‍COVID-19 Focused Survey for Nursing Homes

CMS recently updated its Infection Control Survey protocol to include the two new F-tags that address compliance with the new requirements of participation that became effective on May 8, 2020. Tag F884 addresses the new requirement to report certain COVID-related information to the Centers for Disease Control and Prevention’s (CDC) National Healthcare Safety Network at least weekly. Tag F885 addresses the requirement to notify residents and representatives/families about confirmed COVID-19 cases and the occurrence of three or more residents or staff with new onset of respiratory symptoms that occurred within 72 hours of each other. CMS continues to encourage all providers to use the survey protocol as an assessment tool to determine compliance with infection control requirements.

Access the survey tool on EVOLVE here.

Infection Control Assessment and Response (ICAR)

Also on May 8, 2020, the CDC released a more comprehensive Infection Prevention and Control Assessment Tool for Nursing Homes Preparing for COVID-19. The CDC tool tracks much of what is in the CMS tool, but is more detailed and includes additional recommended areas for review.

Access the ICAR tool on EVOLVE here.

Using the CMS & CDC Self-Assessments to Plan for Survey Scrutiny and Potential Litigation

Although the use of either tool is not required, it is highly recommended that, at a minimum, SNFs complete the CMS assessment tool and ideally complete the CDC ICAR in conjunction to help ensure compliance with the requirements and to identify areas where they may need to improve.

Given the likelihood of survey activity and lawsuits, SNFs should complete the assessment tools and any infection control program reviews under Quality Assurance privilege and consider completing the review under legal privilege.

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