On May 29, 2020, the Pennsylvania Department of Health (“DOH”) issued updated guidance for COVID-19 testing in long-term care facilities, which expands upon the Testing Guidance for Nursing Homes issued by the Centers for Disease Control and Prevention (“CDC”) and supersedes the DOH’s earlier PA-HAN-508 guidance addressing test-based strategies for preventing transmission of COVID-19 in skilled nursing facilities (read more about PA-HAN-508 here). Unlike PA-HAN-508, which addressed the transmission of COVID-19 in skilled nursing facilities, this updated and expanded guidance applies more broadly to all long-term care facilities.[1]

Consistent with previous guidance, the DOH states that COVID-19 testing should not replace, but be used “in addition to,” existing infection prevention and control measures, and can be used to further inform such measures. The updated guidance also specifically addresses the use of antibody testing, advising that antibody tests should not be used to diagnose individuals and should not be used to inform infection prevention and control actions.

The updated guidance reflects the CDC’s three-pronged focus on keeping COVID-19 out of long-term care facilities, detecting cases quickly through facility-wide testing, and stopping transmission through follow-up testing procedures. Specifically, the DOH guidance promotes actively screening residents and healthcare personnel for fever and COVID-19 symptoms daily, and in the event that a new confirmed case of COVID-19 is detected, testing all residents and healthcare personnel (excluding those with a history of confirmed COVID-19).  After testing all residents and healthcare personnel in response to a confirmed case, the DOH suggests follow-up testing to ensure transmission has been terminated.  This includes immediate testing of any resident or healthcare personnel who develops a fever or COVID-19 symptoms, and continuing repeat testing of all previously negative residents and healthcare personnel weekly through at least one 14-day incubation period.

In light of concerns regarding testing capacity at each facility, the DOH specifically offers alternative strategies where testing capacity may prevent the proposed best practices (e.g. prioritize testing based on exposure to confirmed cases rather than universal testing, perform follow-up testing on residents who leave the facility and healthcare personnel who work at other facilities, etc.).

The DOH further offers guidance to adequately plan for universal testing and necessary post-testing measures, including testing logistics, post-testing actions (such as cohorting residents to separate units in three “Zones” based on test results), and return-to-work guidance for healthcare personnel.[2]  The guidance states that skilled nursing facilities should follow such planning guidance “as closely as possible,” while other facilities with more limited nursing and medical support may need to make adjustments to such plans.

It is important to note that this updated guidance represents recommended best practices and does not supersede any formal orders issued.

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[1] For the purposes of this guidance, the term “long-term care facility” is defined to include, without limitation, skilled nursing facilities, personal care homes, assisted living residences, community residential rehabilitation services, long-term structured residences, residential treatment facilities for adults, and intermediate care facilities.

[2] The guidance provides for a COVID + Test (Red Zone), a COVID – Test Potentially Exposed (Yellow Zone), and an Unexposed (Green Zone) to adequately cohort residents and designate staff.