COVID-19 Resources

CCHN has created this page for CHCs to gather and provide up to date information related to the COVID-19 public health emergency. If you have any suggestions for this page or specific questions please don’t hesitate to reach out to anyone at CCHN. 

CCHN Summary of State and Federal Policies for CHCs re: COVID-19 Response

Available here.

This document is a summary of state and federal policies recently enacted to help in the response to the novel coronavirus, COVID-19. The policies summarized here include executive orders, directives, emergency rules, legislation, and other official guidance that impacts Colorado’s CHCs and their operations and funding. CCHN staff are updating this document regularly.

Summary of 2020 COVID-19 Stimulus Bills

Available here.

This is a one page summary of the four stimulus bills passed or in development in response to the COVID-19 crisis.

CARES Act Summary and Resources  (Stimulus #3)

Available here.

This document provides available information on the $2 trillion Coronavirus Aid, Relief and Economic Security Act – the CARES Act. This document is under development and will be updated as information is released.

Click on any of the below for additional resources and information

340B Pharmacy Program

(Last Updated: March 23, 1:04 PM)

FAQs from Office of Pharmacy Affairs: The Office of Pharmacy Affairs (OPA) has posted FAQs on the 340B pharmacy program as it relates to COVID-19.  Importantly, they indicate no flexibility in the definition of patients. However, there is guidance related to the 340B pharmacy program and telemedicine, included below:

  • Given the coronavirus 2019 pandemic, what flexibilities are available to entities to allow a provider to offer telehealth services? HRSA understands that the use of technology in health care delivery during this time is critical, and that telemedicine is merely a mode by which the health care service is delivered. For the 340B Program, HRSA recommends that covered entities outline the use of these modalities in their policies and procedures and continue to ensure auditable records are maintained for each eligible patient dispensed a 340B drug.

340B Flexibilities During Disasters: This page provides guidance for 340B providers participating in relief efforts during a declared public health emergency. Provisions of the guidance include:

  • In a declared emergency, an abbreviated health record may be adequate for purposes of the 340B Program.
  • In the event of a declared emergency, where volunteer health professionals are providing health care, emergency documentation should be generated to make the relationship between the provider and the covered entity clear and to make clear the covered entity’s responsibility for providing care.

Advocacy and Action Alerts

(Last Updated: May 29, 8:40 AM)

For Federal advocacy updates and action alerts, visit the NACHC advocacy webpage at hcadvocacy.org.


Agricultural Worker Resources

(Last Updated: June 2, 2020 1:40 PM)

Ag Worker Access Campaign Task Force Resources: COVID-19 resources compiled by the National Center for Farmworker Health include Voucher Program meeting notes; COVID Resources from NC and PA, including guidelines, protocols, and a Letter to Grower; HRHCare Transportation sample protocols; Indigenous Language resources; FJ letter sent to DOL, DOS, and DHS outlining recommendations to protect H-2A workers from COVID-19; and UFW articles. Resources will continue to be added as they are made available.


COVID-19 Resources for Agriculture: Resources from the UC Davis Western Center for Agricultural Health and Safety related to COVID-19 as it affects agricultural workers, including frequently asked questions for growers and farmworkers, and audiovisual COVID-19 videos in Mixteco and Spanish.


*NEW* Agricultural Workers and Employers: Interim Guidance from CDC and the U.S. Department of Labor: Released June 1, this guidance includes information regarding screening and monitoring workers, infection control plans, and special considerations for shared housing, shared transportation, and children.


Billing

(Last Updated: March 20, 8:15 AM)

Billing Information: Updates on policies, codes and other important information for providers will be posted on the new COVID-19 Provider Information web page. Communications will continue to be sent out via bulletins and newsletters. Please sign up for updates on the Provider News web page.


Providers Who Bill for Laboratory Tests: New HCPCS codes U0001 and U0002 have been released for dates of service on or after February 4, 2020. Providers who test members for the 2019 Novel Coronavirus (COVID-19) using the Centers for Disease Control and Prevention (CDC) 2019 Novel Coronavirus Real Time RT-PCR Diagnostic Test Panel may bill using code U0001. Providers may use code U0002 to bill for non-CDC laboratory tests for COVID-19. Billing with these specific codes will allow for better tracking of the public health response for COVID-19. Claims for U0001 and U0002 will initially suspend for EOB 0000 – “This claim/service is pending for program review.” Suspended claims will be released when the Colorado interChange is updated.


