CMS Memo QSO-20-38-NH: 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

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Long-Term Care (LTC) Facility COVID-19 Testing Requirements (QSO 20-38-NH, revised 9/10/2021)

Please read the memo carefully. CMS has revised testing requirements for nursing homes including testing of symptomatic residents and staff, and routine testing of staff. Two major changes are:

  • Facilities now have two options to conduct outbreak testing, through either a contact tracing or broad-based testing approach. See Table 1.
  • Routine staff testing is now based on the facility’s county level of community transmission instead of county test positivity rate. The link to determine county level of community transmission is in the memo. The frequency of testing has also been updated. See Table 2.

 

Table 1: Testing Summary

Testing Trigger

Staff

Residents

Symptomatic individual identified

Staff, vaccinated and unvaccinated, with signs or symptoms must be tested.

Residents, vaccinated and unvaccinated, with signs or symptoms must be tested.

Newly identified COVID- 19 positive staff or resident in a facility that can identify close contacts

Test all staff, vaccinated and   unvaccinated, that had a higher-risk exposure with a COVID-19 positive individual.

Test all residents, vaccinated and unvaccinated, that had close contact with a COVID-19 positive individual.

Newly identified COVID- 19 positive staff or resident in a facility that is unable to identify close contacts

Test all staff, vaccinated and unvaccinated, facility-wide or at a group level if staff are assigned to a specific location where the new case occurred (e.g., unit, floor, or other specific area(s) of the facility).

Test all residents, vaccinated and unvaccinated, facility-wide or at a group level (e.g., unit, floor, or other specific area(s) of the facility).

Routine testing

According to Table 2 below

Not generally recommended

 

Table 2: Routine Testing Intervals by County COVID-19 Level of Community Transmission

Level of COVID-19 Community

Transmission

Minimum Testing Frequency of

Unvaccinated Staff+

Low (blue)

Not recommended

Moderate (yellow)

Once a week*

Substantial (orange)

Twice a week*

High (red)

Twice a week*

+Vaccinated staff do not need to be routinely tested.

 

Please see the full memo for complete details at https://www.cms.gov/medicareprovider-enrollment-and-certificationsurveycertificationgeninfopolicy-and-memos-states-and/interim-final-rule-ifc-cms-3401-ifc-additional-policy-and-regulatory-revisions-response-covid-19-0.