Tuesday, May 12, 2020

NHSN Reporting Recap and Next Steps

Nursing centers who are still waiting for access to the National Healthcare Safety Network (NHSN) COVID-19 reporting module are encouraged to document all attempts to gain access to NHSN including any email communications you have with the NHSN help desk. Centers trying to register for NHSN continue to run into enrollment delays and lag time between initial registration process and actually gaining access to the reporting system. The delays may put centers at risk for non-compliance. Centers should keep documentation to track and log every attempt to register and gain access to NHSN, email communications to NHSN help desk, and communication responses from NHSN help desk dates to provide to state surveyors and the Centers for Medicare and Medicaid Services (CMS) in the event that your center is not granted access by the end of the grace period.

On May 6, CMS released a QSO memo on the Interim Final rule requiring nursing centers to report to NHSN which went into effect on May 8th. Facilities are required to submit their first set of data by 11:59pm on Sunday, May 17 to NHSN Long-Term Care Facility COVID-19 Module. CMS provided facilities with an initial two-week grace period to begin reporting cases in the NHSN system which ends at 11:59pm on May 24. Centers who do not begin reporting by 11:59pm on May 31 will receive a warning letter reminding them to begin reporting the required information to the NHSN COVID-19 Module. For centers who fail to report by 11:59pm on June 7, CMS will impose a per day (PD) CMP of $1,000 for failure to report that week. Each subsequent week that the facility fails to submit the required report will result in an additional one-day PD CMP imposed at an amount increased by $500. The memo also included information about two F-tag citations (F884 – COVID-19 Reporting to CDC and F885 – COVID-19 Reporting to Residents, their Representatives, and Families).

AHCA recommends accurately reporting the staffing and personal protective equipment (PPE) situation at nursing homes based on normal standards and guidance for PPE and staffing, not utilizing conservation guidance. Federal and state governments will use this data to hold nursing homes accountable for care and services provided and to identify who needs additional resources. It is important that the data reported to NHSN gives an accurate picture of staffing and PPE as well as the other areas collected in NHSN. Nursing homes should keep documentation of their efforts to secure more PPE as well as staffing. You should also report to your local and state health departments that you are employing contingency and crisis strategies to conserve PPE and staffing.

As a reminder, the new rule requiring nursing centers to report to NHSN is optional for assisted living communities.  Assisted living communities should follow specific state reporting requirements and notifications.

The four NHSN data collection pathway forms are:

No comments:

Post a Comment