Nursing homes now have clearer guidance on how to report and notify residents, families and staff around the presence of COVID-19 in their facilities. On May 8, 2020, the Centers for Medicare & Medicaid Services (CMS) issued an interim final rule that covered specific requirements on how and when details about suspected or confirmed cases of COVID-19 among residents or staff members must be reported to the federal government. These new requirements must be completed in tandem with reporting mandated by state and local health officials. Below is an overview of the CMS guidance to support nursing home leaders as they comply with this new federal reporting requirement.
What nursing homes must report
The expanded requirements from CMS are intended to support nursing homes in COVID-19 infection control and monitoring and provide greater transparency around facility exposure for residents, families and staff. To that end, CMS is requiring all nursing home facilities to electronically report the following information to the Centers for Disease Control and Prevention (CDC):
- Suspected and confirmed COVID-19 infections among residents and staff, including residents previously treated for COVID-19
- Total deaths and COVID-19 deaths among residents and staff
- Personal protective equipment and hand hygiene supplies in the facility
- Ventilator capacity and supplies in the facility
- Resident beds and census
- Access to COVID-19 testing while the resident is in the facility
- Staffing shortages
If a nursing home experiences one or more confirmed COVID-19 infections OR three or more staff members or residents develop new respiratory symptoms within 72 hours of each other, the facility must notify residents, their representatives and family members by 5 p.m. the next calendar day. This notification must follow these parameters:
- Exclude personally identifiable information
- Include any infection mitigation actions implemented and whether these deviate from normal operations
- Include cumulative updates on overall cases or infections
Get full detail on reporting requirements in the May 6 CMS memo and FAQs.
When to start reporting
Nursing homes must submit their first report to CDC no later than 11:59 p.m. Sunday, May 17, 2020. After that, subsequent reports are required on a weekly basis (day of the week is up to the nursing home). CMS will also publish the reported information on a publicly accessible site.
To help ease facilities into this new reporting requirement, CMS is providing an initial two-week grace period through 11:59 p.m. on May 24. Nursing homes that still have not reported by May 31 will receive a warning letter. If reports are not received by June 7, CMS will impose a fine of $1,000 per day. This per day amount fine will increase by $500 for each subsequent week a facility fails to submit.
Get ready to report
Nursing homes must submit their weekly COVID-19 reports through the CDC National Health Safety Network’s Long-Term Care Facility COVID-19 Module.
Before using the module portal, nursing homes must ensure their computers have the necessary email and internet security settings. Next, facilities must register with NHSN and then complete the Security Access Management System (SAMS) registration process. Nursing homes will need to electronically accept the NHSN participation and consent agreement before registration is official. Visit the enrollment guide for full instructions.
Survey and FAQs
CMS updated the COVID-19 Focused Survey, which should be coded in the Automated Survey Process Environment (ASPEN) under “Survey Type” as U=COVID-19. If the survey is taking place with an IJ complaint investigation, the survey should be coded in ASPEN under “Survey Type” as A=complaint and U=COVID-19. This will help ensure consistent, accurate reporting.
RKL’s Senior Living Services Consulting team is available to help facilities prepare their systems and processes to comply with this expanded reporting requirement. Contact your RKL advisor or reach out through the form below for assistance or with any questions.
