After nearly a month without new or updated guidance for nursing homes and assisted living facilities (collectively, “LTCFs”), the Centers for Disease Control and Prevention (“CDC”), on May 14, released new guidance focused on the challenges presented by COVID-19 response for LTCFs with residents suffering from Alzheimer’s disease or other forms of dementia.  CDC acknowledges the unique challenges presented by COVID-19 response in a population where disruption to routines, changes in assigned caregivers, use of face masks and other infection control measures may not be understood and may precipitate agitation or a worsening of the symptoms of dementia.

The guidance is directed at LTCFs having dedicated memory care units, though certain elements of the guidance can be adapted to LTCFs that do not have dedicated units but nevertheless serve residents with dementia.

Infection Prevention and Control

In addition to following established CDC guidance for health care facilities generally and for nursing homes and assisted living facilities specifically, CDC recommends that LTCFs consider the following with respect to memory care residents:

• Reminding and assisting residents with frequent hand hygiene, social distancing, and the use of cloth face coverings(if tolerated), though CDC cautions that cloth face coverings should not be used for anyone who has trouble breathing, or is unconscious, incapacitated, or otherwise unable to remove the mask without assistance.
• Using dedicated staff to work only on the memory care unit and to keep staffing patterns consistent. CDC also recommends limiting personnel on the unit to those essential for care.
• Continue providing structured activities in residents’ rooms or staggering them throughout the day to maintain social distancing.
• Providing safe ways for memory care residents to stay active such as by having staff walk with them around the unit or outside.
• Limiting the number of residents in common areas and redirecting ambulatory residents when they get too close to other residents.
• Frequently cleaning high-touch areas.

Residents Suspected of, or Confirmed as, Having COVID-19

When residents in a memory care unit are suspected of, or confirmed as, having COVID-19, CDC recommends:

• Universal use of eye protection and N95 (or equivalent respirators), or face masks if respirators are unavailable, for staff.
• Consideration of the risks and benefits of cohorting the affected residents with other COVID-19 suspected or positive residents in a dedicated unit. While cohorting reduces the exposure risk to other residents and staff, moving memory care residents presents a significant disruption that can result in disorientation, anger, increased risks for falls or wandering, and agitation.  If the provider decides to move residents out of the unit, CDC recommends:
  • Providing information to residents about the move and reminding them of the move, as necessary
  • Informing staff in the receiving unit about the habits and routines of the residents.
  • Staging the new area with familiar objects before moving the resident to make the new space more comfortable for the resident.

While the CDC guidance certainly presents providers with some measures that can readily be implemented to protect both residents and staff, others will require an assessment of available resources, as some providers find themselves stretched thin both with respect to supplies of Personal Protective Equipment and staffing.  Accordingly, providers should undertake a deliberative assessment of the relevant factors and document the steps they ultimately decide to take.