Board Resources

(Last Updated: April 15, 11:53 AM)

Health Center Boards and Novel Coronavirus (COVID-19) – resource from NACHC

This document discusses how health center boards are exercising their governance duties related to COVID-19. Examples include ensuring there are plans in place, considering resource needs and long-term strategic implications, ensuring they can stay connected and continue to meet monthly, and continuing to serve as community ambassadors  The full document is available in English here and in Spanish here.


NACHC has gathered resources for boards on their COVID-19 webpage. Resources posted include:

  • Legal considerations
  • Sample board presentation
  • Financial oversight considerations
  • Partnership with CEOs

CCHN Peer Groups & Section Call Notes

(Last Updated: April 29, 1:53 PM)

Weekly COVID-19 Digests

Colorado Behavioral Health Advisory Network (CBHAN)

Colorado Clinician Advisory Network (CCAN)

Colorado Dental Health Network (CDHN)

Colorado Operations Directors Advisory Network (CODAN)

Fiscal Directors

Human Resources Advisory Network (HRAN)

Healthcare Technology Network (HTN)

Outreach & Enrollment Managers Work Group


CDPHE
Co-Pays

Requirements for CHCs re Charging, Collecting, and Waiving Fees and Co-Pays: CCHN compiled this document on federal, state, and/or other payer requirements that CHCs should follow related to charging and collecting fee and co-pays. This includes any special considerations specific to COVID-19. This is CCHN’s understanding, but this should not be considered legal advice. In the document you will find:

  • A summary of requirements
  • Federal and state references to waiving fees and co-pays
  • Emergency rules under COVID-19
  • Summary of private payers from CHPA

Drive Thru Clinics

(Last Updated: April 7, 8:31 AM)

NACHC Sample Drive Thru Clinic Resources: The National Association of Community Health Centers (NACHC) has put together a resource packet CHCs can utilize for drive thru clinics. The packet includes a script for patient phone calls, sample procedures, a patient screening took, a patient self-monitoring tool, and a sample budget for setting up a drive through clinic. Find the resource in English here and in Spanish here.


FTCA

Guidance from FTLF on FTCA Coverage for COVID-19 Work: On March 20 FTLF hosted a webinar to address common questions related to FTLF and COVID-19. CCHN’s full notes from the call can be found on CCHN’s members page, here.

Hazard Pay

(Last Updated: April 16, 12:37 PM)

Funding for Hazard Pay: COVID-19 Supplemental Funding (also referred to as H8C) may be used for hazard and premium pay if there are policies and procedures in place that cover this type of compensation. Personnel who will be paid with COVID-19 Supplemental Funding must receive salary and benefits consistent with a CHC’s policies of paying salaries under unexpected or extraordinary circumstances from all funding sources, federal and non-federal.  To be eligible, there must be documentation following organizational policies for changing salaries during unexpected and extraordinary circumstances and following HRSA guidance as adopted and permitted by the OMB memoranda M-20-11 and M-20-17.


Pay Premiums Policy: Example from the Windrose Health Network in Indiana that was shared through NACHC’s coronavirus NoddlePod. 


SHRM Hazardous Duty Pay Policy: By Position and Location May need a SHRM membership to access


SHRM Article – When Disasters Strike: Pay, Leave, and Related Issues


U.S. Department of Labor Definition of Hazard Pay: Hazard pay means additional pay for performing hazardous duty or work involving physical hardship. Work duty that causes extreme physical discomfort and distress which is not adequately alleviated by protective devices is deemed to impose a physical hardship. The Fair Labor Standards Act (FLSA) does not address the subject of hazard pay, except to require that it be included as part of a federal employee’s regular rate of pay in computing the employee’s overtime pay. Office of Resources Management – Hazard Pay Compensation Policy.


Colorado Department of Personnel and Administration – Personnel Board Rules and Personnel Directors Administrative Procedures (Section 3-51 is about Hazardous Duty)

Health Coverage

(Last Updated: April 6, 8:41 AM)

DOI Regulation Creates a Special Enrollment Period for COVID-19

UPDATE: The enrollment period has been extended until April 30

The Colorado Division of Insurance (DOI) released Emergency Regulation 20-E-02 which creates a special enrollment period (SEP) due to COVID-19. The SEP allows uninsured Coloradans to enroll in health insurance through Connect for Health Colorado from March 20 – April 3, 2020. Coverage will be effective starting April 1, regardless of when someone enrolls during the SEP. Only people who are currently uninsured are eligible to enroll. Uninsured spouses and children will be allowed to enroll even if one spouse or a child’s parent is already insured. Connect for Health Colorado developed a step by step job aid for assisters and brokers to use when enrolling customers in coverage.


