On December 21, 2021, the Ministry of Children, Community and Social Services (MCCSS) issued new “Interim Direction” with “mandatory” requirements for Congregate Living Settings (CLS), including biweekly rapid testing for all staff (regardless of vaccination status) commencing December 24, 2021. We summarize the requirements below:
Requirements for Staff
- Mandatory rapid antigen screening of all staff who enter a CLS (regardless of vaccination status), at a frequency of 2 times per week (7-day period). It is permitted for this to be inclusive of and not in addition to any existing minimum once weekly rapid testing currently in place for unvaccinated staff under the Letter of Instruction issued by the Chief Medical Officer of Health (CMOH) for a CLS.
- CLSs that are currently using at-home antigen screening for staff may continue to do so.
- A staff member with a positive result on a rapid antigen test must not be permitted entry to the CLS and must obtain a PCR test as soon as possible, and before returning to work.
Requirements for Visitors
- “Mandatory” rapid antigen screening as part of active screening for all visitors entering a CLS (regardless of the visitor’s vaccination status). Exception only if the visitor presented a negative rapid antigen test result at the same CLS the day;
- A visitor with a positive result on a rapid antigen test must not be permitted entry and should be encouraged to seek a PCR test as soon as possible.
Requirements for Residents Returning from an Overnight Absence from a CLS
- Must make rapid antigen screening available for residents who return to a CLS (regardless of vaccination status) from an overnight. The For clarity, it is not a mandatory requirement that returning residents undertake the test. However, service providers are strongly encouraged to promote the use of rapid antigen screening by returning residents as a measure to protect others in the CLS.
- The guidance provides the following additional information:
- For overnight absences of 2 nights or less: Rapid antigen screening should occur on day three and day seven from the day the resident left the CLS.
- For overnight absences of 3 nights or more: Rapid antigen screening should occur on the day of return (as part of active screening upon entry) and day four following their return.
- If the resident leaves for a subsequent overnight absence within those 7 days, a new 7-day period should be started when they return to the
- A resident who receives a positive result on a rapid antigen test should be given a medical (surgical/procedure) mask to wear, unless they are subject to a masking exemption (see masking section) and directed to a designated space away from other residents where they can self-isolate and wait for arrangements to be made for a confirmatory PCR test. Existing guidance for the care of people supported who are COVID-19 positive remain in place.
Use and Availability of N95 Respirators
The new guidance also requires that CLSs revisit the use of N95 Respirators with the following interim recommendations as follows:
Use of PPE
In accordance with Public Health Ontario guidance:
- Personal Protective Equipment (PPE) when providing direct care for individuals with suspect or confirmed COVID-19 includes a fit-tested, seal-checked N95 respirator (or equivalent or greater protection), eye protection, gown, and gloves.
- Other appropriate PPE (based on risk assessment) includes a well-fitted surgical/procedure (medical) mask (a non-fit tested N95 (or equivalent) respirator is considered an alternative to a medical mask), eye protection, gown and gloves for direct care of individuals with suspect or confirmed COVID-19.
- N95 respirators should be fit-tested prior to use to optimize any expected benefit.
A fit tested N95 respirator (or equivalent or greater protection) should be used when an individual’s medical needs require an aerosol-generating medical procedure and they are known or suspected to have COVID-19.
The PHO’s Technical Brief ‘Interim IPAC Recommendations for Use of Personal Protective Equipment for Care of Individuals with Suspect or Confirmed COVID-19‘ (December 15, 2021) provides further information on the required PPE for supporting people in this situation.
In addition, MCCSS guidance also indicates that CLSs may unilaterally identify additional scenarios in which N95 respirators will be used as part of an individual’s care plan, which plan should be clearly documented.
MCCSS also indicates that N95 respirators will be available to staff in CLSs based on “an organization’s risk assessment of the needs of individuals receiving service and the nature of the supports being provided by staff and documented in an individual’s care plan.”
No indication of whether the government will make sufficient quantities of N95 respirators to meet these needs is provided in the guidance.
Policies and Procedures
- Service providers are directed to “ensure appropriate and necessary policies and procedures are in place to support the access to and usage of N95 respirators as part of a respiratory protection program.” MCCSS provides the example of ensuring that a process for accessing N95s outside regular business hours and engaging with your JHSC for that purpose..
- A service provider’s respiratory protection program should incorporate the necessary training for staff to ensure that the PPE will be used safely and appropriately by staff and in accordance with any industry-based standards that may exist.
Fit Testing for N95 Respirators
MCCSS directs that before N95s can be accessed and used, service providers must have identified staff fit tested to ensure a proper seal and trained on appropriate usage of the respirator. Indeed, confirming fit testing is currently a condition for accessing supplies of N95 respirators. At the same time, MCCSS indicates that for positive cases, N95s can be accessed through the OACAS web portal https://request.cwconnects.org/tpr/ and flagged as an emergency order for shipments within 24-48 hours. NOTE: while fit-testing is recommended, it is not required in order to place an emergency order.
MCCSS concludes by confirming that Public Health Units may provide that may be different and/or in addition to those set out in this Interim Direction to prevent and mitigate the spread of COVID-19 and/or other infectious diseases to ensure a tailored response to each local outbreak scenario.