Temporary Amendments to Policy and Procedure During Pandemic State of Emergency
During the pandemic State of Emergency, it is necessary to adjust our policies and procedures frequently to meet the needs of individuals, employees, and comply with changes in federal, state, and local regulations. Business operations must all shift to ensuring the health and safety of our individuals, employees, and the community at-large.
The procedures listed below are the operational/procedural amendments to Open Door policies that will be in effect during this time. Due to the rapid changes presented with this unprecedented pandemic, it may be necessary to temporarily implement emergency procedures and alter any current policy in place. Management will send these alerts through email and post on our website.
1. Designated Safety Team/Coordinator:
The designated safety team consists of the Executive Director, Medical Services Manager, Risk Management Director, and HR Benefits Coordinator. Each play a vital role in the pandemic plan for our agency. The Risk Management Director is the point of contact regarding concerns with any individual that receives services and communicates immediately with Director (regarding infection control/COVID-19). The HR Benefits Manager is the designated safety coordinator for all employee concerns related to COVID-19 and is responsible to communicate directly with Director. Medical Services Manager serves as back-up in absence of Risk Management Director or Director.
2. Hazard Assessment/Worksite analysis:
The designated safety team is responsible for revising and completing hazard and work site analysis assessments with a team including those providing direct care, nursing, and non-supervisory duties. These forms will be kept with the Director.
3. Temporary Reassignment of Employees:
Due to Adult Day closures, transportation restrictions, or families choosing to care for own family members during the pandemic, or increased service needs, all Open Door employees may be reassigned to another work area temporarily. Whenever possible, Open Door will offer hours within typical working schedule, but due to the individual’s needs, that may not be possible. Due to the service needs, employees may be required to work alternate hours in order to maintain their employment status. Employees who refuse to work their temporary assignments may be terminated based on Open Door policy.
4. Staffing During Pandemic State of Emergency:
Due to the critical nature of our mission, ALL Open Door employees may be called upon to provide direct care services for any individual, at any location, alternate shift, or assisting DODD, County Board, or another provider to ensure the continuity of care in our DD system in Ohio. It is the expectation that all staff cooperates with the urgent needs of those receiving services at this time. Refusal to respond to reasonable instruction from supervisory staff may result in disciplinary action for Insubordination. This also may require employees to work outside of scheduled work hours or stay over past shift due to coverage being needed.
5. Leave Form Procedures:
Open Door will abide by the leave procedures currently outlined in the policy. (However, due to orders from the State of Ohio, Open Door must adhere to the screening procedures outlined in the amendments below.) During the State of Emergency, Open Door must continue to ensure the health and safety of all individuals served, employees, and the community at large. Open Door will do everything possible to be able to assist employees during this time with their leave requests. However, due to the emergency needs at this time, all staff are expected to be mindful that the individuals depend on our care, and leave requests may be denied based on emergency coverage needs. Leave requests based on employees affected by the COVID-19 outbreak will be the priority at this time. All leave requests must be completed online using the form on our website for leave requests. The HR Benefits Coordinator will be responsible to log any leave request during this time and respond to employees and service teams in a timely manner. Open Door will abide by any temporary changes presented through federal, state, or local governmental direction or legislation related to leaves of absence or other employee-related benefits. These changes will be communicated through mass email and posted to the Open Door website. Open Door will follow the governor’s recommendations regarding out-of-state travel public health advisory system updates weekly. Effective 7/30/2020: If an Open Door employee chooses to travel to one of the designated hot spot states per the governor’s recommendation, they must self-quarantine for at least 10 days upon returning to Ohio before returning to work. The leave form requires employees to disclose this information to HR.
Open Door will allow excused time off for completion of vaccinations or for vaccination side effects. Employee should give advance notice and get approval from scheduling coordinator at least 24 hours in advance to ensure coverage.
6. Attendance Policy:
Open Door will abide by attendance procedures currently outlined in policy. (However, due to orders from State of Ohio, Open Door must adhere to the screening procedures outlined in the amendments below.) During the state of Emergency, Open Door must continue to ensure the health and safety of all individuals served, employees, and the community at-large. Open Door will do everything possible to be able to assist employees during this time. However, due to the emergency needs resulting with pandemic crisis, all staff are expected to be mindful that the individuals depend on our care and attendance for scheduled work times is essential and increasingly critical. Open Door will prioritize those affected directly by COVID-19 first.
Any no-call, no-shows should be noted on scheduling logs. During this period, the logs will either be electronic or scanned and emailed daily including the HR Benefits Coordinator on the email for staff follow-up. They will then contact employees, send letters, etc.
