Guidance on COVID vaccination and infection control continues to change. Most recently, the Illinois Department of Public Health (IDPH) released updated Emergency Rules regarding COVID that align vaccination and infection control provisions with current Centers for Disease Control and Prevention (CDC) recommendations. The updates include specific guidance for skilled nursing facilities (SNFs) and Assisted Living communities. 

Skilled Nursing
Communities should revise policies and procedures to align with the revised rules listed below.  For the complete rules, click here.

• The term “not up to date” for reporting COVID-19 Vaccination of Facility Staff is deleted.  Instead of requiring that staff be up to date on COVID-19 vaccinations and testing, communities are required to recommend that staff be up to date on vaccinations or tested in a manner that is consistent with the CDC recommendations.  
• The new rules eliminate all provisions related to a vaccination requirement for staff and deletes all testing requirements.
• Communities must now provide clear and accurate instruction to unvaccinated staff; the requirement that they provide a minimum of 90 minutes of instruction on vaccine education is eliminated.
• Facilities are required to track staff COVID-19 vaccination status in each staffer’s confidential medical file (as opposed to vaccination status and weekly testing information). The new rules also have eliminated the penalty language in identifying violations of the vaccination requirements as “Type A,” with the status of “high risk violation” for the purposes of calculating penalties. 

Assisted Living
Rules specific to Assisted Living communities are outlined below and the full description is available here.

• The term Infection Control is amended to ensure that the definition of “outbreak” is consistent with the term as defined in the Control of Communicable Diseases Code
• All testing requirements are eliminated and replaced with a general requirement that communities make recommendations that staff be up to date on COVID-19 vaccinations and tested in a manner consistent with CDC recommendations and the requirements.
• The updated rules no longer require all volunteers to agree to testing.
• Similar to SNFs, the term “fully vaccinated” is replaced with “up to date.” Communities are required to recommend that staff be up to date on COVID-19 vaccinations or tested in a manner consistent with the Centers for Disease Control and Prevention recommendations (opposed to establishments requiring staff be fully vaccinated and tested per requirements).
• Signage must reflect up to date instead of fully vaccinated. 
• As all provisions related to a vaccination requirement for staff are eliminated, the revised rules require that communities offer vaccinations either directly at the establishment or via an arrangement with a pharmacy partner, local health department, or other appropriate health entity.
• The required 90-minute vaccine education of unvaccinated staff is replaced with a general requirement that communities provide clear and accurate instruction including CDC resources on their website.
• Communities are required to track staff COVID-19 vaccination status in each staff person’s confidential medical file (as opposed to vaccination status and weekly testing information) and strike the penalty language identifying violations of the vaccine requirements as “Type 1” violations subject to penalties.