Category: CMS Memo

CMS Updates to the COVID-19 Public Health Emergency 1135 Blanket Waiver

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CMS has updated the COVID-19 Public Health Emergency 1135 Blanket Waiver on 11/29/21.

The only change in this blanket waiver is for nursing homes for Food and Nutrition Services effective 11/26/21. This waiver applies to 42 CFR 483.60(a)(1) and 483.60(a)(2) under Food and Nutrition Services. This is a waiver for the qualifications of the qualified dietitian or other similarly qualified nutrition professional and the director of food services or the grace period.

The following requirements are waived:

  • Dietitians hired or contracted with prior to November 28, 2016, to meet the specified requirements no later than 5 years after November 28, 2016, or as required by state law; and
  • To designate a person to serve as the director of food and nutrition services who, for designations prior to November 28, 2016, meets the specified requirements no later than 5 years after November 28, 2016, or no later than 1 year after November 28, 2016, for designations after November 28, 2016.

Please see the CMS Public Health Emergency Blanket Waiver -11 29 2021.

CMS Memo QSO-22-04-ALL: Vaccination Regulation: Enforcement of Rule Imposing Vaccine Requirement for Health Care Staff in Medicare-and Medicaid-certified Providers and Suppliers is Suspended so Long as Court Ordered Injunctions Remain in Effect

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Survey and Enforcement of the Vaccine Requirement for Health Care Staff in Medicare-and Medicaid-certified Providers and Suppliers Suspended While Court Ordered Injunctions are in Effect: The Centers for Medicare & Medicaid Services (CMS) will not enforce the new rule regarding vaccination of health care workers or requirements for policies and procedures in certified Medicare/Medicaid providers and suppliers (including nursing facilities, hospitals, dialysis facilities and all other provider types covered by the rule) while there are court-ordered injunctions in place prohibiting enforcement of this provision.

Please see the full memo or https://www.cms.gov/medicareprovider-enrollment-and-certificationsurveycertificationgeninfopolicy-and-memos-states-and/vaccination-regulation-enforcement-rule-imposing-vaccine-requirement-health-care-staff-medicare-and for details.

CMS Memo QSO 20-39-NH: Nursing Home Visitation – COVID-19 (Revised 11-12-2021)

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CMS has issued updated visitation guidance for visitation in nursing homes. The new guidance includes that visitation is now allowed for all residents at all times. DHSS will be updating its guidance as well and it will be consistent with the CMS guidance. Long-term care facilities certified for Medicare and Medicaid are required to follow the CMS memo. All long-term care communities (SNF, ICF, ALF and RCF) may utilize the CMS guidance until the DHSS guidance is updated.

Please see the full memo at https://www.cms.gov/files/document/qso-20-39-nh-revised.pdf.

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.

CMS Memo QSO-21-19-NH: Interim Final Rule – COVID-19 Vaccine Immunization Requirements for Residents and Staff

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Interim Final Rule – COVID-19 Vaccine Immunization Requirements for Residents and Staff

CMS has issued QSO-21-19-NH, which outlines the Interim Final Rule – COVID-19 Vaccine Immunization Requirements for Residents and Staff. This rule establishes Long-Term Care (LTC) Facility Vaccine Immunization Requirements for Residents and Staff. This includes new requirements for educating residents or resident representatives and staff regarding the benefits and potential side effects associated with the COVID-19 vaccine, and offering the vaccine. Furthermore, LTC facilities must report COVID-19 vaccine and therapeutics treatment information to the Centers for Disease Control and Prevention’s (CDC) National Healthcare Safety Network (NHSN). Please read through the memo carefully for facility actions and effective dates.

See the memo or visit https://www.cms.gov/files/document/qso-21-19-nh.pdf for complete details.

Revised CMS Memos

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The Centers for Medicare and Medicaid Services release two revised QSO memos today. Below is a summary of the major revisions in each memo. Please read each in its entirety for all revisions. DHSS guidance will be updated to reflect the revisions in the CMS Visitation memo, however all facilities may begin using this revised guidance immediately.

CMS QSO-20-38-NH Revised – Updated Guidance Regarding Testing
The major revision to this document is regarding routine testing of staff. Routine testing of unvaccinated staff should be based on the extent of the virus in the community. Fully vaccinated staff do not have to be routinely tested. Facilities should use their county positivity rate in the prior week as the trigger for staff testing frequency.

