The Occupational Safety and Health Administration on Wednesday will start a round of follow-up inspections of hospitals, nursing homes and skilled nursing facilities that previously received citations for COVID-19-related infractions.

The facilities will have to prove that any past pandemic violations were corrected, and also provide a number of documents and other measures to prove they’ll be prepared for another wave of COVID-19.

“I think for the most part, we’re going to see hospitals being ready for these because hospitals are constantly having to be prepared for quality types of inspections, whether it’s from their state licensure agency, other regulators or CMS,” said Kevin Troutman , a partner at Fisher Phillips, adding that skilled nursing facilities might have a harder time. “Nursing homes and smaller operations may face a bigger challenge just because they don’t typically have as much in the way of resources and dedicated quality assurance types of staff.”

Health facilities will have to show emergency response plans, procedures in place to validate employee vaccinations, COVID-19 employee illness logs and protocols for personal protective equipment use. Inspectors will also interview employees on the proper use of respirators, and how to do PPE fit tests.

Meanwhile, registered nurse union National Nurses United argued that OSHA shouldn’t just be revisiting facilities with previous citations or complaints, arguing that all hospitals and nursing home providers should be inspected. By not doing so, OSHA is likely missing a slew of safety issues and not protecting all healthcare workers, including nurses, they said.

OSHA inspections for the first two months of 2022 have not focused heavily on the healthcare industry; only 4.6% of total inspections this year were in this sector. Construction was the leading site of inspections, followed by manufacturing, retail and waste management, according to a report just released by Fisher Phillips.

OSHA estimated in a release that it expects healthcare investigations in this 90-day period to encompass 15% of inspections in each region.

There’s likely more action coming from the CDC this year on a broader range of infectious diseases. Last year the agency said it wanted to revive an infectious disease proposed rule from 2010 that’s repeatedly been relegated to a list of lower agency priorities over the years.

A proposed rule would create an infection control program standard, targeting diseases like chicken pox, influenza and other air-borne diseases, creating a programmatic approach for another potential pandemic.

The potential for a new standard and the increased enforcement actions are a reminder to hospitals that despite the Centers for Disease Control and Prevention and states have relaxed mask mandates,

“After two years people are just kind of tired of all the precautions, but in hospitals, it’s still part of what you do every day, and they’re going to have to keep doing it,” Troutman said. “My advice to hospitals is, don’t lose your focus.”

The components of the short-term initiative are part of the healthcare COVID-19 Emergency Temporary Standard that expired in December 2021. However, OSHA said then that it would use the standard to evaluate healthcare facilities while working on a permanent rule.