The Centers for Disease Control and Prevention (CDC) and the National Healthcare Safety Network (NHSN) continue to provide guidance to SNFs regarding the NHSN Long-Term Care Facility (LTCF) COVID-19 Module. All SNF facilities are currently required to submit weekly reports on COVID-19 data.
Key Points for LTC Facilities:
- Not later than May 17, 2020, SNFs must submit data going back to May 1, 2020.
- F884: COVID-19 Reporting to CDC is the new federal survey tag detailing the reporting requirements.
- CMS has confirmed that the required COVID-19 data will be reported publicly on Nursing Home Compare
Failure to report data to the NHSN database could result in an enforcement action. Facilities that fail to begin reporting by May 31will receive a warning letter reminding them to begin reporting the required information to CDC. Facilities that fail to report by June 7 will be subject to a per day (PD) Civil Money Penalty (CMP) of $1,000 for each failure to report. Continued noncompliance will result in additional PD CMPs imposed at an amount increased by $500 per week for a total of $4,500 imposed CMPs.
The NHSN Long-Term Care Facility COVID-19 Module training and registration can be found on the CDC website. Facilities should immediately gain access to the NHSN system and begin reporting the required information for each of the pathways. Below are highlights regarding instructions for each of the four reporting pathways to assist facility representatives in submitting data to NHSN accurately. Full instructions along with the pathways can be found on the CDC website under the LTCF COVID-19 Module.
Resident Impact and Facility Capacity Pathway
- The Admissions count should include any newly admitted or readmitted residents treated for COVID-19 regardless if the resident(s) is still in the facility. For example, the count should include resident(s) that remain in the facility, were transferred out of the facility, admitted to another facility, as well as those who have died.
- The Confirmed count should include residents with new laboratory-positive COVID-19 results regardless of whether the resident(s) is still in the LTCF. For example, the counts should include resident(s) that remain in the facility, were transferred out of the facility, admitted to another facility, as well as those who have died.
- The Suspected count should include residents with signs and symptoms suggestive of COVID-19 as described by CDC’s guidance but does not have a laboratory-positive COVID-19 test result. This may include residents who have not been tested or those with pending test results. It may also include residents with negative test results but continue to show signs and symptoms suggestive of COVID-19.
- Include residents with newly suspected COVID-19 signs and symptoms regardless of whether the resident is still in the LTCF. For example, the count should include suspected resident(s) that remain in the facility, were transferred out of the facility, admitted to another facility, as well as those who have died.
- The Total Deaths count should include both COVID-19 related deaths AND non-COVID-19 related deaths.
- The COVID-19 Deaths count should include deaths of residents that had either suspected COVID-19 and/or laboratory-positive COVID-19 results.
- If a resident previously had laboratory-positive or suspected COVID-19 but recovered and is no longer being treated as having COVID-19 (for example, resolved signs and symptoms) at the time the COVID-19 Death count is being collected, do not include the resident in the COVID-19 Deaths count. Instead, include the resident in the Total Deaths count.
- The Census count should include all residents who are occupying a bed in the facility, even non-licensed beds (for example, additional beds had to be brought in to handle increased capacity of residents or residents are being moved to other parts of the facility that are not normally included in the LTCF bed count).
- A response to the Testing question is required to SAVE this pathway.
Staff and Personnel Impact Pathway
Staff and facility personnel should include anyone working or volunteering in the facility, which includes, but is not limited to contractors, temporary staff, resident caregivers, shared staff, etc.
- The Confirmed COVID-19 count should include staff and facility personnel with new laboratory-positive COVID-19 results only.
- The Suspected COVID-19 count should include staff and personnel with signs and symptoms suggestive of COVID-19 as described by CDC’s guidance but do not have a laboratory-positive COVID-19 test result. This may include staff and personnel who have not been tested or those with pending test results. It may also include staff and personnel with negative test results but continue to show signs and symptoms suggestive of COVID-19.
- The COVID-19 Deaths count includes staff and facility personnel with suspected or laboratory-positive COVID-19 results who have died.
- Each facility representative should identify staffing shortages based on their facility’s needs and internal policies for staffing ratios. The use of temporary staff does not count as a staffing shortage if staffing ratios are met according to the facility’s needs and internal policies for staffing ratios.
Supplies and Personal Protective Equipment Pathway
- There are two categories with yes or no responses:
- Do you have a currently supply?
- Do you have enough for one week?
- “Any” means any PPE for staff to use. The goal is to identify shortages.
- The data being submitted must reflect the supply and PPE status on the actual date of the submission to the NHSN database.
- If the facility is extending the use of PPE including reuse of PPE or utilization of non-traditional PPE such as cloth masks, etc., questions should be answered as having a shortage.
Ventilator Capacity and Supplies Pathway
Facility representatives must answer if they have ventilator-dependent units or beds. If the answer is no, the remaining questions in this section can be skipped.
- The Mechanical Ventilators count should include the total number of mechanical ventilators available, including portable ventilators.
MECHANICAL VENTILATORS IN USE
- The Mechanical Ventilators In Use count should include the total number of mechanical ventilators in use for residents who have suspected or laboratory-positive COVID-19.
- The response to these questions is based on all needed ventilator supplies, including but not limited to tubing, flow sensors, connectors, and valves. If the facility is missing any supply item needed to care for residents on mechanical ventilation, answer “NO”.
General Highlights Regarding Data Submission to the Pathways
- After the first submission, the NHSN facility ID, CCN, facility name, and total number of resident beds will be auto-generated.
- Facility representatives can report daily, or non-daily but must report at least weekly on the same day of the week and same time. For example, every Monday at 9 am.
- Facility representatives should use a line list or NHSN data collection form to gather data. These forms are available here.
- The facility representative must select a date on the calendar with each submission. This date must be the date the responses are reported. For example, if data was collected and reported on May 8, 2020, that is the date that should be chosen.
- Submitting data prior to May 1, 2020 is not required but is encouraged. If a facility chooses to submit this data, consider using the calendar feature. The facility will select any calendar date prior to May 1, 2020 and enter the total number residents for each area between January 1, 2020 and April 30, 2020. If data is not available at the time of data entry, leave blank and revise counts later when data is available.
- All data from May 1, 2020 and forward is required to be reported through the NHSN platform.
- If this is the first submission in the NHSN COVID-19 Module, enter the number of resident counts for each area the week data is entered. For example, if data is being entered on May 8, 2020 at 9 am, the counts should include May 1, 2020 at 9 am to May 8, 2020 at 9 am for a total of seven days. Do not enter retrospective data at this time for any data gathered in May.
- If this is not the first time counts are being entered in the NHSN LTCF COVID-19 Module, enter the number of residents for each area since the last date counts were entered. The goal is to capture only new counts. It is very important to collect data at the same time every day as this keeps facility data consistent.
- Data elements consist of counts and yes or no responses to questions.
- Any yes or no questions should be answered based on the day the data is being entered.
- Corporations may wish to upload multiple SNF’s data, which can be done by utilizing the groups/supergroups option. A CSV template is available on the CDC website.
- Facilities must enter a response for all questions even if it is a zero. Any blanks will be considered as missing data and the entry will be deemed incomplete.
- Recommended browsers to access NHSN include: Internet Explorer 11, Microsoft Edge, Chrome, Firefox, or Safari (latest version).