CMS QSO-20-29-NH Visitation
The major revision to this document is regarding group activities and communal dining. The CDC has provided additional guidance on activities and dining based on resident vaccination status. For example, residents who are fully vaccinated may dine and participate in activities without face coverings or social distancing if all participating residents are fully vaccinated; if unvaccinated residents are present during communal dining or activities, then all residents should use face coverings when not eating and unvaccinated residents should physically distance from others. See the CDC guidance Updated Healthcare Infection Prevention and Control Recommendations in Response to COVID-19 Vaccination for information on communal dining and activities.

CMS Memo: QSO-21-15-ALL: Updated Guidance for Emergency Preparedness-Appendix Z of the State Operations Manual (SOM)

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CMS has provided updated guidance for the emergency preparation regulations (Appendix Z). This update is effective immediately.

  • Burden Reduction Final Rule Interpretive Guidelines: The Centers for Medicare &Medicaid Services (CMS) is releasing interpretive guidelines and updates to Appendix Z of the State Operations Manual (SOM) as a result of the revisions of the Medicare and Medicaid Programs; Regulatory Provisions to Promote Program Efficiency, Transparency, and Burden Reduction (CoPs) (CMS 3346-F) Final Rule.
  • Expanded Guidance related to Emerging Infectious Diseases (EIDs): CMS is also providing additional guidance based on best practices, lessons learned and general recommendations for planning and preparedness for EID outbreaks.

Please see the full memo at https://www.cms.gov/medicareprovider-enrollment-and-certificationsurveycertificationgeninfopolicy-and-memos-states-and/updated-guidance-emergency-preparedness-appendix-z-state-operations-manual-som.

CMS Memo: QSO-21-17-NH: Updates to Long-Term Care (LTC) Emergency Regulatory Waivers issued in response to COVID-19

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CMS continues to review the need for existing waivers issued in response to the Public Health Emergency (PHE). Over the course of the PHE, nursing homes have developed policies or other practices that we believe mitigates the need for certain waivers.

  • Therefore, CMS is announcing it is ending:
    • The emergency blanket waivers related to notification of Resident Room or Roommate changes, and Transfer and Discharge notification requirements;
    • The emergency blanket waiver for certain care planning requirements for residents transferred or discharged for cohorting purposes.
    • The emergency blanket waiver of the timeframe requirements for completing and transmitting resident assessment information (Minimum Data Set (MDS)).
  • CMS is providing clarification and recommendations for Nurse Aide Training and Competency Evaluation Programs (NATCEPs)

For more details, please see the full memo at https://www.cms.gov/medicareprovider-enrollment-and-certificationsurveycertificationgeninfopolicy-and-memos-states-and/updates-long-term-care-ltc-emergency-regulatory-waivers-issued-response-covid-19.

Nursing Home Visitation – COVID-19 (QSO 20-39, REVISED 3/10/2021)

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Yesterday- CMS, in conjunction with the Centers for Disease Control and Prevention (CDC), updated visitation guidance with emphasis on the importance of maintaining infection prevention practices, given the continued risk of COVID-19 transmission. The new guidance includes the impact of COVID-19 vaccination. DHSS will be updating its guidance as well and it will be consistent with the CMS guidance. Facilities certified for Medicare and Medicaid are required to follow the CMS memo. All long-term care communities (SNF, ICF, ALF and ICF) may utilize the CMS guidance until the DHSS guidance is updated. CMS hosted a Stakeholder Discussion today regarding the new guidance. A transcript of the session will be uploaded to CMS’ website on 3/12/20 at: https://www.cms.gov/Outreach-and-Education/Outreach/OpenDoorForums/PodcastAndTranscripts.

Key Changes include:

  • Facilities should allow indoor visitation at all times and for all residents (regardless of vaccination status), except for a few circumstances when visitation should be limited due to a high risk of COVID-19 transmission (note: compassionate care visits should be permitted at all times).
  • CMS and CDC continues to recommend facilities, residents, and families adhere to the core principles of COVID-19 infection, including physical distancing (maintaining at least 6 feet between people). This continues to be the safest way to prevent the spread of COVID-19, particularly if either party has not been fully vaccinated. However, they acknowledge the toll that separation and isolation has taken. They also acknowledge that there is no substitute for physical contact, such as the warm embrace between a resident and their loved one. Therefore, if the resident is fully vaccinated, they can choose to have close contact (including touch) with their visitor while wearing a well-fitting face mask and performing hand-hygiene before and after. Regardless, visitors should physically distance from other residents and staff in the facility.
  • Provides guidance to describe how visitation can still occur when there is an outbreak, but there is evidence that the transmission of COVID-19 is contained to a single area (e.g., unit) of the facility.
  • Notes that compassionate care visits and visits required under federal disability rights law should be allowed at all times, for any resident (vaccinated or unvaccinated).
  • States that while visitor testing and vaccination can help prevent the spread of COVID-19, visitors should not be required to be tested or vaccinated (or show proof of such) as a condition of visitation.

