Quality Lives for People with Developmental Disabilities

RCS Safety Plan for Reopening Day Programs

Effective: 8/3/2020

Richmond Community Services is committed to resuming full access to services for individuals, as well as to maintaining health and safety standards, social distancing directives, and precautions to help protect against the spread of COVID-19.  To maintain safety, these guidelines are subject to change.
Richmond Community Services Day Program Administrators are responsible for the implementation and monitoring of these guidelines and are required to adhere to all applicable local, state, and federal requirements.  Agency Certified Day Programs may only re-open if they meet minimum State and Federal safety requirements as outlined by the Centers for Disease Control and Prevention (CDC), Environmental Protection Agency (EPA), United States Department of Labor’s Occupational Safety and Health Administration (OSHA), New York State Department of Health (DOH) and OPWDD while also meeting the minimum standards of the Americans with Disabilities Act (ADA).

Note: Outdoor spaces that belong to Richmond Community Services are not considered public places. Individuals receiving services are not required to wear a face covering when utilizing  outdoor spaces that belong to Richmond or are exclusively used by Day Programs, as long as social distancing from other Day Program participants, staff and essential visitors can be maintained.

Signs will be posted at Day Program entrance and throughout the site, addressing critical COVID-19 transmission prevention and containment. Signage must include guidance regarding:

  • Social distancing requirements
  • Use of mask or cloth face-covering requirements
  • Use and disposal of PPE  
  • Symptom monitoring and COVID-19 exposure reporting requirements
  • Proper hand washing and appropriate use of hand sanitizer
  • Non-essential visitors are not allowed

Entrance into Day Program sites will be restricted to essential staff responsible for the direct provision of service not amenable to delivery via telehealth alternatives or those persons required to ensure continued health and safety operations.   

Day Program Schedules and Activities

Initially, Richmond’s Day Program capacities will be prioritized for individuals who are best served onsite due to their specific clinical needs. Richmond may allow high risk individuals, who prefer to remain at home, to participate in less intensive in-home supports of a shorter duration.  Telehealth may be utilized to supplement service delivery.

In order to implement measures that foster social distancing and disinfection of day program spaces, Richmond may implement the following:

  1. Adjust Day Program hours to allow blocks of service provision (e.g. 9 AM to 1 PM and 2 PM to 6 PM).
  2. Limit staff on site to those essential to direct service provision, prioritizing tasks and activities that most easily adhere to social distancing.
  3. Richmond Day Programs will keep stable groups of individuals together and separated from other groups and focus on activities with little or no physical contact (e.g. walking or hiking) that do not rely on shared equipment.

Health Checks-Entrance

  1. Day Program Administrators will designate a supervisory level staff or health care professional to conduct or oversee daily screenings. Screeners will be provided with, and use PPE, including at a minimum, a face mask and gloves and may include a gown, and/or a face shield. The screener must document health screenings of all individuals and staff. Staff screenings will document if the screening was passed or the staff was sent home, no health information will be recorded. All staff screenings will be secured in a locked area.
  2. All staff and individuals, as well as any essential visitors, must be screened prior to entry into the Day Program site and monitored for signs and symptoms of COVID-19 thereafter.
  3. All staff and individuals must perform hand hygiene immediately upon entering the program and throughout the day.
  4. Screeners must require individuals and staff to self-report, to the extent they are able, any changes in health status throughout the day.  Staff and/or individuals should inform Program Administrators if they are experiencing COVID-19-related symptoms. All such events shall be addressed in accordance to this guideline and will be immediately reported to the agency’s COVID-19 Response Team.  
    1. The health screening assessment should ask about (1) COVID-19 symptoms in the past 14 days, (2) positive COVID-19 test in the past 14 days, (3) close contact with a confirmed or suspected COVID-19 case in the past 14 days and/or (4) travel from within one of the designated states with significant community spread. Assessment responses must be reviewed by Program Administrators every day, and such review must be documented.
  5. Any individual or staff exhibiting signs or symptoms of COVID-19 upon arrival will not be allowed to enter the program building. They will be required to return home until they are fever free for 72 hours without the use of fever-reducing medications (e.g. Advil, Tylenol).

Symptoms While at Day Program

  1.  If symptoms begin while at Day Program, the individual or staff must be sent home as soon as possible. The program must keep sick individuals and staff separate from well individuals and staff.
  2. Any individual or staff sent home should be instructed to contact their healthcare provider for assessment, testing and or/medical clearance.  Day Program Administrators should provide staff with written information on healthcare and testing resources, refer to DOH Testing guidance.
  3. Staff sent home shall comply with appropriate return to work guidance and shall consult with their supervisor prior to returning to work.
  4. Day Program Administrators must immediately notify the COVID-19 Team to ensure that OPWDD and the local health department are notified about the suspected case.
  5. Individuals sent home from program must comply with the agency’s return to program guidance; including obtaining medical clearance prior to returning to the program.
  6. Individuals may not return to/or attend the Day Program while a member of their household or certified residence is being quarantined or isolated. If an individual or staff member is identified with COVID-19, the Day Program Administrator must seek guidance from the COVID-19 Team who will then ensure appropriate reporting to OPWDD and local health officials.

