osha, omig, nysdoh, hero act, mandatory vaccination what

B A R B A R A B . C I T A R E L L A R N . M S , N H D P - B C

S U B J E C T M A T T E R E X P E R T A S P R T R A C I E

R B C L I M I T E D H E A L T H C A R E & M A N A G E M E N T C O N S U L T A N T S

OSHA, OMIG, NYSDOH, HERO ACT, Mandatory Vaccination... What Does All

This Mean?


Pandemic Will Increase Compliance Oversight

End Results for Home Care

Copyright 2021. RBC Limited

4

Financial Penalties

More focus on cybersecurity

More Regulation for the entire industry

Staff with expertise in disaster preparedness and infection prevention- probably will have to outsource

After action reports with more emphasis on disaster preparedness

New Focus On Disaster Planning


5

Wildfires

Oil Spill

Planned Power Outages

Ransomware Attacks- critical infrastructure

Flooding

Heat waves

PANDEMIC

Home Care and Hospice


6

OSHA

HHS

OIG

OMIG

Mandatory Vaccination HERO Act

Home Care and Hospice


OIG

CDC

OSHA


Home Care

OSHA- 29 CFR Part 1910


9

GRAVE DANGEROSHA has determined that an ETS is necessary to protect

healthcare and healthcare support employees in covered

settings from exposures to SARS-CoV-2.

Use a multilayered approach with an emphasis on

infection control, vaccination

Unique Standard


10

ETS

OSHA:COVID-19 in the

Workplace

Respiratory

Protection Program

Bloodborne

Pathogens

Sanitation Standard

Respiratory Protection Program


11

1910.134(a)(2) A respirator shall be provided to each employee when such equipment is necessary to protect the health of such employee. The employer shall provide the respirators which are applicable and suitable for the purpose intended. The employer shall be responsible for the establishment and maintenance of a respiratory protection program. The program shall cover each employee required by to use a respirator.

https://www.osha.gov/laws-regs/interlinking/standards/1910.134(a)(2)

OSHA Respiratory Protection Program


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Use a respirator when caring for suspected or confirmed COVID-19 patients.

medical evaluation

selection of respirators

fit testing

OSHA Enforcement


13

$3.5 million in violations 2020

Implement a written respiratory protection program.

Provide workers with a respirator fit test, training on the proper use of a respirator and personal protective equipment.

Report an illness or fatality.

Record an illness on OSHA recordkeeping forms.

Office of Inspector General Active Work Plan


14

Home Health Agencies' Emergency Communication Plans: Strengths and Challenges Ensuring Continuity

of Care During A Disaster

This evaluation will determine selected HHAs' compliance with EP CoPs (CHHAs) and will report factors these HHAs identify as hindering and/or supporting continuity of care during a disaster.

2023 should see findings

OIG/OMIG Pandemic Response Oversight


15

Financial- CARES Act Spending

State plans

Falsifying COVID Vaccination Cards- expect to see request as part of personnel review

Future Plans

Make recommendations to overhaul CMS Emergency preparedness standard

NYSDOH COVID Surveys


16

Policies

Testing twice a day for COVID

Actual Temperature number

PPE Protection

Local contact information

NYSDOH Surveys


17

Patient classification list

Length of time to produce a patient roster

Patient refusal to evacuate

Review your disaster plan

Call down roster

NYSDOH Survey


18

Updated list of addresses, telephone, cell phone and pager numbers of agency staff.

Pertinent patient data including patient name, telephone number, emergency contact information, address, physician’s name and telephone number, diagnosis, physician orders and patient severity code, transportation assistance level, identification of patients who are dependent on electricity or oxygen to sustain life, and other patient specific needs or special information that may be critical during an emergency.

Maps of local streets and roads in every county served.

Telephone books for every county served.

Map of patients’ locations against those of staff.

Emergency Disaster Resource List

Mandatory Vaccination


19

HOT BUTTON ISSUE

Provide reasonable time and pay

for employee vaccination

and side effect of

vaccination.

Vulnerable Areas


20

Training

Legal Action by patients

Whistleblowing

Documentation for telehealth/telephonic visits

Staying Current

Tracking workforce exposures

Staffing/Patient Care

Cybersecurity

Training


21

In a language employees can understand

Topics are hand hygiene, COVID 19 transmission, mask wearing, use of PPE, and s/s of the disease process

Provide employer specific p&p

Identify tasks and situation for risk of transmission in the workplace

Infection control policies

PPE

Point Of Care COVID Testing


22

FDA Clarifies CLIA-waived Status for Point-of-Care SARS-CoV-2 Tests under Emergency Use Authorizations

The U.S. Food and Drug Administration (FDA) recently clarified that, when it grants an Emergency Use Authorization (EUA) for a point-of-care test, that test is deemed to be CLIA-waived. For the duration of the national emergency declaration for COVID-19, such tests can be performed in any patient care setting that operates under a CLIA-Waiver Certificate.

CLIA


23

As defined by CLIA, waived tests are simple tests with a low risk for an incorrect result. They include:

Certain tests listed in the CLIA regulations

Tests cleared by the FDA for home use

Tests that the manufacturer applies to the FDA for waived status by providing scientific data that verifies that the CLIA waiver criteria have been met

Sites that perform only waived testing must have a CLIA certificate and follow the manufacturer’s instructions.

https://www.cdc.gov/labquality/waived-tests.html

Reminder


24

We are not post-pandemic!

This is not a pandemic about the unvaccinated.

Resources


25

RBC Limited’s new OSHA workplace safety plan template

https://www.rbclimited.com/product/workplace-safety-for-occupational-exposure-to-covid-19-e-

book- $200.00 special price

https://files.asprtracie.hhs.gov/documents/home-care-and-hospice-workplace-safety-checklist.pdf

48 West Pine Road

Staatsburg, NY 12580

T- (845) 889-8128

F- (845) 889-4147

E - [email protected]

www.rbclimited.com

RBC Limited

26Copyright 2021. RBC Limited

osha, omig, nysdoh, hero act, mandatory vaccination what

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