The WTW Senior Living Center of Excellence is closely monitoring COVID-19 developments, and will provide updates and additional resources as new information becomes available.
Please contact Elizabeth Schmidt with questions.
The WTW Senior Living Center of Excellence is closely monitoring COVID-19 developments, and will provide updates and additional resources as new information becomes available.
Please contact Elizabeth Schmidt with questions.
Nursing Home Reopening Recommendations for State and Local Officials - CMS is providing recommendations to help determine the level of mitigation needed to prevent the transmission of COVID-19 in nursing homes. The recommendations cover the following items: Criteria for relaxing certain restrictions, mitigating the risk of resurgence, visitation and service considerations, and restoration of survey activities.
Restoring Community Operations during COVID-19 is a best practice guide that addresses assigning responsibility, infection control, monitoring and surveillance, and other practice criteria for safely restoring community operations.
COVID-19 New Admission Recovery is a planning guide for new community Resident admissions. The guide addresses admissions planning, COVID-19 testing, admission agreement language, and physician oversight during the recovery phase of COVID-19.
COVID-19 and the spread of infection are key concerns for operators. Reopening office spaces during the recovery phase will require increased sanitation and infection control practices. The Reopening Office Spaces Guide will assist in providing best practice guidance for reopening office spaces and controlling the spread of COVID-19 infection and assist in providing guidance to ensure a safe working environment.
Community Administered Vaccinations - There are risk implications that should be reviewed when communities consider using their own staff to vaccinate residents and employees. This paper provides information that will assist a senior living operator in administering COVID-19 vaccinations.
Federal and State OSHA Plan Standards for COVID-19 - All employers should be aware of Federal OSHA’s respiratory protection standard requirements and the new temporary standard requirements, where applicable.
Sample Policy and Procedure for Communicable Disease Outbreak
COVID-19 Environmental Insurance Considerations
Respiratory Protection Program - This written program establishes protocols for maintaining an OSHA compliant respiratory protection program, if your associates must wear a respirator (N95 or greater level protection) to provide direct care for residents with suspected or confirmed COVID-19 diagnoses.
Aerosol Transmissible Diseases Prevention Plan Template - This plan addresses the requirement for SNFs, Home Health Care, Long Term Care and Hospice Facilities in California to comply with Cal OSHA's ATD standard.
Table Top Drills: COVID-19 Resurgence in the Local Community - The goal of table top exercises is designed to prepare for disaster, emergencies and related issues in advance of an actual situation occurring. This template is meant to help the leaders of the community make decisions and access and deploy resources as the emergency and needs evolve.
Telehealth as a COVID-19 Solution
COVID-19 vaccine: Employment practices liability implications - With a vaccine becoming available, employers must be prepared for potential risk exposures.
WTW Head of Liability Claim Consulting, Jim Dorion has been working closely with the leaders of Argentum and ASHA, to drive tort and civil immunity at both the state and federal levels. Such efforts include drafting of a model executive order and model legislation, requesting an expansion of the PREP ACT, and advocating for additional federal legislation. These efforts are critical to protect the front-line workers and organizations who are working nonstop to protect residents. For more information and the latest updates, please contact Jim Dorion.
Leading Age has started to track the vaccine mandate trends in each state; as of February 1, 2022, we find that 25 states have vaccine mandates; 13 states (so far) have vaccine mandate bans. Six states now have mandates for boosters and/or “up to date” vaccine statuses. Sixteen of the states with mandates have language specific to healthcare settings or long term care. Some states’ mandates are strictly ‘vaccinate or terminate;’ others have a ‘vaccinate or weekly testing’ dichotomy. This article will be subject to change and updated as there are new developments.
The Occupational Safety and Health Administration (OSHA) released an enforcement memorandum providing guidance for a highly focused, short term inspection initiative directed at hospitals, skilled nursing and assisted living care facilities that treat or handle COVID-19 patients.
Insurers evaluate every claim individually on its own merits. We provided some guidance on insurance considerations for each line of coverage during the senior living webinar on March 10. You can listen to the webinar replay or access these specific slides here. Please also refer to our Forensic Accounting & Complex Claims Practice Insurance Recovery brochure that describes the steps with an insurance recovery process. Contact your WTW claim consultant or a member of your service team with specific questions regarding your coverage.
The WTW Senior Living Center of Excellence will post links to various websites and materials that we have vetted and think would be helpful reference tools for senior living operators. We will include a brief description of the purpose for referencing the link. This is where you will find resources recommended and discussed during our Open Forums and webinars.
