Members,
Yesterday, January 11, 2022, TAHCH met with HHSC regarding HCSSA staffing shortages and the contradictions and inconsistencies between the revised CDC guidance for Managing HCP and Mitigating Staffing Shortages, and the HHSC emergency rule and HHSC provider FAQ's.
We pointed out the growing need for HCSSA agencies to implement contingency (when a shortage is anticipated) or crisis (when a shortage is occurring) level staffing shortage plans and how providers are conflicted about whether to follow the CDC guidance or risk being non-compliant with the HHSC emergency rule due to the 14 day contact screening criteria and no allowance for reduced isolation timeframes for employees who are vaccinated, boosted, or within 90 days of prior infection. Following our discussion, they agreed to issue additional guidance related to this. They will also be releasing a staffing shortage checklist for HCSSA agencies that can be used to verify the agency is compliant with steps to take in the event of a staffing shortage, and they plan to address this on the upcoming webinar scheduled for February 11, 2022.
They did clarify that providers should follow the CDC guidance related to staffing shortages and will need to document events leading up to the shortage, when the agency determined a contingency or a crisis plan was needed, and agency actions throughout the shortage to ensure compliance.
We will continue to monitor this issue and will post updates via the Open Forum.