7. Health Screening of Employees, Visitors, Vendors, anyone at Facility or On-site:
The State of Ohio has ordered certain health screening of all employees, visitors, and individuals during this pandemic crisis. Open Door will comply with CDC/EMA/State of Ohio direction which requires EACH employee, visitor, vendor or anyone entering Open Door site to take their temperature and complete screening record before being permitted to enter work area for each shift as listed below. Open Door will limit point of entry to one entrance for all visitors, vendors, or others.
NOTE: Park West designated area is front desk during office hours or weekend/evenings/overnight nursing station.
8. Physical Distancing and Physical Barriers
Open Door promotes physical distancing of at least 6 feet when indoors, whenever possible. Open Door will install physical barriers in fixed, non-patient care areas that can be cleaned when office spaces require 2 people to be within 6 feet for long periods of time while indoors or will implement alternate work locations.
9. Payroll Procedures:
Open Door payroll policies and procedures remain in effect with the following changes:
- If issued with pay, employee must complete online payroll inquiry on Open Door website electronically. Accounting will not be permitted to meet face-to-face with any employee because we must limit exposure for all employees.
- Any employee who does not complete their required clock in and out through the proper electronic system for each shift, will be required to submit timesheet form through online website form titled: TIMESHEET VERIFICATION FORM. As per policy, employees are responsible to submit their own time and comply with EVV regulations, therefore, failure to do so may result in delay in pay. Patterns of not completing electronic clock and out will result in disciplinary action per policy.
- Open Door will utilize direct deposit for payroll according to typically scheduled pay dates during this time. IF an employee requests a paper check due to account change, etc., the paper check WILL be mailed to the employee’s address on the personnel record due to current emergency limitations. The employee is responsible to ensure proper address information is on file and must complete the employee change of information form for any requested change electronically through the Open Door website.
- For alternate assignment pay information, please refer to amendment #1 above.
10. Hiring, Recruitment, Onboarding, & Orientation:
- ALL job postings will be through electronic methods only; no job fairs, group interviews, or other events permitted during this time
- Applications through social media may be accepted during this time
- HR will attempt to contact ALL applications received within one business day of receipt.
- ALL interviews may be completed through telephonic or using other technology during this time.
- Open Door will offer background checks (in designated entrance and room only). Only HR personnel should be in the designated room following 6 feet physical distancing with potential employees.
- HR will collect needed physical documents, complete I9 and background checks utilizing universal precautions. HR will provide potential employees instruction document to complete required schedule for training, schedule/address/contact information for work location, and direct them to the proper clock in and out procedures. All onboarding paperwork will be completed through electronic means on the Open Door website.
- The employee will not be permitted to work until HR confirms completion of DSP training, CPR and first aid, and MAC, if applicable through online electronic training module and signature sheet located on the Open Door website.
11. Medication Administration Certifications:
Medication Administration Certification I, II, III refreshers have been added virtually to the Open Door website under the Employee Hub. ALL staff will still be required to successfully complete ANNUAL MEDICATION ADMINISTRATION RE-CERTIFICATION training through either virtual or in-person methods during this time (when indicated on schedule or by supervisor notification). Staff are required to complete the training in its entirety to meet all topic requirements through MEDICATION ADMINISTRATION REFRESHER modules on the Open Door website, or in-person course. ALL STAFF must complete the THE CORRECT MEDICATION TRAINING ACKNOWLEDGEMENT FORM for each MAC certification taken separately with SIGNATURE FORM indicating completion on required training in order for the training to meet compliance. If technology or assistance is needed to ensure meeting needs, all employees should contact Alisha Emmert, Technology Services Manager for assistance. Skills checks for refreshers may be done virtually at the discretion of the RN delegator.
12. Employee Annual Training:
All staff will still be required to complete annual 8-hour training through virtual methods or in-person using social distancing and preventative measures. Staff are required to complete all topic requirements through ANNUAL TRAINING on the Open Door website or in-person. All staff must complete the ANNUAL ACKNOWLEDGEMENT FORM and ANNUAL TRAINING SIGNATURE FORM indicating completion on required training in order for the training to meet compliance. If technology or assistance is needed to ensure meeting needs, all employees should contact Alisha Emmert, Technology Services Manager for assistance.
13. Staff Meetings, Plan Meetings, & Other Trainings:
ALL staff, team and other meetings may be completed through in-person (practicing preventative measures) or by virtual methods whenever possible. IF technology or assistance is needed to ensure meeting needs, all employees should contact Alisha Emmert, Technology Services Manager for assistance. Face-to-face meetings should be limited unless absolutely necessary for any emergency need. (6 foot physical distancing and universal precautions must be followed).