HRSA and NACHC

(Last Updated: May 26, 12:53 PM)

CCHN Summary of Considerations re Federal Uninsured Reimbursement: CCHN put together this summary to help CHCs understand the complexities and considerations regarding the federal reimbursement for COVID testing and treatment for uninsured patients, through HRSA. CCHN expects more information and guidance to come out shortly from both NACHC and BPHC and this document will be updated as more information is available.


Novel Coronavirus (COVID-19) Information and Resources for Community Health Centers from NACHC, available here. The website includes advocacy alerts, important updates and FAQs, and sign up for a the COVID-19 networking group.


Novel COVID-19 Frequently Asked Questions: HRSA published a list of FAQs for CHCs and PCAs in addressing the coronavirus and a separate list of funding FAQs. These questions are updated regularly


COVID-19 Grantee FAQs: HRSA has posted a list of FAQs for grantees, available here. Questions answered include:

  • Will HRSA extend the deadlines for our grant competition since many organizations have been impacted by COVID-19 and have not been able to focus on grant applications?
  • My project period is expiring soon. What can I do if additional time is needed to complete previously approved activities on my grant award?
  • I may not be able to submit my Non-Competitive Continuation progress report on time. Should I request an extension?
  • Can we use grant funds to pay salaries for staff on the budget who are not in the office due to closures because of COVID-19?

Infection Control

(Last Updated: March 30, 1:03 PM)

ECRI COVID-19 Resource Center: This site includes preparation and patient handling checklists, equipment and alternative supplier lists, patient care equipment evaluations, including portable ventilators, recommendations for infection control, and links to Centers for Disease Control and World Health Organization. Some resources of note:


Updated Infection Control Toolkit from ECRI (Requires a free ECRI login, email clinical_rm_program@ecri.org for access.) The toolkit includes:


How to optimize PPE: Due to the limited supply of PPE and the unknown availability of additional resources through the State EOC, it is imperative to optimize the use of PPE or utilize the following alternative suggestions to PPE. The following four links provide information on the optimization and alternatives to PPE:


Coronavirus COVID-19 resources from the Centers for Disease Control

  • Click here for the most recent updates.
  • Here are Exposure Guidelines for health care workers. This document shares the need for PPE and how to prevent exposure to COVID-19.

Tools for monitoring staff symptoms


MAT and SUD

(Last Updated: March 26, 4:02 PM)

COVID-19 Public Health Emergency Response and 42 CFR Part 2 Guidance From SAMHSA: The increased need for telehealth services during the COVID-19 public health emergency has led to instance in which providers may not be able to obtain written patient consent for disclosure of substance use disorder records. In these cases the prohibitions on use and disclosure of patient identifying information under 42 C.F.R. Part 2 would not apply to the extent that, as determined by the provider(s), a medical emergency exists. The full guidance from SAMHSA is available here.


DEA Regulations: Providing MAT via Telemedicine During COVID-19: For the duration of the designated public health emergency, practitioners with a DATA 2000 waiver may issue prescriptions for buprenorphine and other controlled substances to patients for whom they have not conducted an in-person medical evaluation, with provisions:

  • The prescription is issued for a legitimate medical purpose by a practitioner acting in the usual course of his/her professional practice;
  • The telemedicine communication is conducted using an audio-visual, real-time, two-way interactive communication system*; and
  • The practitioner is acting in accordance with applicable Federal and State laws.

See detailhere.
*Federal guidance currently includes only audiovisual (video) systems. CCHN is actively seeking guidance on whether MAT via audio-only (telephonic) meets these provisions and will provide an update when available. 


ASAM National Practice Guidelines – OUD and Alcohol Withdrawal Management: ASAM released updates in March 2020 to the following guidelines:


HRSA Supplemental Integrated Behavioral Health Services (IBHS) Funding: CHCs with IBHS awards should continue work related to these funding requirements. While BPHC is trying to provide flexibility with how grant funds are used, the IBHS supplemental funding should continue to be used for its intended purpose.


