On December 31, 2024, the Centers for Medicare & Medicaid Services (“CMS”) released a memo titled “Long-Term Care (LTC) Facility Acute Respiratory Illness Reporting Requirements” (“Memo”) to state survey agency directors providing survey guidance related to requirements for long-term care reporting through the National Healthcare Safety Network (“NHSN”) as COVID-19 data reporting requirements ended on December 31, 2024.
Background
On November 1, 2024, CMS released a final rule (“Final Rule”) that calls for Medicare-certified and Medicaid-certified nursing homes (“LTC Facilities”) to electronically report information on acute respiratory illnesses, including influenza, severe acute respiratory syndrome coronavirus 2/coronavirus 2019 (“COVID-19”) and respiratory syncytial virus. The Final Rule was published on November 7, 2024, with an effective date of January 1, 2025.
Appendix PP Update Planned
In the Memo, CMS announced that it will develop guidance for surveyors to evaluate compliance with the new acute respiratory illness reporting requirements and provide information on enforcement actions for noncompliance. Once surveyor guidance and enforcement action information are developed, CMS will provide notification that the new requirements have been incorporated into the LTC Facility survey process. This does not alter the effective date of the regulatory requirement for reporting. Therefore, facilities are still required to report data as specified in the requirements.
NHSN Module Is Updated
The NHSN Long-Term Care Facility COVID-19 Module is available and has been updated to include the new data elements that LTC Facilities must report.
Practical Takeaways
- LTC Facilities should continue to report on a regular weekly basis, including reporting of health care personnel’s COVID-19 vaccination status.
- LTC Facilities should immediately gain access to the NHSN system and visit the home page for important information.
- LTC Facilities should look for updated sub-regulatory guidance in Appendix PP in the future.
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- Sean Fahey at (317) 977-1472 or sfahey@hallrender.com;
- Brian Jent at (317) 977-1402 or bjent@hallrender.com;
- Todd Selby at (317) 977-1440 or tselby@hallrender.com; or
- Your primary Hall Render contact.
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