14. Staff Training Related to COVID-19
ALL staff will receive training in orientation period and at least annually on the following:
- COVID 19 pandemic policies/emergency procedures/respiratory protection plan
- Vaccination education
- Universal precautions
Completion of training will be documented through electronic JotForm. This training will be monitored by HR.
Open Door is working very diligently to obtain needed supplies during this period of crisis. As you know, some items have been limited. The administrative team will be shopping and trying to purchase items to limit staff and individual exposure. We have created an electronic form online that can be completed by any staff at any location at any time to request emergency food, supply, Personal Protective Equipment or other needs. Administration will try to obtain items immediately and will secure drivers to deliver these items directly to the location to staff/individuals. This is to limit outside exposure as much as possible. Open Door will comply with COVID-19 PPE reduction guidelines to use for emergency priorities.
Open Door will also assist with grocery shopping tasks through online ordering methods etc. PLEASE CONTACT CCHS PAYEE OR PC TO ASSIST WITH THESE REQUESTS. WE WILL SECURE SOMEONE TO PICK UP ORDERS AND DELIVER TO LOCATIONS TO STAFF/INDIVIDUALS. Individuals are still responsible to pay for their food items through personal means: food stamps or funds.
16. Medication, Pharmacy, & Deliveries:
Open Door relies on pharmacy services for ensuring medication administration for all individuals. Open Door uses Crosby’s Pharmacy as our contracted pharmacy. Crosby deliveries will be directed to one central location for ICF and to back garage area for SCL. The delivery driver will complete proper health screening requirements prior to delivery/entry into any Open Door site. All employees receiving pharmacy deliveries should follow proper sanitizing and universal precautions and practice physical distancing per 6-foot recommendations at all times. Open Door has designated personnel to deliver medications and medical supplies to homes to prevent DSPs/individuals exposure in travelling to office area.
All vendor or outside deliveries should come through front door entrances only. They will use buzzers to notify there and should receive deliveries outside of the Open Door location. If a vendor or external person has an essential reason that they must enter building, this requires approval of Director, Finance Director, or Associate Director only.
17. Visitors, Volunteers, & Interns:
No Open Door employee is allowed to have any outside visitors at ANY work site or location at this time. The visitor policy may be adjusted if current outbreak for employees or individuals served is identified.
ICF – Open Door adheres to all CDC, ODH, and DODD recommendations regarding Visitations at the ICF locations. (Refer to Open Door ICF Visitation Policy and reopening plan attachment for current details)
Waiver – (Refer to Open Door Waiver Visitation Policy and reopening plan for current details.)
18. Essential Employee Designation:
All Open Door employees that provide direct or medical service in any capacity are considered ESSENTIAL personnel. Therefore, in the State of Emergency or order for shelter in place, Open Door employees are required to still report to work due to the critical nature of our work. Open Door has letters to designate ESSENTIAL STATUS, VERIFICATION OF EMPLOYMENT, AND CARD for employees to carry with them. These should be presented if any questions arise regarding the ESSENTIAL designation of your position.
19. Incident Hotline On-Call & Incident Reporting procedures:
All incident reporting, UI, MUI, and investigative procedures remain in effect per Open Door policy. They are available 24/7 to report any urgent issue and will convey immediately to the executive team. All communications for emergency situations should follow our current emergency policies in the 7.00 series. The Incident investigations should be completed to prohibit face-to-face contact at this time, unless absolutely necessary for emergent abuse/neglect cases only. The Risk Management Coordinators may utilize virtual or telephonic interviews and electronic statements to gather needed information during this time. They should utilize fax, email, and electronic methods to obtain needed documents from outside locations at this time.
20. Corrective Actions & Disciplinary measures:
ALL supervisors should attempt to limit staff travelling to offices whenever possible. Additionally, face-to-face meetings should be eliminated. Therefore, coaching notes or written corrective actions may be presented using telephonic or virtual technology methods. Supervisor and witness must be present for any phone or virtual presentation and sign with date/time/witness name and screenshot/photo of evidence of the interaction proving staff’s presence. Any corrective action resulting in termination MUST be completed by Executive Director, Finance Director, or Associate Director ONLY during this period.
21. Events, Transportation & Community Experiences:
All events or activities which involve the potential for any group of people to congregate in indoors (for example: art exhibitions/shows, company sponsored dances/parties, etc…) must adhere to physical distancing, universal precautions, sanitation, and guidance on facial coverings.
Community experiences will be completed following guidance for physical distancing, mask wearing, and proper universal precautions. Any individual exhibiting symptoms should not be completing community experiences.
