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Ftag of the Week – F886 re COVID-19 Testing (Part 1)

In an August 26, 2020 QSO, the Centers for Medicare & Medicaid Services (CMS) provided several policy and regulatory revisions related to COVID-19 and long-term care facility testing requirements. This is the third Ftag that CMS has added to the Infection Control regulatory group since the beginning of the COVID-19 Public Health Emergency (PHE). F886 requires nursing homes to test all residents and staff for COVID-19. Here are some of the specifics:

Testing Parameters

Testing must be conducted based on the parameters set out by the Health and Human Services (HHS) Secretary, including:

  • Frequency of testing
  • Identification of any individual diagnosed with COVID-19 in the facility
  • Identification of any individual with symptoms consistent with COVID-19 or with known/ suspected exposure to COVID-19
  • Criteria for testing asymptomatic individuals
  • Test result response time
  • Other factors that help identify and prevent COVID-19 transmission

Testing must be conducted in a manner consistent with established best practices for COVID-19 testing.

Per the Interpretive Guidance included in the QSO Memo, facilities can meet the testing requirements by using rapid point-of-care tests or by making arrangements with an off-site laboratory. Facilities that wish to conduct their own tests must have a CLIA Certificate of Waiver. If a facility cannot conduct COVID-19 POC testing, it should make arrangements with a lab to conduct the tests as per the requirement.

Who Needs to be Tested

All residents and facility staff, including employees, consultants, contractors, volunteers and caregivers who provide care and services to residents on behalf of the facility, as well as students from affiliated academic institutions and student in the facility’s nurse aide training programs must be tested.

A Testing Summary table has been included in the QSO Memo. These are the parameters:

  • If a symptomatic individual is identified, staff with signs and symptoms must be tested and residents with signs and symptoms must be tested.
    • Symptomatic Staff – must be tested and should be restricted from the facility pending the results of COVID-19 testing. If there is a positive result, the staff member should follow the CDC’s return to work criteria. If the result is negative, but the staff has symptoms, facility policies on when the person should return to work should be followed.
    • Symptomatic Resident – must be tested, and while results are pending, the resident should be placed on transmission-based precautions per CDC guidance. Based on the test results, the facility should take appropriate action.
  • If there is an outbreak of any new case arising in the facility, all staff and residents should be tested, and all staff and residents that tested negative should be re-tested every 3-7 days until testing identified no new cases of COVID-19 among staff or residents for at least 14 days since the most recent positive result.
    • Per the IG, a resident who is admitted to the facility with COVID-19 does not constitute a facility outbreak.
    • For individuals who test positive for COVID-19, repeat testing is not recommended and instead, a symptom-based strategy should be used. Relevant CDC guidance is included in the QSO Memo.
  • For routine testing, staff testing intervals will vary by the level of COVID-19 Activity in the Community. Don’t worry, there’s a table provided for that as well. Testing of residents is not recommended unless the resident is routinely leaving the facility.
    • Per the IG, facilities should use their county positivity rate in the prior week to see what level of routine testing should be done. The plan is for the positivity rates to be housed on https://www.cdc.gov/coronavirus/2019-ncov/hcp/testing-overview.html by August 28, 2020. The, based on the community activity level and county positivity rate, facilities will know whether their minimum testing frequency is once a month, once a week or twice a week.
    • The two weekly testing frequencies are based on the presumption that POC tests are available on-site or the turnaround time for off-site testing is less than 48 hours.

Preventing Transmission

  • Facilities must take actions to prevent the transmission of COVID-19 upon identification of an individuals with symptoms consistent with COVID-19 or who tests positive for COVID-19.
  • Facilities must have procedures for addressing both residents and staff who refuse testing or are unable to be tested.

Test Refusals – Staff

  • These procedures, per the IG, should ensure that symptomatic staff who refuse testing should be prohibited from entering the building until they have met the return to work criteria.
  • If outbreak testing is underway and staff refuse the test, they should be restricted from the building until the outbreak testing process has been completed.
    • Any occupational health or local jurisdiction policies related to asymptomatic residents refusing tests should be followed as well.

Test Refusals – Residents

  • If residents or representatives refuse COVID-19 testing, staff should discuss the importance of testing with them.
  • Procedures must be in place to address residents who refuse testing.
  • Symptomatic residents who refuse testing should be placed on transmission-based precautions until the criteria for discontinuation has been met.
  • If there is an outbreak and testing is triggered, and an asymptomatic resident refuses testing, the facility is expected to ensure the resident remains at an appropriate distance from other residents, wears a face covering and practices effective hand hygiene until the outbreak testing cycle has been completed.
  • If a resident has symptoms consistent with COVID-19 or has been exposed, or if there is an outbreak and the resident declines testing, that resident should be placed on transmission-based precautions until he/she meets the criteria for discontinuation of these precautions.

When There is a Supply Shortage

Facilities, if necessary, are expected to contact state and local health departments to assist in testing efforts if there is an emergency such as a supply shortage of testing materials, difficulty obtaining testing supplies, or difficulty processing test results.

Screening

Screening should continue, regardless of testing or COVID-19 status of the facility, per the IG. Specifically:

  • All staff should continue to be screened each shift.
  • Each resident should be screened daily.
  • Everyone entering the facility should be screened for signs and symptoms of COVID-19.

The above information is a lot to digest, and not even all of the information that providers need to know. Stay tuned for Part 2 of our Ftag of the Week – F886 for information on conducting testing, documentation, and reporting requirements.  The COVID-19 saga continues!

To review the QSO Memo, “Interim Final Rule (IFC), CMS-3401-IFC, Additional Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency related to Long-Term Care (LTC) Facility Testing Requirements and Revised COVID-19 Focused Survey Tool” (QSO-20-38-NH) in full, please click here.

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