Industry Perspective and the Comprehensive Integrated Timeline

In a recent commentary by Jacquelyn Smith Clarke of Hall Booth Smith, P.C., she discussed the importance of maintaining a comprehensive library of COVID-19 documentation.  She noted it is labor intensive, but critical when needed to defend complaints.  She points out that guidance regarding COVID-19 issues has been evolving since the start of the pandemic and maintaining an organized library of these directives at specific points in time is key.  She recommends that long-term care facilities memorialize facility policies and procedures along with outside regulations to provide “consistency of knowledge and reliable evidence to use in support of the care.”

Fortunately for Excelas’ clients, key components of this “library” currently exist.  Excelas has built a database with over 10,000 documents of Federal and State Guidance (for select states).  This database, the Comprehensive Integrated Timeline Tool (CITT), is continually updated as new guidelines are published.

For example, on February 2, 2022, CDC released changes to the guidance for Infection Control for Nursing Homes.  Key updates included:

  • Quarantine for newly admitted residents and for residents who are not up to date with recommended COVID-19 vaccinations and/or who have had contact with an infected person
  • Plan for residents who leave the facility
  • Assign one or more individuals with training in infection prevention and control to provide on-site management
  • Provide supplies necessary to adhere to recommended infection control
  • Ensure residents, health care providers and visitors are educated in current precautions
  • Guidelines for notifying health care providers, residents, and families about outbreaks and reporting to public health authorities
  • Vaccination guidelines for residents and health care providers
  • Physical distancing measures
  • Visitation guidelines
  • Proper use of PPE
  • Testing plan for residents and health care providers
  • Evaluating and managing personnel and residents
    • Identify space in the facility dedicated to monitor and care for residents with confirmed or suspected infections
    • Evaluate residents at least daily
    • Manage residents who had close contact with an infected person
  • Response to new infections in health care personnel or residents

Capturing these new recommendations, while maintaining the previous guidance in the CITT, facilitates a quick basis for comparison to facility policy and procedure changes.  Again, as noted by Ms. Clarke, “a well-organized and user-friendly library of materials showing changes over time provides an excellent roadmap.”  The CITT is that roadmap.

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