PEGWIN wRAM FREQUENTLY ASKED QUESTIONS (FAQs)
Long-term Care (LTC) Facility Requirements for Notification of Confirmed and Suspected Coronavirus Disease 2019 (COVID-19) Cases Among Residents and Staff
WHAT DOES wRAM STAND FOR AGAIN?
wRAM is Pegwin’s Workforce Readiness Assessment Monitor. wRAM was designed to support all healthcare and businesses in preparing their workforce to return to work safely. It is also a requirement for Long Term Care Facilities to comply with the CMS May 8, 2020 Final Rule (available in the Federal Register).
CAN AN INDIVIDUAL SIGN UP DIRECTLY?
Yes, individuals need to answer a request by their employer to download the WhatsApp app and register their cell phone number at the registration link. A message will be sent via WhatsApp to the employee’s phone to take the assessment.
WHAT DOES THE FINAL RULE REQUIRE?
The new CMS reporting requirements specify that facilities must report COVID-19 data to the Centers for Disease Control and prevention (CDC), and to all residents, their representatives, and families.
WHAT IS THE DIFFERENCE BETWEEN THE TERM “NURSING HOME” AND “LONG-TERM CARE FACILITY”?
In this document, the terms “nursing home” (NH) and “long-term care facility” (LTC) are used interchangeably and both refer to a facility that is certified to provide Medicare skilled nursing facility (SNF) services, and/or Medicaid nursing facility (NF) services.
WHAT IS THE PEGWIN MISSION AND VISION FOR IMPLEMENTING wRAM?
To make it safe, rapid, and easy to use for businesses, hospitals, and nursing homes to reopen through automated digital communication between employees and employers. This technology will allow institutions to comply with reopening regulations and restart our economy.
To create a nationwide network of wRAM users who share their safe best practices, and successful reopening of their institutions and businesses with the public, local, state, and national governments.
HOW WILL CMS AND CDC USE THE INFORMATION COLLECTED IN NURSING HOMES?
CDC will use information collected through the CDC’s new National Healthcare Safety Network (NHSN) Long-Term Care Facility COVID-19 Module to strengthen COVID-19 surveillance locally and nationally. Nursing home reporting to CDC is a critical component of the national COVID-19 surveillance efforts and is consistent with White House guidelines, Opening Up America Again.
CMS will use the information to ensure nursing homes are following all requirements for participation, specifically those focused on infection control. CMS may also use the information to determine survey prioritization. Facility-level data collected through NHSN as part of the Long-Term Care Facility COVID19 Module will also be available to a broader set of federal, state, and local agencies. Specifically, COVID-19 data at the state, county, territory, and facility level submitted to NHSN will continue to be used for public health emergency response activities by CDC’s emergency COVID-19 response, by the U.S. Department of Health and Human Services’ (HHS’) COVID-19 tracking system maintained in the Office of the Assistant Secretary of Preparedness and Response (ASPR) as part of the National Response Coordination Center at the Federal Emergency Management Agency (FEMA), and by the White House Coronavirus Task Force.
WHAT ACTIONS ARE THE CENTERS FOR MEDICARE & MEDICAID SERVICES (CMS) TAKING BY REVISING THE REQUIREMENTS FOR PARTICIPATION FOR LTC FACILITIES?
CMS is requiring facilities to report COVID-19 facility data on residents and staff to CDC and to residents, their representatives, and families of residents in facilities. CMS has updated the 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 to reflect these COVID-19 reporting requirements and created two new deficiency tags (F884 and F885). Facilities must submit data through CDC NHSN Long-Term Care Facility COVID-19 Module at least once a week. CMS will begin posting aggregated data from CDC NHSN to https://data.cms.gov/ by the end of May for viewing by LTC facilities, stakeholders, and the general public.
IF STATES ARE ALREADY COLLECTING COVID-19 INFORMATION FROM NURSING HOMES, WHY IS CMS REQUIRING IT TO BE REPORTED TO CDC?