NHSC and CHSC Requirements under COVID-19

(Last Updated: April 2, 1:40 PM)

Colorado Health Services Corps Contract Obligations: The Primary Care Office has shared with CCHN that any disruption to normal practice time directly related to the COVID will “count” under the CHSC provider direct care contract requirements for the time being. If furloughs or layoffs occur, then the PCO will suspend contracts for up to a year. Given the extraordinary disruption all this has caused, they will reassess whether a year suspension is sufficient for folks to get back to work at a later date.


Message on NHSC and Nurse Corps: HRSA understands the COVID-19 outbreak will have a direct impact on our National Health Service Corps and Nurse Corp clinicians and sites. We are committed to providing flexibility to allow our clinicians and sites to focus on facing this unprecedented public health emergency. NHSC or Nurse Corps participants may encounter situations directly related to COVID-19 that might impact their ability to complete their service obligation.  The NHSC and Nurse Corps have mechanisms in place to ensure that, in the event of an emergency or disaster, participants are able to remain in compliance with their service obligation. Participants whose circumstances change – for example, they are  required to be away from their approved service site more than the allotted seven weeks per service year; they become unemployed as a direct result of the outbreak; or they are directed by their employer to provide care outside of the NHSC approved site – should contact a program analyst immediately via the customer service portal for assistance. We will continue to update you on additional provisions relating to your NHSC or Nurse Corps service. Thank you for your commitment to providing care to the nation’s underserved communities.

  • At the discretion of the NHSC or Nurse Corps site/institutions loan repayment recipients can request approval for shifting their clinical service to telehealth to accommodate infection control, social distancing, or other appropriate measure to assist in meeting recommended outbreak reduction/control measures. Additional details on this and other flexibilities are available on the NHSC COVID-19 FAQs page.

OIG

(Last Updated: March 25, 4:14 PM)

OIG Portal for COVID-19 Resources: OIG created a portal for all information and announcements related to COVID-19. The portal can be accessed here.


Operations

(Last Updated May 18, 2020 10:56 AM)


Oral Health
OSHA

(Last Updated: April 3, 10:14 AM)

This webpage from OSHA provides information for workers and employers about COVID-19. The information includes links to interim guidance and other resources for preventing exposures and infection. Resources available on the page include: 

Patient Resources

(Last Updated: June 18, 11:28 AM)

Meals for Children During School Closures: This page from Chalkbeat includes a map of Denver area meal distribution sites.


CDPHE’s Testing Information Page has information on when, how, and where to access COVID-19 tests.


COVID-19: Resources, Links, and Information for People With and Without Disabilities from the Colorado Cross-Disability Coalition


COVID-19 Resource for Non-English-Speaking People: The COVID-19 Health Literacy Project provides translations of essential information about COVID-19 in more than 35 languages. The project was started by a medical student at Harvard and all the information is vetted by Harvard faculty. Forms available on the site include:

  • COVID-19 prevention
  • About COVID-19
  • Managing COVID-19
  • COVID-19 and pregnancy
  • COVID-19 for 3-6 year olds
  • COVID-19 for 6-12 year olds
  • COVID-19 for 13-18 year olds

StayAtHomeCO guide: The Governor announced new stay at home guide for Coloradans.  It includes free resources to support Coloradans while they are at home from wellness, to services, to education, to entertainment and more. The guide can be accessed here.


Resources for Populations Disproportionately Impacted by COVID-19: The US Department of Health and Human Services (HHS) and the Federal Emergency Management Agency (FEMA) have compiled a list of federal resources for Region 8 to support populations disproportionately impacted by COVID-19, available here. The purpose of the document is to help state and local agencies find resources and information that are available at the federal level. The document includes resources from the Administration for Children and Families, Administration for Community Living, Centers for Medicare and Medicaid Services, Health Resources and Services Administration, Substance Abuse and Mental Health Services Administration, Food and Drug Administration, Office for Civil Rights, and FEMA.


Provider Resources

(Last Updated: April 28, 2020 1:56 PM)

CHAMPS Coronavirus Disease 2019 (COVID-19) Resources webpage
In response to the novel Coronavirus, CHAMPS has created a page of resources pertinent to the prevention, slowing of infection rate, and treatment of this illness. This page will be updated as new resources become available. Please contact the CHAMPS Programs Coordinator, Population Health if you have any questions about these materials or would like to share any other useful resources.


