CMS to Enforce Nursing Homes’ COVID-19 Reporting Effective June 7

A minimum of every seven days, nursing homes are now required to report COVID-19 information to the Centers for Disease Control and Prevention (CDC) via the Long-Term Care Facility (LTCF) COVID-19 Module at the National Healthcare Safety Network (NHSN).

“A majority of nursing homes across the United States have successfully enrolled in NHSN, and most of those have reported data,” say officials with the Centers for Medicare & Medicaid Services (CMS). “However, it is critical for national surveillance of the trajectory of the disease in our country that every single nursing home enroll and start reporting information as soon as possible, so we will be enforcing noncompliance or nonreporting.”

In addition, the data will be used to help providers obtain needed resources, adds Jeneita Bell, MD, the Long-Term Care Lead at NHSN. “We are not collecting data merely for the sake of collecting data, and CMS is not looking to penalize you [based on the results of the data]. We are looking to help you.”

The LTCF COVID-19 Module includes four reporting pathways that are used to collect information mandated under the Interim Final Rule Updating Requirements for Notification of Confirmed and Suspected COVID-19 Cases Among Residents and Staff in Nursing Homes, according to CMS Quality, Safety, and Oversight (QSO) memo QSO-20-29-NH.

Providers can choose to set their reporting schedule at “any time during the week and as many times as you would like during the week,” but must report a minimum of every seven days based on a final Sunday deadline, say CMS officials. “You have to have [your reporting] in by that date.” For example, a facility may choose to report daily; every Monday, Wednesday, and Friday; every Friday; etc. The key is to set and follow a consistent reporting schedule that doesn’t go past that Sunday deadline.

The first week of data needed to be reported to the CDC beginning May 8 but no later than May 17. This means that the first report was due May 17, and the second was due on May 24. The third report will be due on May 31. “If we have not received the report by that time, you will receive a warning letter for no report,” say officials. “Then with the fourth report, which is due June 7, we will begin to look at enforcement actions.”

NHSN Help Desk Tips

The NHSN Help Desk has received many questions about the enrollment and reporting requirements. Bell offers the following pointers to reduce response time or obtain an answer another way:

• Put “LTCF” in the subject line. NHSN receives e-mails from state health departments, hospitals, and other partners in addition to nursing homes, notes Bell. Putting LTCF in the e-mail’s subject line “helps us triage your e-mail a little bit faster [and get it] to the appropriate person to answer your question.”
• Don’t repeat an already submitted question in a new e-mail. Sending the same question more than once “slows down our ability to respond rapidly,” says Bell.
• Print and complete data collection forms if waiting to enroll. Providers that are waiting for a response to an enrollment question can print out the data collection forms and complete them on an ongoing basis, suggests Bell. “You will have the data ready at your fingertips when you are [enrolled], and you won’t have to search back in your records to catch up and be compliant with CMS requirements.”
• Review available documentation while waiting for an answer. The enrollment and reporting materials at the LTCF COVID-19 Module website may have answers to many of the questions being sent to the NHSN Help Desk, says Bell. One example of this is a system error that prevented some providers that successfully enrolled from receiving the final NHSN e-mail with instructions on how to electronically accept the NHSN Agreement to Participate and Consent so they could actually enter data. The NHSN Long-Term Care Facility Enrollment Guide (page 9) provides the weblink that allows facilities to complete this final step without help desk guidance.
• Contact the Quality Improvement Network Quality Improvement Organization (QIN-QIO) for assistance. “If you experience some issues and you are waiting on a response from NHSN, please reach out to your QIN-QIO,” says Bell. “They are a tremendous resource and a wonderful partner of NHSN. They have experience with enrolling nursing homes, trouble-shooting common issues, and also supplying you with assistance to report.” Note: Locate the QIN-QIO for each state here.

NHSN data reporting errors to avoid

Early data reporting errors include the following, according to Bell:

• An incorrect CMS Certification Number (CCN). “It is very important to ensure that you have the correct CCN when you enroll in NHSN. Go back and check—and fix it if you need to—because that is an important data field that we use to match up the data with the records that we send over to CMS,” says Bell. “If that information is not correct, you might get a letter from CMS stating that you had not reported.” The following excerpt adapted from the NHSN Long-Term Care Facility Enrollment Guide explains how to find the facility’s CCN and edit it if needed:

If you are a certified CMS facility and do not know your CCN, use this link to find it: https://qcor.cms.gov/main.jsp:

• Select “Tool>basic search”
• Enter your facility name
• The Participation date is the CCN Effective Date needed for enrollment

If unable to locate the facility CCN or if it cannot be validated in NHSN, you may request a temporary enrollment number also known as the CDC Registration ID by contacting NHSN@CDC.GOV. The temporary enrollment number is only valid for 30 days.

Instructions for adding or editing CCNs are available here.

• Aggregate data counts. In two of the NHSN LTCF Reporting Module’s pathways—the Resident Impact and Facility Capacity Pathway and the Staff and Personnel Impact Pathway—providers are asked to submit aggregate data, if available, from January 1 through April 30, notes Bell. “After that point, you are required to report data at least on a weekly basis.”

Reporting after May 1 is not cumulative and should include only new counts since the last time counts were entered for each specific question, says Bell. “We have seen some instances where a facility reports each day, and the count continues to increase. For example, the facility may report 30 on Monday, 31 on Tuesday, and 36 on Wednesday, etc. Please do not do that.”

Note: If this facility reports Monday – Friday, reporting 30 on Monday would mean there are 30 new cases in the facility since Friday (assuming it’s not the first reporting week), reporting 31 on Tuesday would mean there are 31 new cases since Monday, and reporting 36 on Wednesday would mean there are 36 new cases since Tuesday. Only new counts since the immediately preceding count should be entered.

“If you have further questions, please refer to our Table of Instructions for each reporting pathway,” suggests Bell.

Note: Bell and the CMS officials spoke at the May 13 and May 20 CMS Call With Nursing Homes.

Caralyn Davis

Caralyn Davis is a freelance writer specializing in the post-acute care sector. Email her at: caralynd@outlook.com.