22. Medical Appointments & Consults:
During outbreak or state of emergency, medical appointments may be completed for essential medical reasons. Routine appointments may be rescheduled until after extra precautions if not considered emergent or necessity. Staff should contact treatment professionals pre-emptively to inquire about the medical necessity of the appointment or to see if virtual/telemedical options may be available to eliminate need for face-to-face contact. Open Door will assist those needing virtual teledoc options available. If assistance is needed to set up virtual methods, please contact Alisha Emmert, Technology Services Manager. Consult sheets should still be completed indicating cancellations, completion of appointment in person or teledoc to have record of appointment or follow-up needs for rescheduling after State of Emergency is lifted.
23. Isolation Designation & Quarantine Procedures:
IN EVENT OF RECOMMENDATION FOR ISOLATION OR IMMINENT QUARANTINE DESIGNATION:
CAC has dedicated spaces that can be utilized in the instance of needed isolation, quarantine, etc. if it’s in the best interest of individual, staff or community at-large for the quarantine period or isolation care to be completed on-site.
CAC is already equipped with isolation PPE, beds, emergency supplies, medical equipment, food and water supply, etc. If quarantine is initiated, our nurses will work together to ensure one nurse is assigned to this designated location to oversee health and safety giving instructions to Executive Team. The nurses and Executive Team will communicate and direct teams in proper process to ensure best possible health and safety measures for all involved. Open Door will follow recommendations and work with local, state, and federal authorities and follow policies and procedures outlined to ensure health and safety of all involved.
Any media contact should be directed to Executive Director or Marketing/Development Director only.
24. Tours and Intakes:
Tours and intakes should be limited to emergency needs only at this time. Whenever possible, intake meetings and tours should be completed virtually with paperwork completed using online methods.
All Admissions to the ICF via Respite or direct admission require a negative COVID test or proof of being fully vaccinated before admission and attestation that the individual has not been exposed to anyone with COVID or symptoms of and that they have been quarantined for at least 14 days prior to admission.
All new Waiver admissions require team attestation that the individual has not been exposed to anyone with COVID or symptoms of and that they have been quarantined for 14 days prior to admission/start of services. Open Door would like record of vaccination status prior to admission or start of services.
26. Work From Home Procedures:
Due to the extreme nature of this pandemic, there may be times when Open Door employees may be permitted to do work from their home. Any employee working at home must be pre-approved by Director, Associate Director, or Finance Director only. When performing pre-approved work at home, all Open Door employees are required to complete proper clock-in and out procedures in order to be paid. They must comply with all Open Door policies and procedures during the work time. A summary of status of work completed for each shift MUST be submitted via email to department manager and Executive Director. Even if working at home, ALL Open Door employees must be available to respond to emergency coverage needs to provide direct services or support when needed. They must be available by phone during working hours and return any missed call within 15 minutes. Any IT need while working at home, should be forwarded to Technology Services Manager, Alisha Emmert.
Effective September 9th, 2020:
Unless otherwise approved by the Director, an hourly employee who is regularly assigned to a position working on-site (per Open Door office work plan), reports symptoms or the need for quarantine/isolation and are they may not be permitted to work-at-home. They are encouraged to follow quarantine orders or receive negative test. The employee must follow paid time off/leave policies. The employee must communicate directly to the designated COVID personnel contact (Open Door HR Benefits Coordinator).
27. Work at Home, Privacy and Confidentiality:
Open Door must safeguard any employee or individual information. Therefore, when working remotely, each employee may have access to this information that is needed to perform the necessary functions of their job duties. Each employee is required to follow Open Door privacy and confidentiality practices outlined in the policy.
28. Employee Performance Evaluations:
Each year, all employee evaluations are due by May 1st. Open Door is allowing emailed copy of the evaluation to be presented over phone or virtually with employee. After reviewing the evaluation, the employee will sign the acknowledgement form online on Open Door’s website for verification of the evaluation. These will be printed for personnel filing.
29. Individual Funds:
All payee responsibilities will continue during this time. All bills will be paid electronically preferably. Whenever possible, face-to-face contact should be avoided. Therefore, payee may try to reduce needed travel or visits to office. The payee will issue one monthly spending check with amounts for each purpose outlined for individual. Driver will be secured to deliver check to locations with signature approval of its receipt.
NOTE: Stimulus checks for COVID Period are for individual use only. They should be deposited into personal accounts with team to work with individual on how they would like to spend these funds. The team should consider all assets and ensure following guidelines so that individual maintains eligibility for Medicaid and other benefits.
