osha, omig, nysdoh, hero act, mandatory vaccination what
TRANSCRIPT
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?
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Pandemic Will Increase Compliance Oversight
End Results for Home Care
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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
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Wildfires
Oil Spill
Planned Power Outages
Ransomware Attacks- critical infrastructure
Flooding
Heat waves
PANDEMIC
Home Care and Hospice
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OSHA
HHS
OIG
OMIG
Mandatory Vaccination HERO Act
Home Care and Hospice
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OIG
CDC
OSHA
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Home Care
OSHA- 29 CFR Part 1910
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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
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ETS
OSHA:COVID-19 in the
Workplace
Respiratory
Protection Program
Bloodborne
Pathogens
Sanitation Standard
Respiratory Protection Program
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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.
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
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$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
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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
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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
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Policies
Testing twice a day for COVID
Actual Temperature number
PPE Protection
Local contact information
NYSDOH Surveys
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Patient classification list
Length of time to produce a patient roster
Patient refusal to evacuate
Review your disaster plan
Call down roster
NYSDOH Survey
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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
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HOT BUTTON ISSUE
Provide reasonable time and pay
for employee vaccination
and side effect of
vaccination.
Vulnerable Areas
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Training
Legal Action by patients
Whistleblowing
Documentation for telehealth/telephonic visits
Staying Current
Tracking workforce exposures
Staffing/Patient Care
Cybersecurity
Training
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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
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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
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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.
Reminder
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We are not post-pandemic!
This is not a pandemic about the unvaccinated.
Resources
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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
www.rbclimited.com
RBC Limited
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