As surges in various respiratory illnesses – including COVID-19 – loom over holiday gatherings, the Centers for Medicare & Medicaid Services (“CMS”) held an Open Door Forum for skilled nursing facility (“SNF”) providers addressing their obligations to offer/provide COVID-19 vaccinations, vaccination education and COVID-19 treatments, and gave providers the opportunity to bring up questions about obstacles they are facing in achieving compliance with the federal requirements.
During the Open Door Forum, CMS focused on the overall declining rates of resident COVID-19 vaccination and rates of staff with up-to-date COVID-19 vaccines and bivalent boosters, as reported by SNFs across the country through the National Healthcare Safety Network (“NHSN”). A pre-Thanksgiving analysis of this data revealed that just 45% of SNF residents and 23% of SNF staff were up-to-date with COVID-19 vaccines and boosters.1
In light of these general nationwide trends, CMS addressed the following during the Open Door Forum:
In addition to existing resources and guidance, CMS used the Open Door Forum as an opportunity to remind SNFs of Quality Improvement Organization (“QIO”) networks. QIO networks across the country bring SNFs on-site support and technical assistance needed to implement the educational and administrative requirements for COVID-19 vaccines and treatments. A QIO can provide educational materials for staff and providers, and can support vaccination uptake initiatives by assisting with:
CMS encourages facilities to connect to their QIO: Locate Your QIO.
Footnotes
1. Entering the Winter Season, How Many Nursing Facility Residents and Staff Were Up-To-Date With Their COVID-19 Vaccines? | KFF
The CDC defines an up-to-date vaccine status as “having received a bivalent booster or having received a final shot of the original vaccines less than 2 months ago.”
2. QSO-21-19-NH (cms.gov)
3. 42 CFR 483.10(c)(6). Note that residents have the right to refuse the COVID-19 vaccine and must be provided with the opportunity to refuse or change their decision about the vaccine at any time.
4. (DHHS – HC Staff Vaccination Requirement) – 2021-23831.pdf (federalregister.gov)
(CMS – Nursing Home Resident and Staff Vaccination Requirement) – Interim Final Rule – COVID-19 Vaccine Immunization Requirements for Residents and Staff | CMS
5. Fact Sheet: COVID-19 Test to Treat (March 29, 2022) (hhs.gov)
6. https://aspr.hhs.gov/TestToTreat/Documents/Fact-Sheet.pdf
7. QSO-23-03-ALL (cms.gov)
8. Who We Help – Nursing Homes | qioprogram.org
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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