Safety Precautions

  1. Richmond Day Program Administrators are responsible for ensuring a designated site safety monitor, whose responsibilities include continuous compliance with all aspects of the site’s safety plan. The daily arrival and departure document will include the identified safety monitor.   
  2. Day Programs must maintain a log of every person, including staff and essential visitors, who may have close contact with other individuals at the facility; excluding deliveries that are performed with appropriate PPE or through contactless means.
  3. The log should contain contact information, such that all contacts may be identified, traced, and notified in the event someone is diagnosed with COVID-19.

Actions Related to COVID-19 Symptoms and Contact:

  1. If a staff has COVID-19 symptoms AND EITHER tests positive for COVID-19 OR did not receive a test, the staff may only return to work after completing a 14-day self-quarantine. If a staff is critical to the operation or safety of a facility, the COVID-19 Team may consult their local health department and the most up-to-date CDC and DOH standards on the minimum number of days to quarantine before a staff is safely able to return to work with additional precautions to mitigate the risk of COVID-19 transmission.
  2. If a staff does NOT have COVID-19 symptoms BUT tests positive for COVID-19, the staff may only return to work after completing a 14-day self-quarantine. If a staff is critical to the operation or safety of a facility, the COVID-19 Team may consult their local health department and the most up-to-date CDC and DOH standards on the minimum number of days to quarantine before a staff is safely able to return to work with additional precautions to mitigate the risk of COVID-19 transmission.
  3. If a staff has had close contact with a person with COVID-19 for a prolonged period of time AND is symptomatic, the staff should notify the Day Program Administrator and follow the above protocol for a positive case. The Day Program Administrator will report such events to the COVID-19 Team Immediately.
  4. If a staff has had close contact with a person with COVID-19 for a prolonged period of time AND is NOT symptomatic, the staff should notify the Day Program Administrator and adhere to the following practices prior to, and during their work shift, which should be documented by the day program:
    1. Regular monitoring: As long as the staff does not have a temperature or symptoms, they should self-monitor consistent with the Day Program’s health policies.
    2. Wear a mask: The staff should always wear a face mask while in the Day Program.
    3. Social distance: staff should continue social distancing practices, including maintaining, at least, six feet distance from others.
  5. In the event an individual, staff or anyone they reside with are placed on quarantine or isolation, the responsible party (i.e. self, guardian, residence manager etc.) must notify the day program immediately and must suspend attending Day Program until they are medically cleared to return to work/program.

Social Distancing Requirements

All Day Program staff must ensure that for any programming occurring indoors, capacity is limited to the number of participants and required staff, which ensures the following mitigation strategies are adhered to:

  1. At least six feet of physical distance is maintained among individuals and staff, unless safety of the core activity requires a shorter distance, or an individual’s program plan requires that closer contact be maintained with a staff member.
  2. All staff must always wear an appropriate face mask or covering at work, consistent with all current Executive Orders and OPWDD guidelines, unless medically contraindicated.
  3. Acceptable face coverings for COVID-19 include but are not limited to cloth-based face coverings and disposable masks that cover both the mouth and nose.
  4. Cloth, disposable, or other homemade face coverings are not acceptable face coverings for workplace activities that typically require a higher degree of protection for personal protective equipment due to the nature of the work. For those activities, N95 respirators or other personal protective equipment (PPE) used under existing industry standards should continue to be used, as is defined in accordance with OSHA guidelines.

