Starnes Davis Florie


COVID-19 Nursing Home Guidance – Compliance Recommendations & Checklists

March 23, 2020

As coronavirus (COVID-19) cases continue to rise in the United States, federal and state agencies have frequently communicated new, and at times confusing, guidelines and requirements for nursing home providers.  Navigating this guidance as a nursing home provider, while operating a facility, is certainly challenging, but absolutely necessary.

In an effort to help navigate this guidance, attached are three coronavirus checklists (including corresponding links to all referenced federal guidance) we prepared based upon the latest (as of March 22) guidance released by the CDC and CMS. We are continuing to update this material as new guidance is released and will send out periodic updates. These checklists cover:

  1. Guidance for nursing homes with no confirmed or suspected case of COVID-19;
  2. Guidance for nursing homes with a confirmed or suspected case of COVID-19; and
  3. Guidance for healthcare providers with symptomatic or asymptomatic employees after known or suspected exposure of an employee to COVID-19.

PLEASE NOTE:  These checklists should be used to ensure your facility is meeting CMS, CDC, and other government guidelines. These are actions you need to make sure your facility undertakes under each scenario. The checklists should be considered items required to be accomplished.  Links to the actual published guidance are included in the checklists.  These documents do not include best practices—that is, activities which might be recommended or prudent, but which are not now required by government agency guidelines.

Starnes Davis Florie LLP has assembled a Coronavirus Support Team to assist nursing homes and other healthcare providers with understanding and navigating this constantly evolving federal and state guidance and responding to related coronavirus issues that may arise, including compliance, regulatory, labor and employment, and litigation matters. Our unique and highly qualified team includes the former state survey agency director for the Alabama Department of Public Health, a former owner and operator of a nursing home, the former general counsel and chief compliance officer of a multi-facility nursing home operation, in-house nurse consultants, an OSHA and life safety code specialist, and other experienced regulatory, healthcare and litigation attorneys.

We are closely following the release of new guidance resulting from the COVID-19 cases across the nation while analyzing the implications for nursing home providers. If you have any questions or need support in understanding and implementing the federal, state, or local guidance regarding COVID-19, please feel free to contact our team by e-mail or calling:

Reed Bates: 205-868-6080 or

Rick Harris: 334-669-3433 or

Trip Umbach (Labor & Employment):  205-868-6072 or

Breanna Young (Labor & Employment): 205-868-6020 or

Click Here to view more COVID-19 Resources

These attachments are not an exhaustive list of all the new federal requirements. Please consult the actual guidance itself for additional information or seek assistance from legal counsel or industry groups.

This information is not intended to provide legal advice, and no legal or business decision should be based on its content. No representation is made that the quality of legal services to be performed is greater than the quality of legal services performed by other lawyers.  Read full disclaimer.

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