If staffing is supplemented with temporary employees, independent contractors, or by staff-sharing, these considerations may be helpful.

During the current COVID-19 pandemic, Senior Living and Human Services organizations may face the challenge of insufficient staffing to meet their clients’ increasing needs. Under these circumstances, organizations are likely to turn to external sources to supplement staffing levels. According to the Centers for Disease Control and Prevention (CDC), maintaining appropriate staffing in healthcare facilities is essential to providing safe care and a safe work environment for healthcare personnel (HCP). As the COVID-19 pandemic progresses, staffing shortages will likely occur due to HCP exposures, illness, or need to care for family members at home.

Senior Living and Human Services organizations must enact contingency plans to address staffing shortages caused by the current COVID-19 pandemic. If staffing is supplemented with temporary employees, independent contractors, or by staff-sharing with an affiliated or unaffiliated similarly situated organization, these considerations may be helpful.

Onboarding Considerations

Follow your organization’s existing onboarding policy and procedure in compliance with Center for Disease Control (CDC) guidelines, Americans with Disabilities Act (ADA), and Equal Employment Opportunity Commission (EEOC) statutes. Your state may have emergency declarations and temporary waivers for specific processes during the COVID-19 pandemic.

  • Continue to complete documented background screenings to protect individuals, and screen temporary employees, independent contractors, or shared staff. This includes national and state child and sex offender registry, written job applications, criminal background checks, drug screenings, and fingerprinting where required by state or federal agencies. Discounted background checks are available through our vendor partner relationship with IntelliCorp.
    • Due to COVID-19 impacts in some states, use due diligence and document any breakdowns in the screening process.
    • Complete a full screening as soon as is possible.
    • Seek guidance from legal counsel as necessary.
  • Screen all temporary employees, independent contractors, or shared employees for COVID-19 after a conditional job offer.
  • Symptomatic individuals are considered “direct threats” to the health and wellbeing of the facility per CDC and EEOC.
  • Follow internal hiring practices, in line with CDC guidelines and EEOC guidance, to delay or withdraw the job offer for symptomatic HCP until they can safely provide care at the organization.
  • Verify educational qualifications of clinical staff.
  • Staff that cannot be fully screened according to established measures should not have unsupervised one-on-one contact with individuals until a full screening can be completed.

Risk Transfer Controls

  • A written contract should be sought with any agency or independent contractor, stipulating the terms of the arrangement, including which party is required to provide professional liability insurance. If it is determined that your organization will provide the insurance, consult with your insurance agent on appropriately covering temporary workers or independent contractors. If the agency or independent contractor will provide the insurance, include insurance requirements for certificates of insurance, require that your organization be named as an Additional Insured, and ensure liability language such as hold harmless and mutual indemnification clauses favor to your organization.
  • Contracts should be reviewed by your own attorney.
  • When employees are ‘shared’ with another organization, every effort should be made to have that organization officially hire the shared staff member.

Training Considerations

Training, as for any new staff, should be completed for all temporary employees, independent contractors, or shared staff. Some organizations may already have expedited training protocols as part of their internal emergency response protocols. Consider the following areas of training for temporary employees, independent contractors, or shared staff:

  • Review of facility COVID-19 protocols
  • Infectious Disease Preparedness and Response Plan
  • Workplace controls and personal protective equipment (PPE) requirements
  • Abuse, Neglect, and Molestation Prevention and Reporting protocols
  • Medication Management protocols
  • Internal training for staff within their specified role
  • Disaster and emergency management including fire alarm notifications, evacuation plans, and any applicable elopement control measures.
  • Additional risk management programs as deemed necessary

Considerations specific to COVID-19

The COVID-19 prevention and control considerations are the same as for your regular staff. Here are some reminders.

  • Staff caring for those with suspected or confirmed COVID-19 infection should follow the CDC guidance regarding appropriate personal protective equipment.
  • Minimize number of employees assigned to care for residents with COVID-19, and do not float staff between units or facilities.
  • Instruct HCP to monitor themselves for fever or symptoms, have a process to actively screen all HCP for symptoms, and implement a response plan to protect staff and clients.
  • Encourage use of supportive services such as an employee assistance program.
  • Develop a contingency plan to transfer residents to appropriate settings if your organization cannot attain adequate staffing levels.

As always, consult the CDC COVID-19 guidance, federal guidance and state guidelines on the best ways to protect your facility and stay within compliance.

Additional information on preventing unnecessary exposures among residents, employees, and visitors can be found in our COVID-19 Guidelines for Senior Living and Human Services Organizations document.


CDC Mitigating staff shortages
EEOC and ADA screening guidance
Nationwide Loss Control Services resources
CDC Coronavirus Disease
CDC guidance for PPE
State specific temporary waivers

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