Program Sites and Services

  1. Individuals receiving services must wear face coverings, if they can medically tolerate one whenever social distancing cannot be achieved.
  2. Day Programs must ensure that groupings of staff/individuals receiving services are as static as possible, by having the same group of individuals work with the same staff whenever and wherever possible. Group size must be limited to no more than fifteen individuals receiving services. The restriction on group size does not include employees/staff.
  3. Day Programs must ensure that different stable groups of up to 15 individuals have no or minimal contact with one another nor utilize common spaces at the same time, to the greatest extent possible.
  4. Day Programs will maintain a staffing plan that does not require employees to “float” between different rooms or groups of individuals, unless such rotation is critical to the safety of staff and individuals, due to unforeseen circumstances (e.g. staff absence).
  5. Day Programs should modify the use and/or restrict the number of program rooms and seating areas to allow for social distancing, of at least six feet apart in all directions (i.e. 36 square feet).
  6. When distancing is not feasible between workspaces, the Day Program must provide and require the use of face coverings or enact physical barriers, such as plastic shielding walls where they would not affect air flow, heating, cooling, or ventilation.
  7. Shared workspaces or equipment must be cleaned and disinfected between use.
  8. Prohibit the use of tightly confined spaces (e.g. supply closets, equipment storage areas, kitchens, vehicles, or restrooms) by more than one person at a time, unless both individuals and staff sharing such space are wearing acceptable face coverings. However, even with face coverings in use, occupancy must never exceed 50% of the maximum capacity of the space or vehicle, unless it is designed for use by a single occupant.
  9. Day Programs should increase ventilation with outdoor air to the greatest extent possible (e.g. open program room and vehicle windows and prop open doors and/or open as frequently as possible), unless such air circulation poses a safety or health risk (e.g., allowing pollens in or exacerbating asthma symptoms) to individuals using the facility.
  10. Day Programs must take additional measures to prevent congregation in lobbies, hallways and waiting areas.
  11. Day Programs must implement additional measures to prevent congregation in elevator(s) waiting area and limit density in elevators, such as enabling the use of stairs, when possible.
  12. Reduce bi-directional foot traffic using tape or signs with arrows in narrow aisles, hallways, or spaces, and post signage and distance markers denoting spaces of six feet in all commonly used areas and any areas in which lines are commonly formed or people may congregate (e.g. entrance/exit into the facility, meal areas, etc.).
  13. Social distancing may not always be possible when caring for individuals with higher medical, behavioral, or adaptive support needs. Their specific treatment plans may necessitate physical contact to ensure health and safety during activities of daily living (e.g. toileting, eating etc.), behavior intervention techniques (e.g. physical restraint) or medical treatments (e.g. administration of daily medication or first aid etc.). All appropriate personal protective equipment and hygiene must be utilized.

Gatherings in Enclosed Spaces

  1. Richmond is prohibiting gatherings of more than 15 people (excluding staff) in a shared space, at any given time. Rooms should be reconfigured or repurposed to limit density and expand usable space.
  2. Program rooms should include the same grouping of individuals with the same staff each day to the extent possible and avoid crossing programs with other rooms.
  3. Space out seating (6 feet apart) and use floor markers to designate six-foot distances. Remove additional seating above designated room capacity.
  4. Day Programs must provide adequate space for required staff to adhere to social distancing while completing independent tasks (i.e. paperwork) and when taking breaks (e.g. eating). Break times should be staggered to maintain social distancing.

Food Services

  1. Shared food and beverages are prohibited. Food brought from home should require limited preparation at the day program site (i.e. heating in microwave) and be packed appropriately. All reusable food utensils and storage containers should be washed in the dishwasher on the hottest wash and dry setting.
  2. Buffet-style dining is prohibited. Discontinue use of large cafeterias for meals, unless social distancing can be maintained, and stagger mealtimes
  3. To allow for social distancing and disinfection in-between use.

 Food services:

  • Serve individual portions.
  • Avoid use of communal dining areas and substitute eating outdoors or in a classroom, whenever possible.
  • Keep stable groups of individuals separated from one another.
  • Consider staggering mealtimes to reduce occupancy within an indoor space or congregation within an outdoor area; and
  • Separate tables with seating at least six feet apart from other tables, as feasible.

Personal Protective Equipment

  1. Day Programs must have an adequate supply of required PPE on site. All required staff and essential visitors are required to wear a face covering or mask and will be provided one for use onsite at no cost.
  2. All Day Program staff should comply with OSHA standards applicable to each specific work environment.
  3. Face coverings must be cleaned or replaced after use and may not be shared.
  4. All staff must be trained on proper use of PPE including when to use and donning, doffing, disposing, and/or reusing and sanitizing when appropriate. Documentation of such trainings will be retained in the employee’s personnel file.

Hygiene and Cleaning

Hygiene and sanitation requirements is required to reduce transmission as advised by DOH “Guidance for Cleaning and Disinfection of Public and Private Facilities for COVID-19.”  
All agency site-based day programs, and non-site-based programs to the extent it is applicable, are required to implement the following minimum standards:

