COVID-19 Update #267
Interim Final Rule on COVID-19 Vaccine Requirements for LTCF and ICFs-IID

Today, the Centers for Medicare & Medicaid Services (CMS) published an Interim Final Rule on COVID-19 Vaccine Requirements. This rule applies to residents, clients, and staff of Long Term Care (LTC) facilities and Intermediate Care Facilities for Individuals with Intellectual Disabilities (ICFs-IID). CMS also published a QSO memo to state survey agencies on how to operationalize this new requirement.

The rule is scheduled to go into effect on May 21, 2021, ten days from its publication for inspection in the federal register. 

This rule specifies that LTC facilities must develop and implement policies and procedures to: 

  • Educate all residents and staff about COVID-19 vaccines; 

  • Offer vaccination to all residents and staff; and 

  • Report to the CDC via NHSN certain data regarding vaccination status for residents and staff as well as any therapeutic treatments (e.g., monoclonal antibody) use. Note that this requires additional reporting via NHSN modules: reporting the Resident Therapeutics Pathway found on COVID-19 LTCF Module, as well as reporting via the Weekly HCP and Resident COVID-19 Vaccination Module. 

Additionally, ICF-IID facilities must educate all clients and staff about COVID-19 vaccines and offer vaccination to all clients and staff. Reporting is not required for ICFs-IID; however, CMS strongly encourages voluntary reporting. 
The comment period for this interim final rule closes July 12, 2021. CMS is also requesting feedback on the feasibility of implementing similar requirements in other long term care settings that accept Medicare or Medicaid payments, including assisted living.

We and our partners will provide further analysis and guidance on implementing this rule in the coming days. In the meantime, please see this FAQ document from the Maryland Department of Health about reporting vaccination data into CRISP for Nursing Homes. This will help answer some questions that you may have had, and direct you to the right people for other resources you may need. Please note that vaccine data reporting is NOT required for assisted living facilities.
National Skilled Nursing Care Week
The theme for National Skilled Nursing Care Week (NSNC​​W) 2021 is "Together Through the Seasons." NSNCW will take place May 9-15, 2021, and the theme​ will honor the collaborative commitment of skilled nursing care facilities and their staff in providing compassionate care to their residents during this unprecedented time. 
Over the past year, despite the challenges of the pandemic, skilled care centers and their staff have shown an incredible and steadfast commitment to providing quality care and ensuring the safety of their residents. 
NSNCW 2021 will focus on this collective effort and the amazing strength and dedication of those who work tirelessly every day to care for and protect frail, elderly, and disabled adults in long term care. With each new season comes new beginnings, new strategies, and new information. Together we will get through this and together we will begin to heal. 
The 2021 HFAM Conference “Together We Re-Imagine” will be held in person October 4 – 7, 2021 at the Maryland Live Hotel and Casino in Hanover, Maryland. Hundreds of long-term care leaders will connect, share best practices and discuss actionable insights on how we can reflect, reform, rebuild, and revolutionize quality care. You and your teams will not want to miss this opportunity as we come together again.

Visit the conference website to learn more and register.
Thank you to our current sponsors!
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