COVID-10 Just-In-Time ECHO for Primary Care: ECHO Colorado, a leader in developing primary care practice support and clinical education across the state, has developed an effort with numerous statewide key stakeholders to support primary care practices and safety net practices in managing the outbreak of COVID-19. ECHO Colorado has developed a program that is offered three times per week with all Colorado health providers eligible to participate. The virtual sessions offer these practices a connection with a multidisciplinary team and are structured to share a range of topics as a COVID-19 toolkit, followed by questions and case review. Register here.


COVID-19: Geriatrics and Long-Term Care: Dr. Joseph G. Ouslander is a co-creator of INTERACT and recently published a COVID-19 special article and editorial in the Journal of the American Geriatrics Society.


Follow-up Outpatient Visits for Persons with Confirmed COVID-19


Personal Contact Information for Lab Tests
Request from the governor and DORA to provide accurate and complete labeling of test samples, to include:

  1. Patient’s name, date of birth, sex, race, ethnicity, and address (including city and county)
  2. Name and address of responsible physician or other health care provider
  3. Name of disease or condition
  4. Laboratory information – test name, collection date, and specimen type
  5. Such other information as is needed to locate the patient for follow up, such as the patient’s telephone number

A checklist for reopening your practice for “non-essential” face-to-face visits: From the American Academy of Family Physicians, this outlines important points to consider when deciding whether and how to re-open for non-essential in-person visits.


Remote Work

(Last Updated: March 24, 5:10 PM)

Remote Work Best Practices from the Colorado Department of Labor and Employment: As COVID-19 takes its toll on our communities, many employers are moving to telework/remote work. This preventive step is important from a public health perspective, but it leaves many workers, managers, and businesses who have never worked remotely or managed remote teams with some concerns. This page includes resources and answers to some common questions that arise when faced with the experience for the first time. View the full page here. Some of the questions answered include:

  • This is my first time working remotely: what should I know?
  • Sometimes I struggle to be productive and focused when working from home? Help!
  • I’m a manager of a remote worker and I want to make sure I’m holding people accountable. What are reasonable management practices?
  • What are unreasonable management practices?
  • What are some remote team activities I can do to keep our connection and culture alive?
  • How can I have a productive virtual meeting?
  • I struggle with some of the technology we rely on for remote work…what are some quick resources to refresh my skills?
  • We haven’t gone remote…yet. What should I be considering to prepare?

Examples from CHCs

  • Summit Community Care Clinic’s Telecommuting Policy and Procedure:

School-Based Health Centers

(Last Updated: April 15, 10:33 AM)

COVID-19 Resources: The Colorado Association for School-Based Health Care has gathered together resources, including best practices and workflows. These are available to the public through their website.

Scope of Project

(Last Updated: July, 9, 12:56 PM)

Scope of Project Considerations for COVID-19 the Public Health Emergency: To support CHCs with scope of project questions HRSA has compiled several resources onto one page. The page also includes an outline of several questions for CHCs to consider when determining if something is within the scope of project.


Requesting a Change in Scope to Add Temporary Service Sites in Response to Emergency Events (PAL 2020-05): This PAL outlines the process and criteria for CHCs to request a temporary site. On April 15, 2020, HRSA released an updated version of the PAL to clarify what can and can’t be done. Changes to the PAL include: 

  • Rearranges information so it is all within the PAL and there is no additional attachment.
  • Clarifies that CHCs can be impacted by an emergency absent physical displacement of CHC or the community it serves (Page 1). The PAL considers a CHC impacted if any part of the CHC’s service area is within the geographic area of the declared emergency (Page 3).
  • Adds clarification that if the time for the temporary site needs to exceed 90 days the CHC can ask for an extension from their Project Officer (Page 1 and 8).
  • Removes reference to providing staff or resources to assist sites operated by other CHCs under section about non-impacted CHCs.
  • Adds section to further clarify that non-impacted CHCs cannot add temporary sites outside the service area (Page 5).
  • Provides information on limits of FTCA for volunteers (Page 6).
  • Adds table on when to use each criteria (Page 7).

Telehealth Resources

(Last Updated: March 27, 1:43 PM)

CCHN has a dedicated page for Telehealth Resources available here: https://cchn.org/covid-19-telehealthresources.


Testing

(Last Updated: June 16, 2020, 10:32 AM)

CCHN Summary of Funding Sources to pay for COVID Testing and Treatment (June 10, 2020) This document summarizes the state and federal funding sources available to CHCs to pay for COVID-related testing and treatment.