The new reporting tool complements existing, state level reporting efforts. NHSN’s Long-Term Care Facility Module aim is to provide a standardized format due to variation in state and local reporting requirements for COVID-19, and provide a national lens into the experience of long-term care facilities to support and inform the public health response at the local, state, and federal levels. The NHSN Module is not intended as a replacement for state and local public health reporting requirements, and nursing homes are required to continue to report COVID-19 data to state and local health departments in accordance with state and local requirements via existing mechanisms. In some public health jurisdictions, the data that nursing homes report to the new module may supplement the data that they already report to state and local public health authorities. NHSN uses existing functionality (NHSN’s Group Function) to make COVID-19 data immediately accessible to state and local health departments for surveillance and public health response decisions. State and local health departments are also able to submit the required data on behalf of nursing homes, although this does not relieve facilities of their accountability to report in accordance with the regulation.
WILL CDC OFFER TECHNICAL ASSISTANCE/USER SUPPORT TO FACILITIES TO HELP THEM BEGIN REPORTING DATA?
Yes, CDC will offer users training and technical support through a variety of mechanisms, including the following:
CAN STATE HEALTH DEPARTMENTS REPORT COVID-19 DATA TO NHSN ON A NURSING HOME’S BEHALF?
Yes. Each nursing home must first enroll in NHSN to submit its data. Once enrolled, state and local health departments may submit data on behalf of a nursing home. Additionally, data can be batched and submitted as a single file for multiple facilities. We note this does not relieve facilities of their accountability to report in accordance with the regulation. CDC and CMS will work with state health departments and other partners to enable batch data reporting by state health departments or other entities (such as state hospital associations, corporate headquarters, and IT vendors). CDC and CMS will work with state health departments and other partners to communicate and help them utilize this option.
HOW WILL NURSING HOMES KNOW THEIR DATA WAS RECEIVED?
Nursing homes will be able to view their data in the NHSN application upon data submission. NHSN’s analysis and reporting features allows nursing homes to quickly verify that their data have been received.
WILL CMS CITE FACILITIES FOR NONCOMPLIANCE AT F884 AND PENALIZE ANY NURSING HOME WITH A CASE OF COVID-19 REPORTED TO CDC’S NHSN?
The presence of COVID-19 in a nursing home does not automatically mean that facilities are on noncompliance. CMS will not use the data to penalize nursing homes for the presence of COVID-19. Until further notice, surveys will continue to be conducted in accordance with CMS memorandum QSO-20-20-All, which includes surveying for Immediate Jeopardy allegations and Focused Infection Control surveys. CMS has updated the COVID-19 Focused Survey for Nursing Homes with processes related to the new reporting requirements. Surveyors will only cite noncompliance with federal requirements for infection control and prevention based on their investigations, and not based on the COVID-19 information reported through the NHSN system. We note, however, that facilities will be cited and subject to enforcement action for not submitting complete data through the NHSN system in accordance with the new reporting requirements. 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, 2020). Facilities that fail to begin reporting after the third week (by 11:59 p.m. on May 31st) will receive a warning letter reminding them to begin reporting the required information to CDC. For facilities that have not started reporting in the NHSN system by 11:59 p.m. on June 7th, ending the fourth week of reporting, CMS will impose a per day (PD) civil money penalty (CMP) of $1,000 for one day for the failure to report that week. 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 example, if a facility fails to report in week four (following the two-week grace period and receipt of the warning letter), it will be imposed a $1,000 one-day PD CMP for that week. If it fails to report again in week five, the noncompliance will lead to the imposition of another one-day PD CMP in the amount of $1,500 for that failure to report (for a CMP total of $2,500 in PD CMPs). In this example, if the facility complies with the reporting requirements and submits the required report in week six, but then subsequently fails to report as required in week seven, a one-day PD CMP amount of $2,000 will be imposed (which is $500 more than the last imposed PD CMP amount) for a total of $4,500 imposed CMPs.
WHAT IF A FACILITY UNDER-REPORTS COVID-19 DATA TO CDC’S NHSN?
CMS expects facilities to submit complete and accurate information through the NHSN system. CDC understands that identifying cases of COVID-19 in a nursing home can be challenging. However, accurate data is critical to directing public health action and ensuring critical resources and assistance are available to facilities that need them. If, upon further investigation, CMS identifies that a facility did not submit complete and accurate information, the facility would not be in compliance with the new reporting requirements and would be subject to enforcement actions.
