On December 31, 2024, the Centers for Medicare & Medicaid Services (CMS) issued updated guidance on long-term care (LTC) Facility Acute Respiratory Illness Reporting Requirements. Effective January 1, 2025, LTC facilities are required to report data on COVID-19, influenza, and respiratory syncytial virus (RSV), including facility census, resident vaccination status, confirmed resident cases, and hospitalized cases by vaccination status. This new reporting requirement replaces the previous COVID-19 data reporting standards and is part of CMS’s broader effort to enhance respiratory illness surveillance. The data will need to be submitted to the CDC’s National Healthcare Safety Network (NHSN) in a standardized format and frequency.
These reporting requirements were finalized in the rule released on November 1, 2024, as part of the Calendar Year 2025 Home Health Prospective Payment System Rate Update. The NHSN Long-Term Care Facility COVID-19 Module is available and has been updated to include the new data elements that nursing homes must report. Facilities should immediately gain access to the NHSN system and visit the home page for important information, including how to register: https://www.cdc.gov/nhsn/.
CMS has indicated that surveyor guidance and enforcement actions related to these new requirements will be provided in the future. However, the effective date for the requirements remains January 1, 2025, and facilities should continue their usual reporting, including healthcare personnel COVID-19 vaccination status, until further surveyor guidance is released.
According to CMS, this updated guidance supersedes previous memos, but it does not change the effective date of the reporting requirements. The effective date is immediately, and facilities must communicate this information to all relevant staff within 30 days. For more information, providers are encouraged to contact DNH_TriageTeam@cms.hhs.gov.
You can view the CMS guidance here.
Compliance Perspective
Issue
CMS has updated the reporting requirements for nursing homes, effective January 1, 2025. These updates mandate that LTC facilities report data on COVID-19, influenza, RSV, and other respiratory illnesses, including facility census, resident vaccination status, confirmed cases, and hospitalizations. While the reporting is a continuation of prior data collection, it now expands to include more respiratory illnesses beyond COVID-19. LTC facilities must ensure that their policies, procedures, staff training, and auditing systems are aligned with these new requirements to maintain compliance and avoid penalties.
Discussion Points
- Review and update your facility’s policies and procedures to comply with the new reporting requirements set by CMS. Ensure that they address the expanded scope of respiratory illness reporting (including influenza and RSV), and outline the steps for accurate data collection and timely submission to the NHSN. Update policies to include how to track and report vaccination status and hospitalizations by vaccination status, and integrate these into your infection control and surveillance practices.
- Train all relevant staff members on the new CMS reporting requirements and ensure they understand how to collect and report data on COVID-19, influenza, and RSV, as well as how to use the NHSN system. Training should include the specific data elements to be reported and the standardized formats and frequencies required by CMS. Keep documentation of all training sessions, including dates, attendees, and materials covered. Reinforce the importance of accurate reporting to avoid compliance issues.
- Implement regular audits to verify that your facility is consistently meeting the new reporting requirements. This includes auditing the accuracy of respiratory illness data, vaccination records, and hospitalization information submitted to the NHSN. Audit the effectiveness of training programs to ensure that staff members are following updated procedures. Conduct periodic checks on your data reporting process to ensure timely submission and compliance, and address any discrepancies promptly.
*This news alert has been prepared by Med-Net Concepts, Inc. for informational purposes only and is not intended to provide legal advice.*
