September 9, 2020
Dear Administrator:
Thank you for your efforts to keep residents and staff of long-term care facilities (LTCFs) safe and healthy. Virginia remains committed to supporting LTCFs as the COVID-19 pandemic continues to evolve. Please visit the Virginia Long-Term Care Task Force website for current guidance for nursing homes and assisted living facilities. In addition, the Virginia Department of Health (VDH) website has current statewide epidemiologic data.
Nursing Home NHSN Reporting
Per the Code of Virginia (§32.1-35.1), data required to be reported to the National Healthcare Safety Network (NHSN) to meet Centers for Medicare and Medicaid Services (CMS) requirements should be shared with VDH through the NHSN system. In order for VDH to view data from LTCFs reporting in NHSN, VDH is requesting that each nursing home join the VDH NHSN group. You can find instructions on how to do that here. Licensed but not certified nursing homes are not required to report data to CMS, but they may report to NHSN and are encouraged to confer rights to VDH. Please refer to the June 5 memo for additional information.
CMS Testing Requirements for Nursing Homes
CMS published an interim final rule on August 25, 2020, and a memo with a revised focused survey tool on August 26, 2020, that require nursing homes to test all residents and staff for COVID-19. Testing should be completed i) on symptomatic residents and staff; ii) during an outbreak (in which any new case arises in the facility); and iii) on a routine basis. Please review the memos for detailed information.
During an outbreak, the nursing home should repeat testing for individuals testing negative every 3 to 7 days until no new cases are identified for 14 consecutive days. Frequency of routine testing of staff should be based on community COVID-19 activity, wherein low activity (less than 5% county positivity rate) entails testing at least monthly; medium activity (5 – 10% county positivity rate) entails testing at least weekly; and high activity (greater than 10% county positivity rate) entails testing twice weekly. CMS requires that nursing homes use the county-level COVID-19 viral (RT-PCR) laboratory 7-day test positivity rates available on the CMS website. HHS is sending point-of-care testing instruments to nursing homes; frequently asked questions about distribution are available here.
CDC Antigen Testing Guidance for Nursing Homes
The Centers for Disease Control and Prevention (CDC) published a summary of considerations for the use of SARS-CoV-2 antigen testing in nursing homes on August 27, 2020. Antigen tests are point-of-care diagnostics that generate rapid results and are a critical component of timely identification and containment of new cases. The sensitivity of antigen tests is lower compared to that of RT-PCR tests, thus antigen testing is especially applicable to situations where RT-PCR testing capacity is limited or results are delayed by more than 48 hours. An algorithm for interpreting antigen test results in a nursing home setting is available.
Reporting Results from Point-of-Care Testing
Facilities using point-of-care (POC) diagnostic equipment under a CLIA certificate of waiver must report all SARS-CoV-2 test results for each individual tested via NHSN and to the state or local health department. Additional information about CMS reporting requirements is available here. VDH is developing a reporting portal for POC testing results. In the interim, all positive results from POC tests should be reported to the VDH Online Morbidity Reporting Portal within 24 hours. Negative POC results should be added to a line list and faxed to the local health department and also reported within 24 hours. Once the new reporting portal is available, a statewide announcement will be made.
Recommendations for Hospitalized Patients Discharged to LTCFs
VDH recently published a simplified flow chart to inform discharge planning between hospitals and LTCFs. The resource is meant to guide discussions between facilities and ensure compliance with CDC guidance on use of transmission-based precautions for COVID-19 positive patients, and quarantine for patients potentially exposed to COVID-19.
CARES Act Funding for LTCFs
On June 19, 2020, Governor Northam announced that nursing homes and assisted living facilities (ALFs) are eligible for COVID-19 related cost reimbursement using CARES Act funding. The Department of Medical Assistance Services (DMAS) has issued guidance for how facilities can obtain reimbursement. CARES Act funds may be used to reimburse COVID-19 related expenses incurred from July 1, 2020 – October 31, 2020, including purchasing personal protective equipment (PPE), complying with new testing requirements, spending on staffing shortages, and increasing infection control measures. Questions from nursing homes can be directed to caresactinvoicing_nf@mslc.com, and from ALFs to caresactinvoicing_alf@mslc.com.
Vaccination of Residents and Staff in LTCFs
Now is the time for LTCF residents and staff to get their influenza vaccine. Widespread flu vaccination is especially important for high-risk groups such as older adults and people with chronic disease and their contacts and caregivers, including healthcare workers. This year, flu prevention is important to ease stress on the healthcare system. Flu and COVID-19 present with similar symptoms. Protection from flu through vaccination will reduce the number of symptomatic individuals and the spread of illness in LTCFs. Please contact your local health department to discuss opportunities for increasing flu vaccination rates in your facility. In addition to vaccines, facilities should ensure they have proper storage and supplies on hand for vaccination efforts.
The Virginia Immunization Information System (VIIS) is used to consolidate immunization data from multiple sources into a single record. LTCFs not already enrolled in VIIS are encouraged to learn more about the benefits of VIIS and how to enroll here. Enrollment in VIIS will be required before COVID-19 is shipped in Virginia, as facilities will be required to log administration of COVID-19 vaccine in VIIS. Every organization enrolled in VIIS requires an association with a Medical License Number. The Medical License Number used can be associated with a medical director or other healthcare practitioner in the facility. Questions can be directed to VIISInfo@vdh.virginia.gov. More information about how to order COVID-19 vaccine will be shared as soon as it is available.
Training Resources for LTCF Staff
Please visit the Virginia LTC Task Force website for a list of available materials. There are two infection control courses, including one released by CMS on August 25, 2020. There are shorter, more targeted materials relevant for frontline healthcare workers and support staff.
On September 16, 2020, the VDH Tuberculosis (TB) Program is hosting a webinar on TB screening, testing, and treatment; LTCFs are encouraged to attend. Additional information is available here.
Thank you for all your continued efforts to protect Virginians from COVID-19. Please continue to contact your local health department if you have questions about COVID-19.
Sincerely,
M. Norman Oliver, MD, MA
State Health Commissioner