On September 23, 2022, the Centers for Medicare & Medicaid Services (CMS) released an updated 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,” (Ref: QSO-20-38-NH). This QSO Memo was originally published by CMS on August 26, 2020. The new guidance includes updated testing recommendations for individuals who have recovered from COVID-19 and also provides leniency in routine testing of asymptomatic staff. The guidance in this document is related to F886 COVID-19 Testing- Residents & Staff. The requirements for F886 have been updated multiple times (September 2021 and March 2022) since they were originally published.
CMS Aligns Guidance with CDC Recommendation
As has occurred throughout the COVID-19 Public Health Emergency (PHE), CMS has updated its guidance to reflect the recommendations of the Centers for Disease Control (CDC).
The updated QSO Memo states that staff are expected to follow the CDC “Interim Guidance for Managing Healthcare Personnel with SARS-CoV-2 Infection or Exposure to SARS-CoV-2” which was updated on September 23, 2022.
Updated Guidance – Testing of Nursing Home Staff and Residents
Facility staff, regardless of COVID-19 vaccination status, should be advised to report any of the following criteria to the point of contact designated by the facility so they can be appropriately managed:
- Positive viral test for SARS-CoV-2
- COVID-19 symptoms
- Higher-risk exposure to someone with a SARS-CoV-2 infection
Staff or Residents with Signs/Symptoms of COVID-19
- Staff who have symptoms of COVID-19 must be tested as soon as possible, regardless of their vaccination status. The updated guidance still requires that these staff are restricted from work pending the residents of the test.
- Residents who have signs/symptoms of COVID-19 must also be tested as soon as possible, regardless of vaccination status. Those residents should be placed on transmission-based precautions (TBP) in accordance with CDC guidance.
New Resident Admission Testing
The revised guidance directs providers to review the CDC’s guidance “Managing admissions and residents who leave the facility” section of the CDC “Interim Infection Prevention and Control Recommendations for Healthcare Personnel During the Coronavirus Disease 2019 (COVID-19) Pandemic” webpage.
Updated Testing Summary Table
Providers and staff alike will be excited to see that the testing summary table now states that routine testing of staff is not generally recommended.
This means that routine testing of asymptomatic staff is no longer recommended but may be performed at the discretion of the facility. Providers are directed to review the CDC’s guidance “Interim Infection Prevention and Control Recommendations for Healthcare Personnel During the Coronavirus Disease 2019 (COVID-19) Pandemic,” which was also updated on September 23, 2022.
Testing Staff and Residents During an Outbreak Investigation
Per the revised guidance, an outbreak investigation must be initiated when a single new case of COVID-19 is identified in a staff member or resident so it can be determined if others were exposed. A new clarification was added regarding when testing should begin. Per the guidance, testing should begin immediately, but not earlier than 24 hours after the exposure, if known.
An outbreak investigation is not conducted when:
- A resident with known COVID-19 is admitted to the facility directly into transmission-based precautions (TBP)
- A resident known to have had close contact with someone with COVID-19 is admitted to the facility directly into TBP and developed COVID-19 before TBP are discontinued for that resident
