As the country prepares to end the fight against COVID-19, questions regarding the distribution of vaccines have understandably been at the forefront of the minds of

Long-Term Care Facilities (“LTCF”). Indeed, those questions are likely due in part to the differences between the West Virginia Department of Health and Human Resources’ (“DHHR”) proposed plan and the proposed plan of the United States Centers for Disease Control (“CDC”). 

The West Virginia DHHR has indicated that in accordance with Phase 1 of its plan (which could begin in a matter of days), health care personnel, staff members and residents of LTCFs and emergency personnel/first responders will be the first to receive the COVID-19 vaccine. Staff members of LTCFs will be vaccinated before residents, with a portion of the vaccines allocated by the CDC to West Virginia being distributed to LTCFs each week, until all staff members have been offered the vaccine. 

LTCFs have the option of choosing “Vaccination Managed by LTC Staff” or “Vaccination Managed by Pharmacy” during Phase 1 staff vaccinations.  LTCFs that decide to manage their staffs’ vaccinations on-site must enroll as a “vaccinating provider” in the WV COVID Vaccination Program.  Facilities will coordinate with the West Virginia Health Care Authority (“WVHCA”) for distribution and transportation of vaccines.  LTCF staff will manage the inventory and report to the CDC’s Vaccine Administration Management System (“VAMS”) program to submit data during Phase 1, chiefly tracking the doses administered in WV. Importantly, a provider must enroll its facility and all individual users in the VAMS program prior to vaccine orders being filled. 

LTCFs were asked to complete a survey by December 2 submitting certain information, including designating the LTCF’s Employer Coordinator and Vaccine Coordinator.  LTCFs were also required to designate how the facility will handle staff vaccinations (whether managed by LTC staff or by an administrating pharmacy).

In the upcoming weeks, it is expected that additional guidance will be issued as LTCFs begin to administer this vaccine to staff.  For additional questions regarding the administration of COVID-19 vaccines in LTCFs or the associated requirements imposed by the DHHR and CDC, please contact one of the authors of this alert.