CDPH Describes Hospital Surge Monitoring Visits, Other Survey Activity
The California Department of Public Health (CDPH) has issued All Facilities Letter (AFL) 20-69, which outlines the survey activities the department will conduct for both hospitals and skilled-nursing facilities.
CDPH is monitoring the daily COVID-19 data reporting that hospitals complete. Based on the data, if CDPH determines a hospital is at risk of surging, the hospital will receive a check-in phone call about its surge plan, any urgent needs, and whether it needs assistance from CDPH. If a hospital is considered at high-risk, CDPH may conduct a surge monitoring visit to evaluate the hospital’s surge preparedness and infection control practices. CDPH has prepared the Hospital Surge Monitoring Checklist for hospitals to self-assess their surge preparedness and compliance with infection control requirements.
Regarding survey activity for hospitals, CDPH will also:
- Prioritize complaints and facility-related incidents
- Conduct federal revisit surveys for hospitals that were cited an immediate jeopardy violation
- Conduct limited state licensing survey activities, including initial licensing, change of service, and change of location surveys
Finally, CDPH recommends hospitals use the Centers for Medicare & Medicaid Services (CMS) Infection Control Checklist in QSO-20-20-All to conduct a voluntary self-assessment of their infection control plans and protections.
CDPH Requires Weekly Testing of All Skilled-Nursing Facility Staff
CDPH has issued AFL 20-53.3, updating its guidance for testing health care personnel and residents at skilled-nursing facilities. The revised AFL clarifies and aligns with the CMS interim final rule on testing, and Centers for Disease Control and Prevention guidance and terminology. Among the important updates:
- Skilled-nursing facilities without positive COVID-19 cases are required to test all health care personnel weekly.
- Those with a positive COVID-19 case are required to implement response-driven testing, as described in the AFL.
- Use of point-of-care antigen test instruments and associated requirements
- Test reporting requirements
The AFL also clarifies policies for testing newly admitted/readmitted residents and residents previously diagnosed with COVID-19, and quarantine for newly admitted residents.
New Resources for COVID-19 Supplemental Paid Sick Leave Law, Effective Sept. 19
The labor commissioner has released a notice to be used to advise employees of their right to COVID-19 supplemental paid sick leave beginning Sept. 19. While the law requires employers to post a notice and directs the Labor Commissioner to make a sample notice available, it appears that the Labor Commissioner is taking the position that its notice must be used — which would not preclude an employer from also issuing its own notice to employees.
The Department of Industrial Relations has also updated its website to incorporate frequently asked questions about both the food sector supplemental paid sick leave that was adopted in April and the newly adopted COVID-19 supplemental paid sick leave (note that some errors exist in the new FAQs, and CHA has requested they be addressed).
Because the COVID-19 supplemental leave obligations are based, in part, on existing California’s paid sick leave law, the FAQs applicable to that law may also be helpful. For example, one common question is whether COVID-19 supplemental leave may be paid in the pay period after the leave was taken. The new law incorporates existing Labor Code 246(n), which allows an employer to pay for the time off “no later than the payday for the next regular payroll period after the sick leave was taken.” The FAQs note that the existing paid sick leave law “requires that an employer provide payment for sick leave taken by an employee no later than the payday for the next regular payroll period after the sick leave was taken. This does not prevent an employer from making the adjustment in the pay for the same payroll period in which the leave was taken, but it permits an employer to delay the adjustment until the next payroll. For example, if you did not clock in for a shift and therefore were not paid for it but utilized your paid sick leave, your employer would have to pay you not later than the following pay period and account for it in the wage stub or separate itemized wage statement for that following regular pay period.”
It should be noted that the COVID-19 supplemental paid sick leave is in addition to current paid sick leave obligations, and not all aspects of existing law apply to the new COVID-19 supplemental paid sick leave.
Guidance Addresses Rapid Antigen Tests
CDPH has released guidance on the use of rapid antigen tests for COVID-19 in symptomatic individuals. The guidance includes information on performing, processing, interpreting, and appropriate use of the tests. Tests currently given emergency use authorization by the Food and Drug Administration (FDA) include:
- Quidel Sofia SARS Antigen FIA Assay
- BD Veritor System for Rapid Detection of SARS-COV-2
- LumiraDX SARS-COV2 Antigen Test
- Abbott BinaxNOW COVID-19 Ag CARD
Antigen tests offer many advantages — fast turnaround, easy point-of-care use, identification of current viral infection, and lower cost. However, the tests’ drawbacks include lower sensitivity (more false negatives) and intended use limited to individuals suspected of COVID-19 within five to 12 days of symptom onset (number of days varies by manufacturer).
Recommendations for Non-Emergency Transportation of SNF Residents
CDPH has issued AFL 20-70, which recommends that skilled-nursing facilities coordinate with their non-emergency medical transportation and non-medical transportation providers, in accordance with the Department of Health Care Services guidance.
Next CDPH Call for Health Care Facilities: Sept. 22, 8-9 a.m. (PT)
Dial: (844) 721-7239
Passcode: 7993227
Summary of Sept. 15 CDPH Call
CDPH has provided a summary of its most recent weekly call with health care facilities.
Upcoming CMS Calls
CMS will host its Lessons from the Front Lines call on Friday — a joint effort between CMS Administrator Seema Verma, FDA Commissioner Stephen Hahn, MD, and the White House Coronavirus Task Force. Physicians and other clinicians are invited to share their experiences, ideas, strategies, and insights with one another related to their COVID-19 response. CMS will also host five other calls next week. Details are as follows:
- Lessons from the Front Lines: Sept. 18 at 9:30 a.m. (PT)
Dial: (833) 614-0820
Passcode: 4446447
Audio Webcast - Hospitals: Sept. 22 at 2 p.m. (PT)
Dial: (833) 614-0820
Passcode: 2409459
Audio webcast - Home Health & Hospice: Sept. 22 at noon (PT)
Dial: (833) 614-0820
Passcode: 1169237
Audio webcast - Nursing Homes: Sept. 23 at 1:30 p.m. (PT)
Dial: (833) 614-0820
Passcode: 5839938
Audio webcast - Dialysis Organizations: Sept. 23 at 2:30 p.m. (PT)
Dial: (833) 614-0820
Passcode: 7026727
Audio webcast - Nurses: Sept. 24 at noon (PT)
Dial: (833) 614-0820
Passcode: 5872398
Audio webcast