The Governor announced on 3/18/20 that the following will be prioritized for testing at the State Laboratory:

  • Identify and monitor for community transmission of COVID-19.
  • Investigate potential outbreaks in health care and residential facilities.
  • Ensure a safe workforce in health care and other facilities serving high-risk populations.
  • Test critically ill patients for whom commercial testing will not provide timely enough results.

Read more here.


CCHN’s Resources for Becoming a Community COVID-19 Testing Site: Includes a summary of CDPHE’s Community Testing Playbook, CHC site-specific considerations, and suggested next steps.


Personal Contact Information for Lab Tests
Request from the governor and DORA to provide accurate and complete labeling of test samples, to include:

  1. Patient’s name, date of birth, sex, race, ethnicity, and address (including city and county)
  2. Name and address of responsible physician or other health care provider
  3. Name of disease or condition
  4. Laboratory information – test name, collection date, and specimen type
  5. Such other information as is needed to locate the patient for follow up, such as the patient’s telephone number

Volunteers

(Last Updated: April 15, 4:07 PM)

Help Colorado Now Website: This website launched just a few days ago will be updated soon to add an intake form for health care workers (providers and others) to indicate their availability to volunteer. This new intake form is being set up at the request of Colorado hospitals in coordination with the Governor’s Office.  When ready, health care organizations, including CHCs should be able to request volunteers, and similarly, available providers can sign up to volunteer in the COVID-19 response effort.  Pleas not it appears it will be the responsibility of the health care organization accepting the volunteers to assure proper credentialing and malpractice coverage.  CCHN will share more information when we have it.


FTCA for Volunteers: For liability protections to apply, the volunteer must be a health care professional who is licensed or certified to provide clinical services. This would include Licensed Practical Nurses (LPNs) and Medical Assistants (MAs) who are licensed or certified. Volunteers who are not licensed or certified are not eligible for volunteer health professional (VHP) coverage. VHPs are not automatically eligible for liability protections under the Health Center FTCA Program. Deemed health centers must apply for such protections for their individual volunteers through a VHP deeming sponsorship application. See Program Assistance Letter (PAL) 2020-03: Calendar Year 2021 Volunteer Health Professional Federal Tort Claims Act (FTCA) Deeming Sponsorship Application Instructions. The deemed health center must submit to HRSA and receive approval of a VHP deeming sponsorship application for each individual volunteer.

 

Workforce/HR

(Last Updated: June 11, 10:26 AM)

Return to Work Resources From EEOC: The U.S. Equal Employment Opportunity Commission (EEOC) today posted an updated and expanded technical assistance publication addressing questions arising under the Federal Equal Employment Opportunity Laws related to the COVID-19 pandemic. The publication, “What You Should Know About COVID-19 and the ADA, the Rehabilitation Act, and Other EEO Laws,” provides approaches employers may adopt as they plan for employees returning to the workplace, including providing information to all employees about who to contact with requests for disability accommodation or other flexibilities, and inviting employees to make any requests in advance that the employer will consider on an individualized basis. Highlights include Q&As on the following topics:

  • Disability-Related Inquiries and Medical Exams
  • Confidentiality of Medical Information
  • Hiring and Onboarding
  • Reasonable Accommodation
  • Pandemic-Related Harassment Due to National Origin, Race, or Other Protected Characteristics
  • Furloughs and Layoffs
  • Return to Work
  • Age
  • Caregivers/Family Responsibilities
  • Pregnancy

Paid Sick Time Requirements – State and Federal

State Requirements: From the CO Department of Labor and Employment: Under normal circumstances, Colorado wage law does not require employers to provide time off due to illness or injury. However, the Colorado Health Emergency Leave with Pay (HELP) rules has been put into place due to COVID-19. The HELP rules do not apply to CHCs unless staff fall under one of the covered fields:

  • Applies to any employer in the field of leisure and hospitality, food services, child care education at all levels, home health care (working with high-risk individuals), operating a nursing home, or operating a community living facility.
  • Must provide up to four days of paid sick leave for an employee with A) flu-like symptoms and B) who is being tested for COVID-19. Sick leave ends if an employee receives a negative COVID-19 test result.
  • These rules do not require an employer to offer additional days of paid sick leave if it already offers all employees an amount of paid leave sufficient to cover four days. However if an employee has exhausted paid leave allotted but then has flu-like symptoms or is being tested for COVID-19 then he or she is entitled to additional paid sick days.