Updated Healthcare Infection Prevention and Control Recommendations in Response to COVID-19 Vaccination

CDC has released new guidance, related to vaccinated individuals and the need to quarantine in LTCF. The Updated Healthcare Infection Prevention and Control Recommendations in Response to COVID-19 Vaccination guidance can be used by LTCF. In using this guidance, long-term care communities should carefully think about how they will determine if the person has had prolonged close contact with someone who was positive.

“Quarantine is no longer recommended for residents who are being admitted to a post-acute care facility if they are fully vaccinated and have not had prolonged close contact with someone with SARS-CoV-2 infection in the prior 14 days.”

https://www.cdc.gov/coronavirus/2019-ncov/hcp/infection-control-after-vaccination.html

 The revised guidance is attached.

CMS Memo: QSO 20-31-ALL: Revised COVID-19 Survey Activities, CARES Act Funding, Enhanced Enforcement for Infection Control deficiencies, and Quality Improvement Activities in Nursing Homes

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CMS has revised the criteria requiring states to conduct focused infection control surveys due to the increased availability of resources for the testing of residents and staff and factors related to the quality of care. In addition, CMS has provided Frequently Asked Questions related to health, emergency preparedness and life-safety code surveys.

See the memo for details.

CMS QSO Memo 21-06-NH

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The Centers for Medicare & Medicaid Services (CMS) is committed to being transparent with the public about changes in publicly reported information related to long-term care facilities (i.e., nursing homes) through the COVID-19 public health emergency (PHE).

Changes to the Nursing Home Compare Website and Five Star Quality Rating System:

  • CMS will resume calculating nursing homes Health Inspection and Quality Measure ratings on January 27, 2021.
  • CMS is completing its transition to the new Care Compare website.

Please see the full memo for details.

CMS Memo: QSO-21-02-NH

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Compliance with Residents’ Rights Requirement related to Nursing Home Residents’ Right to Vote

Memorandum Summary

  • The Centers for Medicare & Medicaid Services (CMS) is affirming the continued right of nursing home residents to exercise their right to vote.
  • While the COVID-19 Public Health Emergency has resulted in limitations for visitors to enter the facility to assist residents, nursing homes must still ensure residents are able to exercise their Constitutional right to vote.
  • States, localities, and nursing home owners and administrators are encouraged to collaborate to ensure a resident’s right to vote is not impeded.

Please see the full details in the memo.

CMS Memo: QSO-20-41-ALL

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Guidance related to the Emergency Preparedness Testing Exercise Requirements- Coronavirus Disease 2019 (COVID-19)

Memorandum Summary

  • Emergency Preparedness Testing Exemption and Guidance – CMS regulations for Emergency Preparedness require specific testing exercises be conducted to validate the facility’s emergency program. During or after an actual emergency, the regulations allow for an exemption to the testing requirements based on real world actions taken by providers and suppliers.
  • This worksheet presents guidance for surveyors, as well as providers and suppliers, with relevant scenarios on meeting the testing requirements in light of many of the response activities associated with the COVID-19 Public Health Emergency (PHE).

Please see the full details in the memo.

CMS 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 and Revised COVID-19 Focused Survey Tool – Effective Date: September 2, 2020

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Please read this memo carefully. This memo outlines testing requirements for nursing homes including testing of symptomatic residents and staff, testing in response to an outbreak and routine testing of staff. A revised focused infection control survey protocol is also included which incorporates the requirements in this memo. If attempts to meet the 48-hour turn-around time cannot be met, it is very important that homes document their specific attempts to comply with the testing requirements as outlined in the memo. Routine testing frequency for staff is based on the county-level positivity rates which will be updated weekly (see section titled, “COVID-19 Testing”): https://data.cms.gov/stories/s/COVID-19-Nursing-Home-Data/bkwz-xpvg. NOTE: This memo applies to homes certified for Medicare and/or Medicaid. It does not apply to residential care or assisted living facilities.

COVID-19 LTCF Guidance
This document has been revised to include guidance on the use of antigen tests and updates to guidance made over the last several weeks (specifically related to the change in timeframes for transmission-based precautions and updated reporting guidelines). The guidance can be found at: https://health.mo.gov/living/healthcondiseases/communicable/novel-coronavirus/professionals.php#collapseSix.