HOW LONG WILL REPORTING TO CDC’S NHSN SYSTEM AND TO RESIDENTS, RESIDENT REPRESENTATIVES, AND FAMILIES CONTINUE TO BE REQUIRED?
These requirements go into effect with the publication of the interim final rule. CMS will inform the public and all stakeholders of any changes in the reporting requirements. Until any changes are announced, these requirements remain in effect.
ARE FACILITIES REQUIRED TO REPORT DATA THAT PREDATES THE EFFECTIVE DATE OF THE INTERIM FINAL RULE?
No, there is no requirement in the rule to collect older data. The NHSN system has capability for retrospective reporting from January 2020 onward, consistent with CDC’s mission-critical work, but CMS will not take enforcement action if a nursing home is unable to accurately report information from that time. However, we encourage facilities to report older data as it will help with CDC’s ongoing surveillance and response efforts to assess burden of COVID-19 in nursing homes and support a comprehensive national surveillance of the pandemic.
MUST A FACILITY REPORT DEATH OF RESIDENTS WHICH OCCUR IN HOSPITALS TO THE NHSN’S LTCF COVID-19 MODULE?
Yes, the LTCF COVID-19 Module does include reporting of deaths in another location. This is clarified in the COVID-19 module instructions that facilities will use when reporting on resident impact and facility capacity. Reporting COVID-19 Activity to Residents, Their Representatives, and Families.
MUST THE FACILITY NOTIFY ALL RESIDENTS, REPRESENTATIVES, AND FAMILIES, OR JUST THOSE AFFECTED?
Facilities must notify all residents in the facility, their representatives, and families, not just those who are suspected or confirmed cases of COVID-19. Notification must include data when a confirmed COVID-19 case is identified or when three or more residents or staff have new onset of respiratory symptoms that occur within 72 hours of each other in the facility. Cumulative updates must be provided when other confirmed cases or clusters of three or more residents or staff with respiratory symptoms occur within 72 hours of each other, and at least weekly. We note that there are a variety of ways that facilities can meet this requirement, such as informing families and representatives through email listservs, website postings, and/or recorded telephone messages. We do not expect facilities to make individual telephone calls to each resident’s family or responsible party to inform them that a resident in the facility has laboratory-confirmed COVID-19. However, we expect facilities to make all reasonable efforts to properly inform residents, their representatives, and families of the information facilities are required to provide.
WHAT INFORMATION IS REQUIRED TO BE REPORTED TO RESIDENTS, THEIR REPRESENTATIVES, AND FAMILIES? WILL THIS INFORMATION INCLUDE NEW CASES AS WELL AS TOTAL CASES?
Cumulative, confirmed COVID-19 cases as well as clusters of three or more residents or staff with respiratory symptoms within 72 hours must be reported. The facility is not required to identify new versus total cases.
CAN YOU CLARIFY WHAT SYMPTOMS CMS IS REFERRING TO IN THE REQUIREMENT TO REPORT IF THREE OR MORE RESIDENTS OR STAFF HAVE RESPIRATORY SYMPTOMS WITHIN 72 HOURS OF EACH OTHER?
Respiratory symptoms consistent with COVID-19 are shortness of breath, difficulty breathing, new or change in cough, sore throat, or new loss of taste or smell. To a lesser extent, symptoms have included new sputum production, rhinorrhea, or hemoptysis. For more information on updated symptoms, please view CDC’s webpages: Symptoms of Coronavirus and Preparing for COVID-19: Long-term Care Facilities, Nursing Homes.
MUST THE FACILITY REPORT ANY SUSPECTED CASE OF COVID-19 OF A RESIDENT OR STAFF MEMBER TO RESIDENTS, THEIR REPRESENTATIVES, AND FAMILIES?
No. The regulation does not require facilities to report to residents, their representatives, and families every suspected case of COVID-19 in residents and staff of the facility. However, it does require facilities to report suspected cases when three or more occur within 72 hours of each other.
