Nursing Homes: Oppose Extension and Expansion of NHSN Reporting
(July 29, 2024) Nursing homes are encouraged to submit comments on the Centers for Medicare and Medicaid Services' (CMS) proposed regulation to make permanent the National Healthcare Safety Network (NHSN) weekly reporting and expand reporting requirements to additional respiratory viruses.
The proposed nursing home NHSN reporting expansion was included in the recent Medicare Home Health Payment Rule. It would extend NHSN reporting requirements (some of which are scheduled to sunset at the end of 2024) indefinitely, making them part of the federal Requirements of Participation for nursing homes. Additionally, the proposed regulation would expand the list of required elements to include data on influenza and respiratory syncytial virus (RSV). If adopted as proposed, starting in 2025, NHSN reporting for nursing homes would be expanded to include:
- resident vaccination status for respiratory illnesses including COVID-19, influenza, and RSV (and perhaps more);
- detailed breakdowns by vaccination status of confirmed resident cases of respiratory illness including COVID-19, influenza, and RSV (and perhaps more); and
- hospitalized residents with confirmed respiratory illness broken down by COVID-19, influenza, and RSV, and reported as overall numbers along with breakdowns by vaccination status.
Finally, the rule would also authorize CMS to require additional reporting in the future without following the typical notice and comment process should it be determined that a public health emergency due to an acute respiratory illness is occurring, or that there exists a significant threat of an occurrence.
While the collection of data on the health and immunization status of nursing home residents may sound appealing in concept, it is accompanied by the risk of citations and penalties, and in many cases, such as in NY, may be duplicative and/or inconsistent with data collected by state authorities. The link to the proposed Home Health Payment Rule is here. The nursing home reporting provisions are on page 114 of the PDF version.
Comments are due by 5 p.m. ET on Aug. 26th. LeadingAge National has prepared this resource for help developing and submitting your comments.
Members not commenting directly but interested in their thoughts being reflected in the comments submitted by LeadingAge NY are asked to share their comments with us by Aug. 19th.
A summary of the home health provisions of the proposed rule and resources for developing comments are available here.
Contact: Darius Kirstein, dkirstein@leadingageny.org, 518-867-8841