Planning Guidance and Documentation Requirements for Residential Providers with a Positive COVID-19 Case

Purpose:

This Information Bulletin provides additional guidance for residential providers, specifically Community Integrated Living Arrangement (CILA), Host Family, waiver funded and non-waiver funded Community Living Facility (CLF), and Children's Group Home (CGH), for operating after a resident or staff member has tested positive for COVID-19, as well as a documentation of activities and policy implementation.

It is the Division of Developmental Disabilities (DDD) expectation that the sections below will be completed by each provider and kept on hand. In the event of a COVID-19 outbreak in a residential setting identified above, the Division may request the document from the provider.

Providers are still responsible for maintaining Emergency Preparedness plans in order to maintain their licensure with the Bureau of Accreditation, Licensure and Certification. In addition, providers should follow the Updated Suggested Guidance for Small Congregate Facilities for specific COVID-19 guidance.

Staffing:

Providers must ensure they meet the health, safety and supervision needs of the individuals they serve after a positive COVID case. Providers may face staffing shortages for a variety of reasons. Providers must complete contingency plans to address how they will support individuals served in the event of limited staff availability. Providers should consider the following:

• A communication plan for calling in off-duty staff, which could include group text, calling tree, and/or mass notification software.
• Policies to encourage individuals to come to work, including sleeping accommodations at the home or nearby locations to minimize travel time.
• A training plan to cross-train staff to fulfill different roles in case the primary person responsible for a given function is not available.
• Relationships and/or contracts with local staffing agencies in the event of severe staffing shortages.
• For individuals with loved ones or family members nearby, agencies could ask these supports if they would be willing to take their loved one home on a short-term basis (if it is safe to do so).

Residential Address	# of staff during normal conditions	Minimum # of staff during crisis
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Staffing Contingency Plans  (in the event of limited staff available)	.
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Communications:

Providers must have a robust communication strategy with direction on communicating COVID-19 positive cases. This policy should include communicating a positive COVID-19 case with an individual's guardian, family and other service providers, including medical professionals, if appropriate; notification to impacted staff and/or roommates; and formal external communication plan for other stakeholders. Providers should routinely share information about the current situation and the steps they have put into place for resident and staff safety. This includes visitation policies and home visiting policies. Note: Providers should not communicate with unauthorized parties about HIPAA protected information.

Provider's should also:

• Maintain emergency contact numbers for staff, partnering providers, individuals, family members and other stakeholders.
• Establish and maintain a relationship with the local health department who is the first line resource for COVID-19 support and guidance, as well as access to PPE.

External Communications	.
(  )  Provider has created and maintains an emergency contact list
(  )  Provider has identified and maintains a list of local health department(s)
(  )  Provider has a formal communication policy and procedure
*These documents should be available for review upon request

Delegation of Authority/Order of Succession:

Agencies should identify key individuals, by name and position, and their successors, in the event the key individual is unable to serve in that capacity due to COVID-19. All individuals listed will have authority to operate in the position they are assuming, to the fullest extent possible, until they are relieved by the next-highest-ranking individual in the event of an emergency.

Key Position	Successor 1	Successor 2	Successor 3
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Critical Functions:

Critical functions are the job functions or services that a provider provides on a normal, daily basis. Delivery of these services must continue without interruption, or resume quickly, despite a positive case of COVID-19. Providers should make a list of their critical functions and confirm they have a system to ensure that critical functions are maintained. For instance: Alternatives if staff are unavailable (Temporarily suspend the function, alternate staffing models, closure of certain areas and reallocation of staff, reduce the frequency of the action, etc.)

Critical Functions	.
(  )  Provider has a list of critical services
(  )  Provider has a mitigation strategy to maintain, resume or manage the function differently
*These documents should be readily available for review if requested

Supply/Equipment:

Adequate supplies, including PPE, and equipment are essential for maintaining critical functions after a positive case of COVID-19 is identified. Providers should make a list of supplies and equipment that are considered essential, assign ownership of tracking these items and create contingency plans in the event the items are limited.

Supply/Equipment	Tracking Owner	Adequate Supply Level
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Supplies/Equipment Contingency Plans	.
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This list is not exhaustive and is not intended as legal advice.

Adapted from the Minnesota Department of Health Long-term Care Contingency Staffing Plan (TEMPLATE)