COVID-19 Update: Ohio issues final plan for health care isolation centers

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Health care isolation centers (HCICs) play an important role in Ohio’s response to the COVID-19 pandemic by relieving pressure on hospitals for post-acute care, conserving existing health care resources through avoiding or delaying hospitalization and supporting long-term care facilities that are unable to maintain sufficient isolation and/or clinical support for residents. To address this role, Ohio has established an HCIC plan to facilitate this process.  

An HCIC is a center that operates under the guidance and monitoring of the Ohio Department of Health (ODH) and specializes in the care of patients with an active or convalescent COVID-19 infection (COVID-19 level of care 3-1 and below) or who have other health care needs and require quarantine for up to 14 days following exposure to COVID-19 (quarantine level of care).

COVID-19 level of care requires: (1) a level of care comparable to that required for admission to a nursing home, (2) a physician order and (3) having a COVID-19 diagnosis (tested or probable). Quarantine level of care requirements are the same, except the third requirement is exposure to COVID-19 that requires quarantine, rather than a COVID-19 diagnosis. An HCIC should not be used for clinically stable individuals who can be treated safely where they live, including congregate settings.  

COVID-19 care needs can be classified in the following levels:

  • Level 1: Minor symptoms. It is preferable that these individuals remain at their residence (including nursing homes and assisted living facilities).
  • Level 2: Requires oxygen or other respirator treatment.
  • Level 3: Does not require hospitalization in all cases but may require care beyond a traditional nursing home’s capacity (may include ventilator or other medical care).
  • Level 4: Consistent with level 3, but deteriorating and requires hospitalization.

All HCICs must be located in physically separate spaces, utilizing either an entire new or existing facility or part of an existing facility (a floor, unit or wing). HCICs will be designated as follows:

  • HCIC-Q: Provide only quarantine level of care.
  • HCIC-I: Provide only COVID-19 level of care 1-3.
  • HCIC-IQ: Provide both quarantine and COVID-19 level of care in separate and distinct units. This includes designated staff and appropriate PPE for each unit.

Requirements for HCIC-I and HCIC-IQ providers: HCIC-I and HCIC-IQ facilities/units must be able to provide level of care 3 with the clinical expertise in caring for individuals with respiratory illnesses; should have a separate entrance for the isolation unit; must have 24/7 access to a pulmonologist or clinician; and, if providing ventilator care, must have a respiratory therapist in the HCIC 24/7.

Requirements for all HCIC providers: All HCIC providers must have a current long-term care facility provider agreement with CMS. Only providers with demonstrated history of providing care at acceptable levels of quality and safety will be considered. Staff working in an HCIC can only work in that HCIC, and the provider must have adequate supplies of PPE and must be able to share patient information with pharmacies, hospitals, nursing facilities and outpatient clinicians. All HCICs must have a dedicated full-time infection control personnel available 24/7. HCIC providers assume all responsibility for discharge planning and coordination of transfers.

Approval process and fiscal considerations: HCICs must be initially approved by the Regional Hospital Zone, documenting “need” for the facility. ODH may approve a waiver to capacity limits through the use of previously de-licensed space, converting single to double occupancy rooms, repurposing common space or administrative areas, or converting unused residential care facility space. An HCIC may also be located in another building that is not currently licensed nursing home space. Any bed increase for an HCIC will be included in the provider’s certified capacity only. The beds will not be included in the provider’s licensed capacity and, therefore, are not subject to the franchise permit fee. The Ohio Department of Medicaid will designate HCICs, which will be reimbursed using a tiered flat per-diem rate based on the level of care needs.

All HCICs will continue to exist until CMS rescinds the 1135 waivers. Any certified bed increase granted for an HCIC will be temporary and the bed operating rights may not be sold or transferred.

Non-HCICs
Ohio’s plan allows nursing homes to surge their capacity to facilitate other nursing homes becoming HCICs or to support the nursing home’s own needs during the COVID-19 pandemic, without becoming an HCIC. The state’s plan describes guidelines and considerations for doing so.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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