The FDA has approved two COVID-19 vaccines to prevent COVID-19 caused by severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) in individuals 16 years of age and older. The first vaccine approved, known as Pfizer-BioNTech COVID-19 will now be marketed as Comirnaty, for the prevention of COVID-19 disease in individuals 16 years of age and older. The vaccine also continues to be available under emergency use authorization (EUA), including for individuals 5 through 15 years of age and for the administration of a third dose in certain immunocompromised individuals.
On January 31, 2022, the FDA announced the second approval of a COVID-19 vaccine. The vaccine has been known as the Moderna COVID-19 Vaccine, and will now be marketed as Spikevax, for the prevention of COVID-19 in individuals 18 years of age and older. Spikevax has the same formulation as the EUA Moderna COVID-19 Vaccine and is administered as a primary series of two doses, one month apart. Spikevax can be used interchangeably with the EUA Moderna COVID-19 Vaccine to provide the COVID-19 vaccination series.
For more information, check out the following links and resources:
Industrial hygiene vendors: The 2020 AIHA (American Industrial Hygiene Association) Consultants Listing provides a comprehensive directory of occupational and environmental health and safety professionals that can assist you with onsite fit testing. This option could facilitate fit testing when test kits are not available for you to use.
CDC streamlines COVID-19 guidance to help the public better protect themselves and understand their risk - CDC is streamlining its COVID-19 guidance to help people better understand their risk, how to protect themselves and others, what actions to take if exposed to COVID-19, and what actions to take if they are sick or test positive for the virus. COVID-19 continues to circulate globally, however, with so many tools available to us for reducing COVID-19 severity, there is significantly less risk of severe illness, hospitalization and death compared to earlier in the pandemic.
Updates on return to work for health care personnel - Asymptomatic health care personnel who have had a higher-risk exposure do not require work restriction if they are up-to-date with all recommended COVID-19 vaccine doses and do not develop symptoms or test positive for SARS-CoV-2. The duration of protection offered by booster doses of vaccine and their effect on emerging variants are not clear; additional updates will be provided as more information becomes available.
COVID-19 Vaccines for Moderately to Severely Immunocompromised People - The CDC recommends people who are moderately to severely immunocompromised should receive an additional dose of mRNA COVID-19 vaccine after the initial 2 doses. Immunocompromised people have accounted for a large proportion of hospitalized breakthrough cases. This link provides details on an additional third dose.
Strategies for Sharps Disposal Container Use During Supply Shortages – Currently, there are supply shortages of sharps containers in the United States (as of April 1, 2021). This PDF document provides practical guidance for you to follow to conserve your supply of sharps containers and what to do if you run out of your supply of sharps containers, following OSHA regulations.
Mitigating Staff Shortages - Maintaining appropriate staffing in healthcare facilities is essential to providing a safe work environment for healthcare personnel (HCP) and safe patient care. As the COVID-19 pandemic progresses, staffing shortages will likely occur due to HCP exposures, illness, or need to care for family members at home. Healthcare facilities must be prepared for potential staffing shortages and have plans and processes in place to mitigate these, including providing resources to assist HCP with anxiety and stress. This link provides CDC guidance and updates.
Vaccine Benefits - Residents and staff may be concerned about getting vaccinated once a COVID-19 vaccine is available in the United States. While these vaccines are being developed as quickly as possible, routine processes and procedures remain in place to ensure the safety of any vaccine that is authorized or approved for use. This link provides CDC facts about COVID-19 vaccines.
Post-Vaccine Considerations for Healthcare Personnel - The CDC has released strategies that are needed for healthcare facilities to appropriately evaluate and manage post-vaccination signs and symptoms among healthcare personnel (HCP). The approach described in this link is intended to reduce the risks for disruptions in care and pathogen (e.g., SARS-CoV-2) transmission resulting from:
These considerations are based on the current understanding of signs and symptoms following COVID-19 vaccination, including timing and duration, and might change as experience with the vaccine accumulates.
Post-Vaccine Considerations for Residents - The CDC has published post-vaccine strategies for residents of long-term care facilities. Strategies are needed by long-term care facilities to appropriately evaluate and manage post-vaccination signs and symptoms among their residents. The approach described in this document is intended to balance:
While this guidance is intended for long-term care facilities, it could also be applied to patients in other healthcare settings. These considerations are based on the current understanding of signs and symptoms following COVID-19 vaccination, including timing and duration, and might change as experience with the vaccine accumulates.
COVID-19 Vaccination Program Interim Playbook - Pandemic vaccination response planning requires collaboration among a wide range of public- and private-sector partners. Significant additional planning is needed to operationalize a vaccination response to COVID-19, which is much larger in scope and complexity than seasonal influenza or other previous outbreak-related vaccination responses. Following the planning and improvement guidance in the COVID-19 Vaccination Program Interim Playbook can assist in developing a baseline readiness to launch the COVID-19 Vaccination Program.