Federal Requirements 

Families First (FFCRA) Information:

NACHC COVID-19 Human Resource Issue Resource Packet: NACHC has released a complete COVID-19 FQHC Employment Issues/Human Resource Guidance and Resource packet to support CHC workforce leadership in navigating their COVID-19 response. This packet contains FAQs regarding paid and family leave, legal guidance on emerging and immediate human resource/employment, and additional resources relevant to federally qualified health centers (FQHCs). Within the document you can find:

  • Links to Additional Resources – On Page 1
  • Frequently Asked Questions – Begins on Page 2
  • High level legal overview – Begins Page 15

Emergency Paid Sick Leave and Emergency Family Leave Established in FFCRA: This document shared by NACHC reflects information available as of March 25, 2020, and provides details on the following topics:

  • Employers to whom FFCRA Applies – Page 4
  • Types of Emergency Leave – Page 5
  • Payment for FFRCA Leave –  Page 5
  • Emergency Paid Sick Leave – Page 6

 

The document linked here, also from NACHC, provides a nice breakdown of which employees are eligible for the types of leave provided by the legislation. The power point, linked here, provides a flow chart for determining how leave is applied based on an individual employees circumstances.

 

The US Department of Labor has shared answers to commonly asked questions about the FFCRA, available here. It includes the definition of health care providers that may be excluded.


Guidance on Implementing Coronavirus Paid Leave: This Department of Labor update includes information on two new refundable tax credits designed to immediately and fully reimburse them for the cost of providing Coronavirus-related family and medical leave and sick leave to their employees.

Updated Information on Grants, Loans, and Other Cashflow Options: NACHC has released updated resources to addressed grants, loans and other cashflow during the COVID-19 pandemic. These are evolving documents and will continue to be updated with new information as it becomes available. Please contact cmeiman@nachc.org with questions. 


Emergency Childcare for Essential Emergency Service Workers: Beginning Monday, March 23, childcare options will be available to all essential health care workers at no cost for at least two weeks. Those needing to utilize this service will need to sign up here as soon as possible so that local providers can be activated and ready to go starting next week. Every effort will be made to match those who need care with a licensed facility near you that has available capacity to help.

 

Update as of March 30: Child care for essential health care employees has been extended and expanded until Sunday, May 17. There is an expanded list of critical workers in the latest CDPHE guidance who can participate, allowing as many available as 5,000 more families to enroll. The parent and provider matching transitioned to an app that matches parents with providers – details here.


Work-Share Program Information: This program, as part of the Colorado Employment Security Act, permits employers to allow for staff to work reduced hours and be paid part of their regular unemployment benefits. Employees participating in the program are paid a portion of their unemployment benefits based on the percentage of reduced hours. This program provides employers an alternative to laying off employees. All employees are can be in the work share program, or employees from a particular unit can be in the program.

For employers to be eligible to take advantage of this program, they must have a positive percent of excess. This means an employer must have paid as much in premiums as the state has paid former employees in benefits. Percent excess was mailed to employers last November. Employers will be charged for any unemployment benefits paid; however, this charge will be less than if an employer completely laid off an employee.

Additional Eligibility Requirements:

  • You are applying to be in the Program instead of laying off your employees.
  • You are reducing the hours of at least 2 employees in a certain unit. You would have laid off at least that many employees.
  • You are reducing the work hours of that group by at least 10% but no more than 40%.
  • You will not hire or have other employees work in that group.
  • Your employees’ collective-bargaining agent (union), if any, must agree to the plan.
  • You cannot get rid of or reduce employees’ benefits that you currently provide. These include health insurance, retirement/pension benefits, vacation pay and holidays, sick leave, and any other similar benefits you normally provide.

How to Apply:

Fill out the Request for Approval of Work Share Plan, linked here. Submit your completed form via email or send it to the address located at the bottom of the form. The application will be reviewed, and a letter will be mailed to let you know whether your plan is approved. Each work-share plan is effective on the date of approval and runs for 12-months or 52-weeks from that date.

 

It is CCHN’s understanding at this time that if CHCs want to take advantage of this program that they do need to apply. According to the website, once you apply your application will be processed within a week.

 

Per this program, employees work can be reduced by at least 10 percent but no more than 40 percent and receive unemployment to cover the amount their work is reduced (additional details below). The handout, linked here, provides additional information on requirements, advantages and disadvantages of the program. The handout, linked here, provides information to employees regarding the program. 

