DHS Issues Respiratory Outbreak Guidance for Post-Acute Facilities

September 17, 2020

Throughout the COVID-19 pandemic, hospital have encountered issues when discharging patients to post-acute care because of concerns of COVID-19 transmission.  On Thursday, September 17, 2020, the Wisconsin Department of Health Services (DHS) issued guidance on the prevention and control of respiratory illness outbreaks, including COVID-19, in long-term care facilities (LTCFs).  This guidance may exacerbate the issues hospitals have had  accessing post-acute care for patients.  

The guidance recommends temporary restriction of admissions to LTCFs if a suspected or confirmed case of COVID-19 is identified in the facility, at least until the extend of transmission can be determined and interventions implemented.  Whereas a previous draft version of this guidance recommended restricting admissions to the entire facility, the revised guidance advises the facility to restrict admission to affected units, wings or floors of the facility.

When an initial draft of this policy surfaced in July, WHA expressed concern about its potential impact on hospitals. WHA CEO Eric Borgerding made the following points in an August 18 email to DHS:
  • Hospital Discharges: Hospitals cannot be the designated “holding” place for patients awaiting skilled nursing facilities (SNFs) due to recommended time periods for restricting admissions.
  • Downstream Impact on SNFs: Many SNFs will not be able to weather the storm of closing for the 14- or 28-day time periods on and off and will start closing permanently.  If this happens, hospitals will have even more difficulty finding post-acute care for patients upon discharge.
  • No good alternative options for patients needing SNFs:  There are few infrastructures and payment systems in place for SNF alternatives. Alternative post-acute options for the future must be designed. 
  • Discretion is needed to decide when it is safe to take new admissions.  The DHS memo are described as “guidance,” but the waiting periods may be interpreted as a standard.
The September 17 guidance, which was issued with little notice or stakeholder feedback, does specifically address readmissions of residents who have been hospitalized.  The guidance states that the “facility should consider the readmissions of ill residents (e.g., those returning from a hospital stay), provided that upon return to the facility, the appropriate infection control measures are implemented to protect the health of other residents. Laboratory testing of residents for ARI [acute respiratory illness] (including influenza and COVID-19) prior to readmission is not recommended and should not be used as a criterion for readmission to the facility.”

WHA continues to be concerned about the potential negative impacts this guidance could have on access to post-acute care for hospital patients. While the safety of residents and staff is paramount, WHA encourages DHS to rely on the discretion and expertise of the facilities in determining safe admissions policies.

Questions and comments about this guidance may be directed to Laura Rose or Laura Leitch, WHA’s contacts for post-acute care issues.

This story originally appeared in the September 17, 2020 edition of WHA Newsletter