Guidance on everyday steps for cleaning and disinfecting your facility
PPE Sequencing - This document provides step-by-step directions on how to don and doff required infection control PPE, when caring for residents with suspected or confirmed COVID-19 diagnoses. Anyone who must enter a room or isolation area/room should be trained with successful return demonstration on these procedures. It is also recommended to post this document in areas where associates must follow these procedures (i.e. isolation areas/rooms).
Infection Prevention and Control Assessment Tool
Recommended Guidance for Extended Use and Limited Reuse of N95 Filtering Facepiece Respirators in Healthcare Settings
Interim guidance on criteria for return to work for healthcare personnel with confirmed or suspected COVID-19
Strategies to Optimize the Supplies of PPE and Equipment
Long Term Care Respiratory Surveillance Line List is an audit tool that is referenced in the CDC COVID-19 preparedness checklist. This tool can assist with tracking respiratory outbreaks in a community and for surveillance of both residents and staff.
The Inter-facility Infection Control patient transfer form can assist in fostering communication during transitions of care and promotes communication of healthcare associated infections between transfer and receiving health care centers.
CDC guideline for isolation precautions - The transition of healthcare delivery from primarily acute care hospitals to other healthcare settings (e.g., home care, ambulatory care, free-standing specialty care sites, long-term care) created a need for recommendations that can be applied in all healthcare settings using common principles of infection control practice, This link provides infection control precautions that can be applied in all health care settings and be easily adapted for senior living providers.
CDC guidance to assist in preventing the spread of COVID-19 in retirement communities and independent living - This COVID-19 guidance is for owners, administrators, operators, workers, volunteers, visitors, and residents of retirement communities and ILF that are not healthcare facilities.
CDC checklist for COVID-19 preparedness for nursing homes and other long-term care settings - Identifies key areas that long-term care facilities should consider in their COVID-19 planning. This can be used to self-assess the strengths and weaknesses of current preparedness efforts.
CDC guidance for Memory Care Units on Infection prevention strategies to prevent the spread of COVID-19 - Infection control prevention strategies are especially challenging to implement in dedicated memory care units where numerous residents with cognitive impairment reside together. For example, residents can have a difficult time following recommended infection prevention practices such as social distancing, washing their hands, avoiding touching their face, and wearing a cloth face covering for source control. This link provides infection control considerations for Memory Care Units in Long Term Care Facilities during COVID-19.
CDC guidance on testing healthcare personnel for SARS-CoV-2 - This update provides recommendations from the CDC Decision Memo that asymptomatic people who have recovered from SARS-CoV-2 infection may not need to undergo repeat testing or quarantine in the case of another SARS-CoV-2 exposure within 3 months of their initial diagnosis. The update also provides information on key points for testing healthcare personnel (HCP).
CDC guidelines to improve the fit and filtration of your mask - This update provides information on correct and consistent mask use to reduce the spread of COVID-19 and provides updates to general principles for mask use.
The Federal Register - Effective May 21, 2021, CMS requires Medicaid and Medicare skilled nursing facilities to report COVID-19 vaccination status for staff and residents, with the possibility of requiring assisted living to also report this information. This interim rule is open for comment.
CMS COVID-19 Toolkit: This is a compendium of state’s actions for mitigating COVID-19, including testing initiatives, in nursing homes. Information can be applied to assisted living.
Fact Sheet: Sweeping Regulatory Changes to Help U.S. Healthcare System Address COVID-19 Patient Surge
COVID-19 Long-Term Care Facility Guidance for staffing and infection control
April 2, 2020 publication on issuing new recommendations to state and local governments and long-term care facilities to help mitigate the spread of the COVID-19. The publication addresses infection control, PPE supplies, symptom screening and separate units.
COVID-19 Focused Infection Control Survey tool provides a focused review of the critical elements associated with transmission of COVID-19, will help surveyors prioritize survey activities while on-site and identify survey activities which can be accomplished offsite. This tool can be used by senior living providers in preparing for survey and development of infection control programs.
CMS is providing recommendations to help determine the level of mitigation needed to prevent the transmission of COVID-19 in nursing homes. The recommendations cover the following items: Criteria for relaxing certain restrictions, mitigating the risk of resurgence, visitation and service considerations, and restoration of survey activities.
Executive Orders by State and Classification - The Council of State Governments is our nation’s only organization serving all three branches of state government. CSG is a region-based forum that fosters the exchange of insights and ideas to help state officials shape public policy.
Staff Isolation or Quarantine after COVID-19 Exposure
Federal OSHA
OSHA COVID-19 Healthcare Emergency Temporary Standard (ETS) Worksite Checklist- Employers in settings where employees provide healthcare services or healthcare support services may use the following Worksite Checklist to implement worker protections from COVID-19 in compliance with the OSHA COVID-19 Healthcare Emergency Temporary Standard (ETS).
