UPDATE: West Virginia Nursing Home Vaccination Distribution Plan

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Anders W. Lindberg

Member, Chair, Litigation Department

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December 10, 2020
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The West Virginia Department of Health and Human Resources (“DHHR”), in conjunction with the West Virginia Health Care Association, issued new guidance on the administration of vaccines to Long-Term Care Facilities’ (“LTCF”) residents and staff. Importantly, residents of LTCFs are now slated to be among the first to receive the vaccine, alongside health care workers at LTCFs. Additionally, the DHHR has suggested a change to the logistical framework for the shipment and administration of the vaccine, calling on pharmacies to serve as intermediaries between the state and LTCFs. 
 
Due to changes by the CDC, the prior distribution plan was modified. Under the new distribution plan (“Push plan”), West Virginia would establish an “approved” pharmacy list. Every LTCF would then partner with its preferred pharmacy that will act as an intermediary between it and one of five state-controlled shipment hubs for the vaccine. Once the appropriate information is received from the pharmacy, the pharmacy would administer the vaccine on site at the LTCF. Furthermore, the pharmacy would handle the vaccine reporting requirements. Both the pharmacy and LTCF will track dose administration to ensure that both doses of the vaccine are received in a timely manner, consistent with the requirements of the two vaccines being evaluated by the FDA for emergency use authorization.
 
There are many outstanding issues that still need to be resolved by the state, including payment and consent. LTCFs are asked to identify their preferred pharmacy, as well as an alternative pharmacy option.
 
Additional guidance is expected in the coming days. Please contact the authors of this alert with any questions or concerns you may have.