Hitting the COVID-19 Vaccine Up-to-Date Moving Target
To code a new vaccine MDS item, long term care staff will need to stay current with the changing recommendations for COVID-19 vaccinations.
Jessie McGill, RN, BSN
9/11/2024
Starting October 1, 2024, the Centers for Medicare & Medicaid Services (CMS) will add a new item, O0350, to the Minimum Data Set (MDS) to indicate whether a resident’s COVID-19 vaccination is up-to-date. To code this item accurately, long term care staff will need to stay current with the recommendations from the Centers for Disease Control and Prevention (CDC) for COVID-19 vaccinations. These recommendations have changed over time and will likely be modified in the future. Thus, this situation creates a moving target that will require the close attention of long term care providers. This article reviews the instructions in the draft Long-Term Care Facility Resident Assessment Instrument 3.0 User’s Manual (RAI User’s Manual)1 and CDC recommendations as of June 2024. It offers tips on how the nurse assessment coordinator (NAC) can code this new item accurately.
New to the MDS October 1, 2024
The new item, O0350: Resident’s COVID-19 vaccine is up to date, asks for a simple yes or no response. But the coding instructions described in the draft are much more complex. CMS recognizes the importance of coding this item on the MDS, stating, “In 2020, persons aged 65 years or older accounted for 81 percent of U.S. COVID-19-related deaths.” CMS also provides care-planning considerations, such as a focus on an effective infection prevention and control program, as well as ensuring that residents and staff remain up-to-date with COVID-19 vaccines.
However, CMS also recognizes some risk, stating, “A vaccine, like any other medicine, could possibly cause serious problems, such as severe allergic reactions. Serious problems from the COVID-19 vaccine are very rare.” It suggests using the “Interim Clinical Considerations for Use of COVID-19 Vaccines in the United States”2 CDC web page as a resource.
To determine whether a resident’s vaccine is up-to-date, the NAC may use information from the medical record or from an interview with the resident, family, or other caregivers or health care providers. However, the NAC must also follow this RAI User’s Manual’s definition of “up-to-date” for COVID-19 vaccines: “For the definition of ‘up to date,’ providers should refer to the CDC webpage ‘Staying Up to Date with COVID-19 Vaccines’ at https://www.cdc.gov/coronavirus/2019-ncov/vaccines/stay-up-to-date.html.” This guideline means that the NAC must follow the recommendations in place at the time of the assessment reference date for the MDS item.
Additionally, if the resident’s COVID-19 vaccination is not current for any reason (e.g., resident refusal, religious exemptions, or medical contraindications), the MDS item should be coded “No,” indicating the vaccine is not up-to-date.
CDC Recommendations
The CDC provides complex guidelines for COVID-19 vaccines based on age, previous vaccinations, and immunocompromised status. But these guidelines may change as updated information is available or new vaccines are developed.
The CDC “Staying Up to Date” web page offered the following information as of July 2024:3
- CDC recommends the 2023–2024 updated COVID-19 vaccines—Pfizer-BioNTech, Moderna, or Novavax—to protect against serious illness from COVID-19.
- Everyone aged 5 years and older should get one dose of an updated COVID-19 vaccine to protect against serious illness from COVID-19.
- Children aged 6 months–4 years may need multiple doses of COVID-19 vaccines to be up to date, including at least one dose of an updated COVID-19 vaccine.
- People who are moderately or severely immunocompromised may get additional doses of an updated COVID-19 vaccine.
- People aged 65 years and older who received one dose of any updated 2023–2024 COVID-19 vaccine (Pfizer-BioNTech, Moderna, or Novavax) should receive one additional dose of an updated COVID-19 vaccine at least four months after the previous updated dose.
Tips to Code O0350 Accurately
To code this new MDS item correctly, staff must stay current on CDC recommendations, including tracking any relevant changes, and clearly document vaccine administration, refusals, exemptions, and any related adverse effects.
- Stay up-to-date with vaccine recommendations:
• Check the CDC “Staying Up to Date” web page frequently.
• Subscribe to the CDC’s “Advisory Committee on Immunization Practices (ACIP): Vaccine Recommendations” news and updates.4
• Watch for trainings offered by ACIP on vaccine recommendations and updates.
- Create a folder to document vaccine recommendations by time period, with clear indications of when changes occurred:
• Print the COVID-19 ACIP vaccine recommendations.5
- Update policy and procedures for COVID-19 vaccines to align with CDC recommendations:
• Create a facility policy for and/or form documenting the administration of COVID-19 vaccines, including the formula (e.g., 2023–2024 formula) and manufacturer.
• Create a facility policy for and/or form documenting any refusal, religious exemptions, or medical contraindications.
- Monitor and document any adverse effects from vaccine administration.
- Ensure clear and consistent documentation practices to streamline data review for the NAC for accurate MDS coding.
Creating a structured policy and a consistent location for documentation regarding vaccine administration or refusal/exemption will streamline the NAC’s data review for accurate MDS coding. Designating a specific location to track changes to CDC recommendations will also ensure the team is following current recommendations and provide support for accuracy during the specific time period.
New Quality Measure
The information collected at MDS item O0350: Resident’s COVID-19 vaccine is up to date, will also be used in a new Skilled Nursing Facility Quality Reporting Program (SNF QRP) measure, COVID-19 Vaccine: Percent of Patients/Residents Who Are Up to Date. Data collection for this measure will begin October 1, 2024, and fourth quarter 2024 data will be used for the fiscal year (FY) 2026 SNF QRP program year. Thereafter, the measure will use a full calendar year (CY) of data (i.e., FY 2026 uses CY 2025).
Because this is also an SNF QRP measure, failure to report data at O0350 may result in a penalty. Dashing O0350 (implying the item was not assessed) counts against the reporting threshold and could result in a 2 percent reduction in the Medicare annual payment update if the facility does not report at least 90 percent of assessments with all of the required data.
Conclusion
The goal of the efforts described here is to protect residents from serious illness by ensuring ttheir COVID-19 vaccinations are up-to-date. This policy not only helps reduce the risk of severe outcomes but also contributes to the overall health and safety of the long term care community. As CDC recommendations continue to evolve, maintaining a proactive and organized approach will be key to meeting CMS requirements, coding the MDS accurately, and reporting required data for quality measure accuracy.
Jessie McGill, RN, RAC-MT, RAC-MTA, is a curriculum development specialist for the American Association of Post-Acute Care Nursing (AAPACN). McGill can be reached at jmcgill@AAPACN.org.