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OIR CCRC Coronavirus Alert #2 - March 20, 2020

Joel L. Anderson, Chair | Steve Bahmer, President/CEO

1812 Riggins Rd | Tallahassee, FL 32308 | P: (850) 671-3700 | F: (850) 671-3790

Continuing Care/Life Plan Coronavirus Alert #2
3/20/2020

Important Clarification from OIR on Compliance with Informational Memorandum OIR-20-03M issued on March 16, 2020 

Chris Struk, OIR Life & Health Policy Advisor, has provided clarification on the OIR’s expectations regarding CCRC compliance with the Informational Memorandum. Please note it is very different from the guidance provided in the Alert you received from us yesterday.  

Chris, who is very familiar with CCRCs because of past positions held with the OIR, understands your business and service model and is serving as the reviewer of responses to the recent COVID-19 Informational Memorandum for all life and health related insurance companies including continuing care/life plan communities.  

He emphasized that the OIR is not evaluating the appropriateness of the actions taken by a CCRC. Therefore, the OIR does not need a lot of details.  However, it is important that the OIR be notified of actual or potential issues that affect resident care and services.
 
OIR agrees that CCRCs are not like insurance companies. Nonetheless, the OIR is interested in the same information as it is requiring of other insurers.  They want to know when a CCRC activates its Business Continuity Plan or Continuity of Operations Plan, have assurance that the company can take care of its customers/residents, and know who to contact in the event of questions.  Some of you have asked for a definition of a Business Continuity Plan or Continuity of Operations Plan. It is your emergency management plan, which OIR requires to be submitted with a Provisional Certificate of Authority application. You do not need another plan. 
 
According to Chris, the OIR very much understands that procedures at CCRCs are in a state of flux as additional information is learned about the Coronavirus. The OIR is asking CCRCs to follow the recommendations from the CDC, the Agency for Health Care Administration, and the Department of Health. There is no need to notify the OIR of any actions in response to those recommendations.  However, the OIR needs to know “if a CCRC has to relocate residents, is closing sections of campus, can’t take care of residents for whatever reason, can’t provide food to its residents, or has positive or suspected cases of COVID-19”, and whatever mitigation strategy the CCRC is using to address the problem.  
 
Chris indicated that the OIR is very concerned about CCRCs – probably more than any line of business it regulates. He said, “We are all in this together to keep Florida residents safe. Therefore, we ask your assistance in making this as easy as possible for CCRCs so we that we get good compliance.” OIR wants to be aware of the challenges you are facing rather than reading about them in the newspaper or hearing about them from residents. They will advocate on our behalf if widespread problems exist. 
 
Action required: So what does OIR expect? If a CCRC activates its Business Continuity Plan or Continuity of Operations Plan (your emergency management plan), it should submit 2-3 sentences notifying CCRC of that occurrence plus the name, phone, number, and email address of the point of contact at the CCRC. Chris emphasized that the submission should be short; almost like a text. Chris or one of his colleagues will contact you if there are questions.  

Example for an extreme situation: 
“We have activated our plan effective (date) to address staffing challenges resulting from the Coronavirus. We are having difficulty providing care to residents due to most staff being in isolation. At this time, we are considering transferring staff from other locations to assist with this issue. We will let you know when this has been completed. Our point of contact is…..” 

The notification should be emailed to COVID-19@floir.com. If a situation occurs such as a positive or suspected case of COVID-19 on campus, please notify Chris Struk (Christopher.Struk@floir.com) or 850/413-2480. You do not need to notify the OIR when a staff person is required to self-isolate. If you have not activated your plan, nothing is needed at this point. If you have an update that you do not want to put in writing, you may leave a phone message for Chris, and he will return your call. 
 
Please retain this alert in a file on compliance with OIR requirements during the 2020 Coronavirus Public Health Emergency to use during your next OIR Examination/Triennial Audit in the event that there are related questions. 

For questions or more information, please contact Mary Ellen Early, Public Policy Liaison, via email or by phone at (386) 734-7681

1812 Riggins Rd, Tallahassee FL 32308
Phone: (850) 671-3700
Websitehttps://www.LeadingAgeFlorida.org

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