  1. Maintain an adequate stock of cleaning and EPA approved disinfecting agents.
  2. Conduct frequent cleaning and rigorous disinfection of high-risk areas (i.e. bathrooms, nursing stations) and high touch surfaces (i.e. shared equipment or supplies). Please refer to DOH’s “Interim Guidance for Cleaning and Disinfection of Public and Private Facilities for COVID-19” for detailed instructions on how to clean facilities.
  3. Adhere to proper dwell times for all cleaners, sanitizers and disinfectants per manufacturer recommendations as indicated on the product label and ensure adequate ventilation to prevent inhaling toxic fumes. Use only EPA registered products for disinfecting non-porous surfaces.
  4. Maintain at each site cleaning logs indicating the date, time, and scope of cleaning.
  5. Cleaning products, sanitizers and disinfectants must be kept secure and out of reach of individuals who may misuse (i.e. consume, dump out etc.). Products should be locked in a separate supply closet or cabinet, with only staff having key access. After sanitizing or disinfecting any gloves, paper towels or other disposable items used will be immediately discarded. These should be tied in a trash bag and removed from the environment to prevent individuals from accessing potentially contaminated or hazardous materials.
  6. Limit use of shared objects/equipment and clean then sanitize after each use. Items that cannot   be cleaned and sanitized should not be used (i.e. soft toys, cloth placemats, etc.) Individuals should not be permitted to bring such personal items from home.
  7. Put in place reasonable measures to limit the sharing of objects, such as electronic equipment, arts and craft materials, touchscreens, as well as the touching of shared surfaces; or, require employees to wear gloves (trade-appropriate or medical) when in contact with shared objects or frequently touched surfaces; or, require workers and individuals to practice hand hygiene before and after contact.
  8.  If cleaning or disinfection products or the act of cleaning and disinfecting causes safety hazards, staff must use PPE as needed followed by hand hygiene. Use cleaning/disinfecting wipes for electronics (do not use sprays). Limit the number of people using the equipment when proper cleaning/disinfecting of such items are not possible.
  9. Provide and maintain hand hygiene stations throughout each location, where possible to include:
  • Handwashing: soap, running warm water, and disposable paper towels.
  • Hand sanitizing: alcohol-based hand sanitizer containing at least 60% alcohol for areas where handwashing facilities may not be available or practical. Hand sanitizer should be available and utilized frequently throughout community-based services.
  • All staff and individuals should wash their hands frequently with soap and water, for at least 20 seconds upon arriving to any site-based programming, before handling food, before and after eating and drinking, smoking/vaping, using the bathroom, after touching shared objects or surfaces, after touching their eyes, nose or mouth, or after cleaning, sanitizing or disinfecting surfaces or when hands are visibly dirty.
  • Use of hand sanitizer by individuals should be supervised as needed by staff.

CDC Guidelines for Cleaning and Disinfecting Day Program Sites  
If someone is suspected or confirmed to have COVID-19 infection:

  1. Will close off areas used by the person who is sick. Richmond may not necessarily close operations if they can safely close off the affected areas.
  2. Open outside doors and windows to increase air circulation in the area.
  3. In accordance to OPWDD, DOH and the CDC, Richmond will clean and disinfect all areas used by the person who is sick such as offices, classrooms, bathrooms, common areas, and shared equipment.
  4. Once the area has been appropriately disinfected, it can be opened for use.
  5. Employees and individuals without close contact with the person who is sick can return to the area immediately after disinfection.

All certified agency Day Programs must ensure that the following measures are in place to transport individuals to/from day programming:

  1. In most cases, only individuals and staff from the same program site will be transported together; however, in accordance with OPWDD guidelines, Richmond may allow individuals who are participating in the same day program site, but who live in different residences or family homes to be transported together. Families could also decide to transport directly.
  2. Capacity on buses, vans, and other vehicles should be reduced to 50% of total capacity to maximize social distancing and reduce COVID-19 transmission risks.
  3. Richmond Day Programs may stagger arrival and departure times to reduce density during these times.
  4. To the extent possible, individuals and staff will restrict close contact by not sitting near each other or the driver.
  5. Additionally, if there are multiple doors in a bus or van, one-way entering and exiting may be utilized. Individuals should be directed to not exit the vehicle at once, instead following driver or staff instruction on exiting one person at a time.
  6. To the extent they can medically tolerate one, individuals, staff, and the driver must always wear face- coverings in the vehicle.
  7. After each trip is completed, the interior of the vehicle will be thoroughly cleaned before additional individuals are transported; and
  8. Where appropriate and safe, windows should be rolled down to permit air flow.

Tracing and Tracking

  1. Richmond Community Services must notify the local health department and OPWDD immediately upon being informed of any positive COVID-19 test result by an individual or staff at their site.
  2. In the case of a staff or visitor testing positive, Richmond will cooperate with the local health department to trace all contacts in the workplace and notify the health department of all staff, individuals and visitors who entered the facility dating back to 48 hours before the staff began experiencing COVID-19 symptoms or tested positive, whichever is earlier, but maintain confidentiality as required by federal and state law and regulations.
  3.  Local health departments will implement monitoring and movement restrictions of infected or exposed persons including home isolation or quarantine.
  4. Staff who are alerted that they have come into close or proximate contact with a person with COVID-19, and have been alerted via tracing, tracking or other mechanism, are required to self-report to their Program Administrator, at the time of alert, and shall follow all required protocols as if they had been exposed at work.