In the wake of the COVID-19 global pandemic declaration, hospice providers are faced with the difficult conundrum of ensuring the continuity of care for their vulnerable patients while attempting to comply with the recent CDC and CMS guidelines regarding post-acute care facilities’ lock-down procedures. There is no question the intentions of long-term care facilities are well-meaning in an effort to protect its residents who are most susceptible to COVID-19 complications.[1] However, these precautionary measures put residents receiving hospice services at risk of missing supportive treatment and important care planning.  The American Health Care Association (AHCA) and National Center for Assisted Living (NCAL) derived its skilled nursing facility visitor restriction recommendations from the CMS revised guidance issued March 9, 2020, and hospice providers should take note of these recommendations to ensure they are not prohibited from caring for their patients.

AHCA and NCAL, like nearly every other healthcare organization, are encouraging its members to prevent the spread of COVID-19 throughout its facility by restricting the entrance of “non-essential individuals.”[2] While the associations do not specifically define “non-essential individuals,” undoubtedly hospice providers are far from non-essential. In fact, AHCA and NCAL set forth five key actions to minimize COVID-19 transmission within nursing facilities and the first action states “limit entry to only individuals who need entry.”  AHCA clarifies such individuals are “facility employees, contractors, and consultants who are needed to keep the operations running and assure the residents’ needs are met.” The remaining actions encourage facilities to require hand washing upon entrance and screen individuals attempting to enter the building and turn away those (regardless of whether the individual is an employee, provider, etc.) who exhibit the signs and symptoms associated with Coronavirus (fever, cough, and/or shortness of breath), or had exposure to the disease, such as travel to an affected area or close contact with an individual with a confirmed diagnosis. All clinicians can agree, including hospice providers, any individual who meets the above criteria should be prohibited from entering the facility to protect the health of its residents and employees and someone with the same credentials and qualifications as the absent provider should step into the role. Moreover, the CMS guidance encouraging visitor restrictions in nursing facilities does not classify hospice providers as visitors. The guidance states, “facilities should review and revise how they interact with  . . .  other practitioners (e.g., hospice workers, specialists, physical therapy, etc.), and take necessary actions to prevent any potential transmission,” but gives no indication such steps include banning providers from the facility. In other words, nursing facilities are encouraged to work with hospice providers rather than restrict their entry.

Keep in mind hospice providers should take into consideration any guidance implemented by local and state public health departments.

[1] According to the CDC, older adults and people with chronic medical conditions such as heart disease, lung disease, and diabetes are at a higher risk for severe illness and death related to Coronavirus. Many residents at a Washington State nursing facility died due to COVID-19 complications and throughout the U.S. majority of the COVID-19 related deaths were individuals 70 and older.

[2] AHCA/NCAL COVID-19 Guidance