CMS Letter Addresses Family Notification, CDC Reporting, and Survey Tool
On May 6, 2020, the Centers for Medicare and Medicaid Services (CMS) issued letter QSO-20-29 outlining a number of key requirements for nursing homes.
Family Notification:
- Notify all residents and family members and representatives of all residents each time either of the following occurs:
- If any resident or staff member tests positive for COVID-19, or if any resident suffers a COVID-19-related death; and
- If there is a cluster of three or more residents and/or staff with new onset of respiratory symptoms (see the Centers for Disease Control and Prevention (CDC) guidance on respiratory symptoms) within 72 hours of each other.
- Provide these notifications by 5 p.m. the next calendar day following a single confirmed COVID-19 infection, respiratory symptom cluster, or COVID-19-related death or within 24 hours of such event, whichever comes first.
- Provide cumulative updates of these events at least weekly, or by 5 p.m. the day following the occurrence of a confirmed COVID-19 infection or new-onset respiratory cluster.
- Include information on mitigating actions implemented to prevent or reduce the risk of transmission, including if normal operations of the facility will be altered.
Reporting to the CDC:
In addition to the resident/family notification requirement, CMS guidance requires all nursing homes (for adult care facilities (ACFs), the CDC reporting is not required, but is at the option of the provider) to report information to the CDC. LeadingAge NY had previously issued guidance on the National Healthcare Safety Network (NHSN) at the CDC with an overview of the reporting module and instructions on how to register in the network.
The areas covered in the reporting to the NHSN are as follows:
(i) Suspected and confirmed COVID-19 infections among residents and staff, including residents previously treated for COVID-19;
(ii) Total deaths and COVID-19 deaths among residents and staff;
(iii) Personal protective equipment (PPE) and hand hygiene supplies in the facility;
(iv) Ventilator capacity and supplies in the facility;
(v) Resident beds and census;
(vi) Access to COVID-19 testing while the resident is in the facility;
(vii) Staffing shortages; and
(viii) Other information specified by the Secretary.
These CDC reporting requirements are in addition to, and do not take the place of, the required daily Department of Health (DOH) reporting through the Integrated Health Alerting and Notification System (IHANS).
Due to a high volume of nursing homes seeking to register in the NHSN, delays have been encountered by many nursing homes. Therefore, additional time beyond the original May 8, 2020 date to submit the data has been granted.
CMS is asking facilities to submit their first set of case data to the CDC by Sun., May 17th, but is granting an initial two-week grace period (which ends on May 24th) for this to occur.
Infection Control-Focused Survey:
Included in the CMS letter is a revised Infection Control Survey Tool that includes the requirements for family notification and CDC reporting. Currently, CMS has suspended routine survey and revisit activities and is focusing almost exclusively on survey of nursing homes for compliance with the requirements issued on COVID-19. Among the areas that the tool reviews are the use of PPEs, staffing, education, screening activities, and infection control surveillance. Members should utilize the Infection Control Survey Tool to evaluate their current infection control practices to ensure that they are in full compliance. We would expect surveillance activities to be linked to data submission.
FAQs:
Also included in the CMS letter are several Frequently Asked Questions (FAQs) that discuss the requirements for notifying families, as well as the CDC reporting requirement.
Contact: Elliott Frost, efrost@leadingageny.org, 518-441-8761