Here is Clearpol’s opinion on PIN 22-09-ASC, which can be found on our Policies.ai website here alongside the PIN text:
This PIN has updated guidance about quarantine (keep people who have been in close contact with someone infected apart from others) and isolation (keep people with confirmed or suspected infection from those not infected) for staff based on staff vaccination status and staffing levels.
It has tables to guide work restrictions for asymptomatic staff with COVID-19 and for asymptomatic staff with exposures. Depending on whether staff is Boosted OR Vaccinated but not booster-eligible of Unvaccinated with exemption OR Vaccinated and booster-eligible but not yet received booster dose, then the number of days, if any, of work restriction depend on whether the facility has Routine Staffing or a Critical Staffing Shortage (when no longer enough staff to provide safe care to residents based on the facility’s unique circumstances).
In general, asymptomatic staff who have had an exposure do not require work restriction if they have received all recommended COVID-19 vaccine doses and do not develop symptoms or test positive. Restrictions should still be considered for staff who have underlying immunocompromising conditions.
A RCFE may implement more protective procedures and follow guidance for a longer (10-day) isolation period for infected staff or a longer (10-day) quarantine for exposed staff, as indicated in PIN 21-23-ASC. The CDC’s risk assessment framework can be used to determine exposure risk for staff with potential exposure to residents, visitors and other staff with confirmed COVID-19. The exposure period for the source case begins 2 days before the onset of symptoms or, if asymptomatic, 2 days before test specimen collection for the individual with confirmed COVID-19, for contract tracing to identify exposed staff for response testing.
A RCFE should reach out to their local ASC regional office if the recommendations in the tables are not sufficient in relieving critical staff shortages, but they must have made every attempt to bring in additional registry or contract staff and must have considered modifications to non-essential procedures.
The CDSS informational call on 2/16 reviewed this PIN. It also reviewed the updated booster guidance in PINs 22-05-ASC and 22-06-ASC and the documentation requirements in PIN 21-32.1-ASC as well as following the strictest requirements should the federal, state and local health department guidance differ. It also reviewed the visitation requirements in PIN 22-07-ASC and resources for staffing shortages.