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 CMS Issues Interim Final Rule on SNF’s COVID-19 Reporting Requirements

The Centers for Medicare & Medicaid Services (CMS) has released a QSO memo addressing the interim final rule requiring skilled nursing facilities (SNFs) to report to National Healthcare Safety Network (NHSN) on COVID-19, as well as to provide notifications to residents, their representatives, and families. 

The American Health Care Association/National Center for Assisted Living (AHCA/NCAL) said these requirements go into effect with the publication in the Federal Register of the interim final rule on May 8. 

CMS had previously communicated the effective date was May 1. However, the agency revised the effective date to May 8, AHCA/NCAL said.

Highlights of the interim final rule are: 

--The effective date means SNFs are required to begin notifications of residents, their representatives, and families as of May 8. This means the first notification could be required to occur by May 9 at 5 p.m., should the facility have any of the resident and/or staff COVID-19 cases on May 8 as described by CMS required to make notification. 

--Action: Providers should ensure system and processes for notifications are in place by May 8 to meet new requirements. 

Facilities must submit their first set of data by 11:59 p.m. on May 17 to the NHSN Long Term Care Facility (LTCF) COVID-19 Module.

--Action: Providers should register now for NHSN and begin collecting data starting May 8. [NOTE: Registration is taking more time than expected, and AHCA/NCAL encourages providers to start now to avoid further delays that may impact a facility’s compliance.] Also note that the memo provides an overview of the registration process. For NHSN questions, please email: and add “LTCF” in the subject header. 

CMS will provide facilities with an initial two-week grace period to begin reporting cases in the NHSN system (which ends at 11:59 p.m. on May 24). Facilities that do not begin reporting after the third week (by 11:59 p.m. on May 31) will receive a warning letter reminding them to begin reporting the required information to the Centers for Disease Control and Prevention (CDC). 

For facilities that have not started reporting in the NHSN system by 11:59 p.m. on June 7, ending the fourth week of reporting, CMS will impose a per day (PD) civil money penalty (CMP) of $1,000 for the failure to report that week, AHCA/NCAL said. 

For each subsequent week that the facility fails to submit the required report, the noncompliance will result in an additional one-day PD CMP imposed at an amount increased by $500. 

For enforcement-related questions, email:

In addition, CMS has established two new F-Tags - F884: COVID-19 Reporting to CDC and F885 COVID-19 Reporting to Residents, their Representatives, and Families. 

CMS has also updated survey tools, including COVID-19 Focused Survey for Nursing Homes, Entrance Conference Worksheet, COVID-19 Focused Survey Protocol, and Summary of the COVID-19 Focused Survey for Nursing Homes. AHCA/NCAL said these updated forms are posted to the 
Survey Resources folder in the COVID-19 Focused Survey sub-folder on the CMS Nursing Homes website. 

--Action: AHCA/NCAL said facilities should begin using the revised “COVID-19 Focused Survey for Nursing Homes” to perform their self-assessments. Surveyors will begin using these revised documents immediately. 

CMS anticipates publicly posting CDC’s NHSN data (including facility names, number of COVID-19 suspected and confirmed cases, deaths, and other data as determined appropriate) weekly on Mondays at by the end of May. 

Lastly, AHCA/NCAL said CMS provides 22 Q&As in the last seven pages of the memo. Question 10 addresses retrospective reporting and reads as below: 

Q: Are facilities required to report data that predates the effective date (May 8) of the interim final rule? 

A: No, there is no requirement in the rule to collect older data.​

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