CMS Issues QSO Memo on Staff Testing

Yesterday, the Centers for Medicare & Medicaid Services (CMS) released QSO memo 20-38-NH outlining details on compliance with the new interim final rule 483.80(h) requiring COVID-19 testing of staff.  In discussions with the Michigan Department of Health & Human Services (MDHHS) staff, they have indicated they are reviewing the CMS guidance as it relates to the current Michigan COVID testing requirements and are expecting to release updates in the near future. 

CMS is requiring facilities to conduct three types of testing: 

Symptomatic Testing: Test any staff or residents who have signs or symptoms of COVID-19 (facility must continue screening all staff, residents and other visitors).

Outbreak Testing: Test all staff and residents in response to an outbreak (defined any single new infection in staff or any nursing home onset infection in a resident) and continue to test all staff and residents that tested negative every 3-7 days until 14 days has passed since the most recent positive result. 

Routine Testing: Test all staff based on the extent of the virus in the community, using CMS' published county positivity rate in the prior week as the trigger for staff testing frequency.  This frequency includes:

• Low Risk = < 5% Positivity in County = Test Staff Monthly
• Medium Risk = 5% - 10% Positivity in County = Test Staff Weekly
• High Risk = > 10% Positivity in County = Test Staff Biweekly

CMS indicated they will maintain & post County Positivity Rates HERE beginning August 28, 2020.  In addition, CMS shared this frequency is based on the premise Point of Care (POC) testing is available at the facility for rapid results, or outside diagnostic results are attainable within 48 hours. 

In addition to the testing cadence, CMS includes guidance and clarification regarding other related areas including:

• Types of tests (antigen and PCR)
• Definition of facility staff (staff and contractors or vendors who regularly provide care and services)
• Documenting issues with test supplies and shortages
• Dealing with refusals by residents or staff
• Reporting requirements 
• Documenting test results
• Conducting tests
• Documenting/demonstrating compliance at F886
  

CMS Issues QSO Memo on COVID Test Reporting

The Centers for Medicare & Medicaid Services (CMS) also released S&C Memo QSO-20-37-CLIA, NH yesterday, outlining reporting requirements and enforcement of CLIA requirements related to COVID testing.  Currently, Michigan SNFs report COVID testing results from outside labs directly to CMS through weekly National Healthcare Safety Network (NHSN). 

 

Facilities conducting Point of Care (POC) tests under a CLIA certificate of waiver are subject to regulations that require laboratories to report data for all individual tests completed to the local or public health department.  The Association has requested reporting guidance from the Michigan Department of Health & Human Services (MDHHS) to ensure facilities have accurate information regarding required reporting mechanisms for the POC COVID tests. 

HCAM will share additional documentation and guidance with members as it becomes available.

 

TOMORROW!! AHCA Hosting Member Call on Testing & Reporting - New CMS Testing Requirements for Staff & Residents: What You Need to Know

Please join AHCA/NCAL for an all member webinar with President and CEO Mark Parkinson and Chief Medical Officer Dr. David Gifford tomorrow, Friday, August 28 at 11 a.m. EST on the interim final rule released this week.

 

As a reminder, the rule establishes a new requirement for nursing home facilities for COVID-19 testing of staff and residents. On tomorrow's webinar, learn what providers can do now to successfully comply and implement the new requirements.

 

This webinar is for AHCA/NCAL facility members only - Click HERE to Register

Please Note:  

• Use Google Chrome to avoid technical problems.
• Members must log in using their existing AHCA/NCAL username and password first.
• Register once logged in to the website.
• Forgot your password? Click HERE.
• If you are new to the site, create an account HERE. After doing so, you will be able to register for the webinar. Please note, all new account holders must add their member facility to their account at the time of account creation.

The webinar recording will be posted on ahcancalED as soon as it is available.

Screening Kiosks and Hands Free Screening Device Use Supported by LARA

Screening devices that utilize thermo-imaging or other technologies to screen individuals for COVID-19 are acceptable for use in long term care communities.  Michelle Roepke, Director Federal Certification and Survey Division of the Michigan Department of Licensing & Regulatory Affairs (LARA) has confirmed that the use of technology to assist in COVID screening and documenting screening results is supported by the department.  Surveyors will not cite for the use of technology to support providers efforts to screen individuals entering facilities.

 

 

For questions or concerns please contact Cathy Sunlin at CathySunlin@HCAM.org. 

 

Aug. 27, 2020