 

The state can pay your employees part of the unemployment benefits they could get for that week. They look at the percentage of how much you reduced their hours and pay them the percentage of the unemployment benefits the state can pay them. You can use the calculator, linked here, to estimate weekly amounts staff would receive under this program.


COVID-19 HR and People Operations Prep Document from LifeLabs Learning: LifeLabs Learning has gathered 650+ HR Leaders from different companies to share ideas, policies, and templates. We co-created this shared doc (which continues to be a work in progress). Access the page here.


Responding to COVID-19 in the Workplace – HUB International: HUB International has developed the following FAQs to help HR leaders and business owners respond to the many employee relations issues resulting from the coronavirus crisis. These FAQs address many of the complex challenges facing our clients. Some content has been taken from federal publications, such as EEOC and DOL FAQs. For information on business insurance and risk management issues, visit the HUB coronavirus resource center here.


Stay At Home Order Resources for Employers: On Wednesday, March 25, Governor Polis issued Executive Order D2020-017 ordering Coloradans to stay in place due to the presence of coronavirus disease 2019 (COVID-19) in the state. Colorado Department of Public Health and Environment’s (CDPHE) issued a public health order defining critical emergency personnel, infrastructure, government functions, and other activities that are exempt from the directives in this Executive Order. Click here for more information on what this means for your staff. Additional resources are provided below.

  • A letter stating that your employees are essential staff and can travel freely is linked here. Resource provided by Mountain Family.
  • Here is another letter template stating that employee is authorized to travel during the stay at home order.
  • Here is another letter template regarding essential business.
  • While the state is not requiring it, our Department of Public Safety has added a Critical Business Self-Certification form to their website in response to requests from employees and private sector members for a document to carry that certifies that they are traveling for work for a critical business. The form is voluntary. It is not required. Link to the document can be found here.

Information on Loans Available for Nonprofits in the CARES Act 

CCHN is continuing to examine this legislation and will share updated information as it is available. You can find a CCHN produced CARES Act Summary and Resources here.

The Coronavirus Aid, Relief, and Economic Security Act CARES Act (Pub. L. 116-136) defined a number of programs that charitable nonprofits will be eligible to apply for. The chart that follows provides information on those loan options, eligibility criteria, terms, and application information. This chart is neither financial nor legal advice for any specific organization. It is an analysis of the new law before any rules or regulations. Click here to access the resource.


Reduced Workflows and Staffing Guidance for Non-Clinical Operations: This packet from NACHC contains procedures and workflows informed by health centers who are currently implementing reduced and/or telework staffing models specific to non-clinical services and functions


New resources from the HHS Assistant Secretary for Preparedness and Respons: ASPR has released several resources to provide tips and general guidance to mitigate the impacts of healthcare provider grief related to a patient’s or colleague’s death and to maintain workforce efficiency and individual well-being.


Guidance for Rehiring Staff and Unemployment: As Coloradans in non-essential roles return to their workplace, many are concerned about their safety in the workplace. This resource addresses how employers can respond to staff who have safety concerns, what categories of staff are able to decline a return to their positions, and choices for CHCs who are participating in the Paycheck Protection Program who have had a reduction in full-time staff.  


Workforce Virtual Toolkit: HHS.gov has curated a list of resources to assist in the workforce response to COVID-19 called COVID-19 Workforce Virtual Toolkit: Resources for Healthcare Decision-Makers Responding to COVID-19 Workforce Concerns. This free virtual toolkit includes guidance, sample policies, and training resources for CHC leadership, providers, and frontline staff. Highlights include:

  • COVID-19 Workforce Training Resources – Including training for behavioral health, nurses, pharmacy, and more.
  • Workforce Surge Planning Guidance – This resource highlights strategies that local healthcare workforce decision-makers could adopt to optimize healthcare workforce assets, assess ongoing staffing needs, and identify resources to meet patient surge during the COVID-19 pandemic.
  • Workforce Protection Resources – These resources related to workforce protection during the COVID-19 pandemic response. It includes checklists and trainings in relation to both preparedness and response. These may be useful for professionals tasked with ensuring the health and safety of the healthcare workforce.
  • COVID-19 Workforce Resilience/Sustainability Resources – This Topic Collection focuses on plans, tools, templates, and other immediately implementable resources to help with COVID-19 preparedness, response, recovery, and mitigation efforts, focusing on workforce resilience and sustainability.

Additional Resources