LeadingAge NY to Governor: Daily HERDS Is Unnecessary and Unproductive

(July 29, 2024) In a letter to Governor Hochul and Commissioner of Health James McDonald, LeadingAge NY again requested the elimination of the daily Health Electronic Response Data System (HERDS) reporting that has been required of nursing homes and adult care facilities (ACFs) since the beginning of the pandemic. The letter emphasized that the Centers for Disease Control and Prevention (CDC) has concluded that COVID-19 “is no longer the emergency that it once was, and its health impacts increasingly resemble those of other respiratory viral illnesses.” Accordingly, this daily 19-question survey no longer serves the goals it once did and instead diverts precious resources from critical resident care needs.

The letter explained that the elimination of the daily HERDS report would not affect the State’s ability to conduct epidemiological surveillance or respond to outbreaks. The HERDS report is largely duplicative of other, more reliable data sources. Moreover, the survey instrument has not kept pace with changes in the public health response to the virus, and flaws in its questions have resulted in the collection of irrelevant and unreliable data.

The defects in the survey instrument are most striking with regard to its vaccination questions. Both the nursing home and ACF daily surveys ask seven questions regarding vaccination, and yet the data collected does not reveal how many residents are “up to date” with their COVID-19 vaccinations. Further, due to a lack of clarity in the wording of the questions and instructions, the data likely does not provide the information the Department of Health (DOH) believes it is collecting.

LeadingAge NY recommended the following:

• Immediate elimination of the daily HERDS survey for nursing homes and ACFs.
• Use of COVID-19 data reported elsewhere (i.e., nursing home data reported to the CDC's National Healthcare Safety Network (NHSN) system and DOH's Bureau of Healthcare Associated Infections (BHAI) and ACF reports of infections to local health departments) to inform State policy and public health responses to COVID-19.
• To the extent that data regarding new COVID-19 infections is needed, in addition to what is already reported to local health departments and the BHAI, DOH could establish a reporting mechanism for nursing homes and ACFs for that limited purpose.

LeadingAge NY will notify members of any responses to these recommendations.

Contact: Karen Lipson, klipson@leadingageny.org, or Diane Darbyshire, ddarbyshire@leadingageny.org