On March 13, 2020, the Centers for Medicare & Medicaid Services (CMS) issued guidance to nursing homes on COVID-19 (coronavirus). CMS is directing nursing homes to restrict all visitors and non-essential health care workers from entering facilities, except in end-of-life and other compassionate care situations. While COVID-19 presents significant danger to vulnerable nursing home residents, a blanket restriction of access to family members may place residents at risk of additional unmet care needs.
Decades of studies have concluded that too many nursing homes suffer from understaffing. For example, a 2019 Health Affairs study found that nursing homes had “large daily staffing fluctuations, low weekend staffing, and daily staffing levels often below the expectations of the Centers for Medicare & Medicaid Services (CMS).” In the absence of adequate staffing, even under normal circumstances, families may need to continue caregiving after their relatives and friends are admitted to nursing homes.
CMS recognizes the importance of family caregivers in surveyor guidance, using the terms “family” and “families” over 200 times. In fact, CMS states that, when residents do not have an effective family support system, nursing homes should provide social services or obtain outside support for residents.
In light of the outsized role that family caregivers have on quality of care and quality of life, we respectfully ask CMS to revise its March 13th guidance to recognize family caregivers as essential health care workers. Family caregivers should be subject to the same CDC guidelines for screening as essential health care workers. Those who pose minimal risk should be allowed to enter nursing homes using all of the same precautions as essential health care workers.
Note: On March 4, 2020, CMS issued a memorandum suspending non-emergency health inspections nationwide. Until further notice, CMS is directing state survey agencies to focus on a limited set of inspections and to prioritize all immediate jeopardy complaints, allegations of abuse and neglect, and complaints alleging infection control violations. The memorandum appears to suspend all other complaint inspections. This suspension makes it even more critical for properly screened family caregivers to have access to residents, as nursing homes potentially shift focus away from the non-impacted standards of care.
March 19, 2020 – D. Valanejad