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CMS Updating Requirements for Nursing Home Infection Surveillance & Reporting

The Centers for Medicare & Medicaid Services (CMS) issued a QSO Memo on Sunday, April 19, 2020, “Upcoming Requirements for Notification of Confirmed COVID-19 (or COVID-19 Persons Under Investigation) Among Residents and Staff in Nursing Homes.” The QSO Memo outlines reporting requirements for nursing homes to provide data directly to the Centers for Disease Control (CDC) as well as for facility notification of residents/representatives on conditions inside the facility. In a press release issued alongside the guidance, CMS Administrator Seema Verma emphasized the importance of nursing home reporting to the CDC to assist with enhancing a nation-wide COVID-19 Surveillance System that can help reopen the country. 

COVID-19 Reporting to CDC

Although existing regulatory requirements are in place that require nursing homes to have a surveillance and reporting system in place to ensure that State and/or Local health departments are notified about outbreaks, including residents or employees with confirmed or suspected COVID-19, residents with severe respiratory infections that resulted in hospitalization or death, and 3 or more residents or staff with new-onset respiratory symptoms within 72 hours of each other, the data is not being collected on a national scale by federal agencies. This means that CMS, CDC and FEMA do not have access to this information, so CMS and CDC have collaborated to provide guidance and a standard reporting format to facilities that can be used for surveillance of COVID-19 on a larger scale with more data. Here’s what to know:

  • Information will be reported through the CDC National Health Safety Network system.
  • Guidance has not yet been released on the reporting format, but should be expected shortly.
  • There are plans to make this data available publicly after it is collected.

Requirements for Resident and Resident Representative Reporting

CMS plans to additional rulemaking in the near future that will require nursing homes to notify its residents/representatives regarding conditions inside the facility. The requirements will include:

  • Notification to residents and their representatives within 12 hours of the occurrence of:
    •  A single confirmed COVID-19 infection OR
    • 3 or more residents or staff with new-onset of respiratory symptoms that occur within 72 hours
  • Weekly updates to residents/representatives OR notification each subsequent time that a confirmed COVID-19 infection is identified or when 3+ residents/staff have new onset of respiratory symptoms within 72 hours of each other
  • Providing information in the updates on what mitigation is being implemented to prevent or reduce the risk of transmission, including if normal nursing home operations will be changed.

The QSO Memo states that failure to provide timely reporting of resident/staff incidence of communicable disease or infection, including confirmed COVID-19 cases or cases of Persons Under Investigation (PUI) for COVID-19, to residents/representatives may result in enforcement action against the facility.

Last week, CMSCG President Linda Elizaitis wrote on our blog about how nursing homes need to be prepared for enhanced scrutiny of Infection Prevention & Control practices by the regulators in the future. This, she notes, is partially attributed to inconsistency in surveillance, tracking and trending practices by providers. Read her blog post, “Infection Prevention & Control – Beyond COVID-19,” here.

We continue to update our list of COVID-19 resources for healthcare

View the full 4/19/2020 QSO Memo (Ref: QSO-20-26-NH) here.

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