Guidance on Reopening of Long-Term Care Facilities
This document has been revised to include guidance on the use of antigen tests. The guidance can be found at: https://health.mo.gov/living/healthcondiseases/communicable/novel-coronavirus/professionals.php#collapseSix.

 

CMS Memo – QSO-20-38-NH
Missouri Interim Guidance for LTCF COVID-19 8-31-2020
Missouri Guidance on Reopening of Long-Term Care Facilities 8-31-20

CMS Memo: QSO-20-28-NH

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Nursing Home Five Star Quality Rating System updates, Nursing Home Staff Counts, Frequently Asked Questions, and Access to Ombudsman (REVISED)

  • CMS is committed to taking critical steps to ensure America’s nursing homes are prepared to respond to the threat of the COVID-19.
  • Nursing Home Compare website & Nursing Home Five Star Quality Rating System: We are announcing that the inspection domain will be held constant temporarily due to the prioritization and suspension of certain surveys, to ensure the rating system reflects fair information for consumers.
  • Posting of surveys: CMS will post a list of the surveys conducted after the prioritization of certain surveys, and their findings, through a link on the Nursing Home Compare website.
  • Nursing Home Staff: CMS is publishing a list of the average number of nursing and total staff that work onsite in each nursing home, each day. This information can be used to help direct adequate personal protective equipment (PPE) and testing to nursing homes.
  • Access to Ombudsman: We are reminding facilities that providing ombudsman access to residents is required per 42 CFR § 483.10(f)(4)(i) and per the Coronavirus Aid, Relief, and Economic Security Act (CARES Act).
  • Frequently Asked Questions (FAQ): We are releasing a list of FAQs to clarify certain actions we have taken related to visitation, surveys, waivers, and other guidance.

Please see the memo or visit https://www.cms.gov/medicareprovider-enrollment-and-certificationsurveycertificationgeninfopolicy-and-memos-states-and/nursing-home-five-star-quality-rating-system-updates-nursing-home-staff-counts-frequently-asked.

CMS Memo: QSO-20-34-NH

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Changes to Staffing Information and Quality Measures Posted on the Nursing Home Compare Website and Five Star Quality Rating System due to the COVID-19 Public Health Emergency

The Centers for Medicare & Medicaid Services (CMS) is committed to transparency about changes in publicly reported information on nursing homes during the COVID-19 public health emergency.

Changes to the Nursing Home Compare Website and Five Star Quality Rating System:

  • Staffing Measures and Ratings Domain: On July 29, 2020, Staffing measures and star ratings will be held constant, and based on data submitted for Calendar Quarter 4 2019.
    • Also, CMS is ending the waiver of the requirement for nursing homes to submit staffing data through the Payroll-Based Journal System. Nursing homes must submit data for Calendar Quarter 2 by August 14, 2020.
  • Quality Measures: On July 29, 2020, quality measures based on a data collection period ending December 31, 2019 will be held constant.

Please see the full details of the memo at https://www.cms.gov/files/document/qso-20-34-nh.pdf.

SNFS are expected to report their Quality Reporting Program (QRP) data starting Quarter 3, which begins July 1, 2020

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The March 27, 2020 Medicare Learning Network Newsletter (MLN) Exceptions and Extensions for QRP Requirements that includes SNFs applies only to Quarter 4 of 2019 (October 1-December 31, 2019) and Quarters 1 and 2 of 2020 (January 1-June 30, 2020). Providers are expected to report data and meet the QRP requirements beginning with Quarter 3, 2020 that starts July 1, 2020.

As stated in that March 27, 2020 MLN Newsletter, “In some instances, these exceptions and extensions are granted because the data collected may be greatly impacted by the response to COVID-19 and therefore should not be considered in the quality reporting program. CMS is closely monitoring the situation for potential adjustments and will update exception lists, exempted reporting periods, and submission deadlines accordingly as events occur.”

Starting with Quarter 3 that begins July 1, 2020, CMS expects providers to report their quality data. CMS will analyze the data recognizing that the COVID-19 public health emergency (PHE) remains in effect and could impact the quality data submitted. CMS will closely monitor the situation for public reporting of the data and provide any updates.

This update is posted on the CMS SNF QRP Spotlights and Announcements webpage.