FOR DEDICATED COVID-19 FACILITIES AND THOSE WITH COVID-19 UNITS, MUST THEY INFORM RESIDENTS, THEIR REPRESENTATIVES, AND FAMILIES EACH TIME A NEW RESIDENT WITH CONFIRMED COVID-19 IS ADMITTED OR STAFF MEMBER TESTS POSITIVE? SIMILARLY, WHAT IS THE TIME FRAME FOR NOTIFYING RESIDENTS, THEIR REPRESENTATIVES, AND FAMILIES FOR SUBSEQUENT COVID-19 ACTIVITY?
Yes. The facility must provide any cumulative updates for residents, their representatives, and families. Updates must occur at least weekly or by 5 PM the next calendar day following the subsequent occurrence of either: a confirmed infection of COVID-19 is identified (including new admissions), or whenever three or more residents or staff with new onset of respiratory symptoms occur within 72 hours of each other.
WHO ARE CONSIDERED “STAFF” FOR PURPOSES OF REPORTING CONFIRMED CASES OR CLUSTERS OF RESPIRATORY SYMPTOMS TO RESIDENTS, THEIR REPRESENTATIVES, AND FAMILIES?
“Staff” include employees, consultants, contractors, volunteers, and caregivers who provide care and services to residents in the facility, including nurse aides that have not yet completed a nurse aide training, competency, and evaluation program (NATCEP) but are providing services to residents.
WHEN INFORMING RESIDENTS, THEIR REPRESENTATIVES, AND FAMILIES OF SUSPECTED AND CONFIRMED COVID-19 CASES IN THE FACILITY, DOES THE FACILITY HAVE TO SPECIFY WHETHER INDIVIDUAL CASES ARE RESIDENTS OR STAFF?
No. CMS does not require this.
DO FACILITIES NEED TO INFORM ANYONE WHO WALKS THROUGH THEIR DOORS (E.G., A HOSPICE OR OTHER HEALTHCARE PROVIDER) OF THE SAME NUMBERS OF SUSPECTED AND CONFIRMED COVID-19 CASES THAT THEY ARE SHARING WITH RESIDENTS, THEIR REPRESENTATIVES, AND FAMILIES?
No. Facilities are not required to provide the same COVID-19 information reported to residents, their representatives, and families. However, facilities would share with the visiting healthcare provider, if the resident receiving care is suspected of, or has laboratory confirmed COVID-19. Any precautions the provider should take while in the facility (e.g., specific personal protective equipment) will be communicated to that provider by the facility as part of their standard practices under the infection prevention and control program requirement.
WHAT IF A FACILITY HAS NEVER HAD A SUSPECTED OR CONFIRMED COVID-19 CASE? IS THE FACILITY REQUIRED TO INFORM ALL RESIDENTS, THEIR REPRESENTATIVES, AND FAMILIES?
No. CMS does not require this however, we encourage facilities to transparently communicate regularly with residents, their representatives, and families about the status of the facility.
WHAT IF A FACILITY HAS THREE OR MORE RESIDENTS OR STAFF WITH NEW ONSET OF RESPIRATORY SYMPTOMS BUT NOT WITHIN 72 HOURS OF EACH OTHER? DOES THE FACILITY STILL NEED TO REPORT THIS TO ALL RESIDENTS, THEIR REPRESENTATIVES, AND FAMILIES?
No. CMS does not require this.
DOES THE REPORTING REQUIREMENT AT 42 CFR §483.80(G)(3)(I)-(III) (F885) FULFILL THE REQUIREMENT AT §483.10(G)(14)(I)(B), NOTIFICATION OF CHANGES (F580)?
No. The new reporting requirement at §483.80(g)(3)(i)-(iii) (F885) requires facilities to notify residents, their representatives, and families of cumulative numbers of confirmed COVID-19 cases and clusters of three or more residents or staff with respiratory symptoms within 72 hours of each other. By way of comparison, §483.10(g)(14)(i)(B) requires nursing homes to notify the resident, the resident’s physician and as applicable, the resident’s representative(s) of an individual resident’s change in condition (F580) if he/she is suspected or confirmed to have COVID-19.