30. COVID-19 Communications, Updates, & Procedures:
The Executive team is committed to transparent communications during this time, therefore, all notices will be sent through mass email distributions. If you are not receiving mass email communications, please subscribe through our website or email/contact Melissa Combs at firstname.lastname@example.org.
Anyone is welcome to receive these updates including community partners, guardians/families, individuals served, employees, etc. Additionally, we have created a dedicated webpage where all COVID-19 response updates will be posted for easy reference.
During declaration of national shortage of PPE, Open Door adopts the recommended crisis time protocols. The full PPE will be prioritized to the quarantined and isolation spaces where positive cases are being cared for or in homes with potential exposures present. There is a supply room of PPE at the Corporate office that can be delivered to locations at any time.
ALL OPEN DOOR EMPLOYEES IN ANY LOCATION ARE REQUIRED TO WEAR FACIAL COVERINGS AT ALL TIMES WHILE INDOORS AND IN VEHICLE WITH INDIVIDUALS SERVED except for when eating/drinking which must be done in space with proper distancing in place. FAILURE TO WEAR FACIAL COVERING WILL RESULT IN CORRECTIVE ACTION UP TO TERMINATION.
Each home will be provided with gloves, masks, sanitizers, etc. Each home may request supplies through online COVID request form and they will be delivered to home.
IF POSITIVE OR SUSPECTED COVID-19 CASE IN LOCATION, Open Door will immediately notify all involved. Open Door will provide proper PPE per guidance. Please refer to full Respiratory Protection Plan for details of the procedures. This includes completion of OSHA medical questionnaire and fit testing prior to staff wearing the N95 respirator. Open Door will supply the N95, gowns, goggles/eye wear in addition to PPE listed above when this situation arises.
32. Sanitation/Environmental Infection Control:
All Open Door locations have been provided with proper sanitation guidelines/environmental infection control information and can request any needed supplies through the COVID REQUEST FORM. Sanitation/cleaning lists should be completed and documented as per attached checklist. Frequent sanitation with approved cleaners assists with reduction in transmission of COVID. All employees will follow attached guidance on handwashing and use of hand sanitizers.
33. Hospice Care in ICF:
Open Door’s highest priority is to keep people safe. According to CDC guidance, health care personnel who work in multiple locations may pose higher risk of transmission. To protect both the individuals served and the employees of Open Door, the following guidance will be followed:
Open Door and Hospice agency must work together to ensure individual’s needs are being met. These needs can hopefully be met by ICF staff in coordination with offsite coordination and consultation with the hospice provider (such as virtual communications, phone, video, documentation and report reviews).
When end-of-life is determined imminent and compassion care is needed, Open Door must ensure that individuals appropriate care, and may allow hospice staff access during this time. Decisions about when to allow hospice visits must be made on a case-by-case basis by facility and hospice together. All hospice staff must also follow all Open Door screening procedures outlined above. They must check in at front desk or nursing station to complete full screening and get permission to enter the buildings accompanied by nurse or designated facility staff.
34. Communal/Family Style Dining:
The CMS guidance from March 13, 2020, indicates risk factors identified in transmission related to congregate/communal dining in LTSS. This includes guidance to cancel communal/family style dining and all group activities. Open Door will take all reasonable steps to implement and adhere to the this guidance based on staff availability, individual ability and needs, environmental constraints. Open Door will continue to follow any CMS update regarding communal dining. May 2021: Open Door began reinstituting dining in the kitchen; however, still tries to follow guidelines below:
Family-Style Dining/Meal practices have been temporarily altered to allow for:
- Serving food in safe, alternate areas for those assessed to be able to feed self
- Identifying high risk individuals and ensuring that they remain at least 6 feet distance from others especially while eating/drinking
- Arrange meal sittings so that roommates are sitting together
- Alternate meal times if needed to ensure proper safety measures (rotate times)
- Staff MUST perform handwashing or sanitizing EACH TIME when switching assistance between residents
- Mealtime focus should be on safety, proper handwashing, hydration, proper diets/texture modifications, and foodservice.
35. Guidance for Discontinuing Transmission-Based Precautions in COVID-19 Patients:
Open Door follows ODH/CDC guidance regarding discontinuation of precautions.
36. OSHA Reporting and Retaliation
Open Door will be responsible to report any work-related COVID-19 fatalities and inpatient hospitalizations as per OSHA requirements. Open Door’s HR Benefits Manager will maintain the occupational exposure log. These records are made available to employees and representatives. No employee will be discharged or discriminated against for exercising their rights under ETS or engaging in required actions.
Last Revised: 7/29/21