CMS Memo: QSO-20-29-NH

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Interim Final Rule Updating Requirements for Notification of Confirmed and Suspected COVID-19 Cases Among Residents and Staff in Nursing Homes

  • CMS is committed to taking critical steps to ensure America’s healthcare facilities are prepared to respond to the Coronavirus Disease 2019 (COVID-19) Public Health Emergency (PHE).
  • On May 8, 2020, CMS will publish an interim final rule with comment period.
  • COVID-19 Reporting Requirements: CMS is requiring nursing homes to report COVID-19 facility data to the Centers for Disease Control and Prevention (CDC) and to residents, their representatives, and families of residents in facilities.
  • Enforcement: Failure to report in accordance with 42 CFR §483.80(g) can result in an enforcement action.
  • Updated Survey Tools: CMS has updated the COVID-19 Focused Survey for Nursing Homes, Entrance Conference Worksheet, COVID-19 Focused Survey Protocol, and Summary of the COVID-19 Focused Survey for Nursing Homes to reflect COVID-19 reporting requirements.
  • COVID-19 Tags: F884 and F885.
  • Transparency: CMS will begin posting data from the CDC National Healthcare Safety Network (NHSN) for viewing by facilities, stakeholders, or the general public. The COVID-19 public use file will be available on https://data.cms.gov/.

Please see the full details of the memo.

CMS QSO Memo Release – QSO 20-28-NH

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Nursing Home Five Star Quality Rating System updates, Nursing Home Staff Counts, and Frequently Asked Questions

  • Nursing Home Compare website & Nursing Home Five Star Quality Rating System: The inspection domain will be held constant temporarily due to the prioritization and suspension of certain surveys, to ensure the rating system reflects fair information for consumers.
  • Posting of surveys: CMS will post a list of the surveys conducted after the prioritization of certain surveys, and their findings, through a link on the Nursing Home Compare website.
  • Nursing Home Staff: CMS is publishing a list of the average number of nursing and total staff that work onsite in each nursing home, each day. This information can be used to help direct adequate personal protective equipment (PPE) and testing to nursing homes.
  • Frequently Asked Questions (FAQ): CMS has released a list of FAQs to clarify certain actions we have taken related to visitation, surveys, waivers, and other guidance.

Please see the memo for further details.

CMS QSO 20-26-NH

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Upcoming Requirements for Notification of Confirmed COVID-19 (or COVID-19 Persons under Investigation) Among Residents and Staff in Nursing Homes

  • Communicable Disease Reporting Requirements: To ensure appropriate tracking, response, and mitigation of COVID-19 in nursing homes, CMS is reinforcing an existing requirement that nursing homes must report communicable diseases, healthcare-associated infections, and potential outbreaks to State and Local health departments. In rulemaking that will follow, CMS is requiring facilities to report this data to the Centers for Disease Control and Prevention (CDC) in a standardized format and frequency defined by CMS and CDC. Failure to report cases of residents or staff who have confirmed COVID -19 and Persons under Investigation (PUI) could result in an enforcement action. This memorandum summarizes new requirements which will be put in place very soon.
  • Transparency: CMS will also be previewing a new requirement for facilities to notify residents’ and their representatives to keep them up to date on the conditions inside the facility, such as when new cases of COVID-19 occur.

Please see the memo for details.

CMS QSO Memo Regarding Prioritization of Survey Activities

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CMS Memo QSO-20-20-ALL: https://www.cms.gov/files/document/qso-20-20-all.pdf

Infection Control Survey Checklist

CMS is prioritizing surveys by authorizing modification of timetables and deadlines for the performance of certain required activities, delaying revisit surveys, and generally exercising enforcement discretion for three weeks. During this three-week timeframe, beginning March 20, 2020, only the following types of surveys will be prioritized and conducted:

  • Complaint/facility-reported incident surveys: State survey agencies (SSAs) will conduct surveys related to complaints and facility-reported incidents (FRIs) that are triaged at the Immediate Jeopardy (IJ) level. A streamlined Infection Control review tool will also be utilized during these surveys, regardless of the Immediate Jeopardy allegation.
  • Targeted Infection Control Surveys: Federal CMS and State surveyors will conduct targeted Infection Control surveys of providers identified through collaboration with the Centers for Disease Control and Prevention (CDC) and the HHS Assistant Secretary for Preparedness and Response (ASPR). They will use a streamlined review checklist to minimize the impact on provider activities, while ensuring providers are implementing actions to protect the health and safety of individuals to respond to the COVID-19 pandemic.

CMS is disseminating the Targeted Infection Control Survey checklist developed by CMS and CDC so facilities can educate themselves on the latest practices and expectations. CMS expects facilities to use this new process, in conjunction with the latest guidance from CDC, to perform a voluntary self-assessment of their ability to prevent the transmission of COVID-19. The checklist is attached.

Though the contents of the memo and checklist are provided by CMS, DHSS is adhering to the same requirements for all facilities. All facilities should complete the infection control self-assessment.