OSHA withdraws COVID-19 ETS- The Occupational Safety and Health Administration (OSHA) has announced that it is withdrawing most of the Emergency Temporary Standard for healthcare employers (Healthcare ETS) it promulgated more than six months ago.
The agency did not withdraw recordkeeping provisions requiring COVID-19 logs and case reports, as they were promulgated under separate provisions of the Occupational Safety and Health Act (OSH Act).
OSHA COVID-19 Frequently Asked Questions on vaccinations
President Biden signed an executive order on January 21, 2021 requiring OSHA to determine if a temporary emergency standard to address the COVID-19 pandemic is necessary.
OSHA published updated guidance on Mitigating and Preventing the Spread of COVID-19 in the Workplace on January 29, 2021.
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Respiratory Protection Guidance - In this guide, you will find an explanation of the differences between cloth face coverings, facemasks, FDA-authorized surgical masks, NIOSH approved N95 respirators, and FDA authorized surgical N95 respirators. This document also reviews the requirements for implementing an OSHA compliant respiratory protection program with excellent resource links to information on NIOSH approved vs. counterfeit N95 respirators, contingency and crisis capacity guidelines, and OSHA’s temporary enforcement guidelines for respiratory protection.
7 Steps to Putting On and Taking Off a Respirator Awareness Posters in English and Spanish
Revised Enforcement Guidance for Recording Cases of Coronavirus Disease 2019 (COVID-19)
Guide to identify fake 3M N95 Respirators – Counterfeit 3M N95 respirator masks are circulating within the United States. These respirators may not provide the level of protection needed to prevent employee exposure to COVID-19. This guide will help you to identify if you have counterfeit 3M N95 respirators and what to do if you have them.
FAQs on Telehealth and HIPAA during COVID-19 nationwide public health emergency
Interim Guidance on Infection Prevention and Control - The WHO published interim guidance on infection prevention and control for long-term care facilities in the context of COVID-19. This link provides key points to the WHO guidance on long-term care facilities, high-risk settings, and COVID-19 transmission. The publication also highlights policies, procedures and infection prevention and control measures to mitigate the spread of infection. The published guidance provides details on vaccine programs, masking and ventilation measures in addition to key principles for prevention and early detection of SARS-COV-2.
U.S. Department of Labor
The U.S. Department of Labor’s Wage & Hour Division’s website identifies frequently asked questions and answers related to the Federal Labor Standards Act and COVID-19 at it’s webpage: Department of Labor - COVID-19 and the Fair Labor Standards Act Questions and Answers. As recommended by the DOL, you will still need to also consult any applicable state labor office, and a link is provided at the above website.
On May 28, 2021, The U.S. EEOC updated their technical assistance guide which addresses questions arising under the federal equal employment opportunity (EEO) laws. In this updated technical assistance, the EEOC updates the Section K, Vaccinations section and expands previous guidance including addressing the use of incentives under the Americans with Disabilities Act (ADA) and the Genetic Information Nondiscrimination Act (GINA). This technical assistance also further addresses questions regarding employee vaccinations, including the EEOC’s updated guidance on assessing a “direct threat” in the workplace and potential reasonable accommodations to be considered, as well as further guidance on Title VII and responding to religious objections to a vaccine. See, COVID-19 Vaccinations: EEO Overview beginning at K.1 of the technical assistance.
The EEOC also posted a new resource, Federal Laws Protect You Against Employment Discrimination During the COVID-19 Pandemic: for new applicants and employees to explain the federal employment discrimination laws and to outline the rights and responsibilities of employees during the pandemic.
It is important to remember that the U.S. EEOC and the above links refer to federal EEO laws, and that other federal, state and local laws should be consulted as it relates to COVID-19 and employment. Legal counsel should be consulted to ensure compliance with all applicable laws.
8 Questions Employers Should Ask About Coronavirus
Association for Professionals in Infection Control and Epidemiology - This site has multiple resources on infection control and prevention for senior living and long term care settings
Argentum Coronavirus Preparation and Response Toolkit
American Seniors Housing Association
California Assisted Living Association
Centers for Disease Control
CDC's Clinician Outreach and Communication Activity (COCA)
Emergency Care Resource Institute (ECRI) COVID-19 Resource Center
Map of COVID-19 Global Cases by Johns Hopkins University
National Institutes of Health
OSHA COVID-19 Page
World Health Organization
For additional resources and information please visit WTW’s COVID-19 microsite. This site is updated frequently with new information.
Please contact Elizabeth Schmidt with questions.
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