IHCA/INCAL Summary of Revised CMS Testing Guidelines

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The Center for Clinical Standards and Quality Survey & Certification Group released revised guidelines for testing requirements for long-term care (LTC) facilities on September 23, 2022.

What do you want to know:

  • Routine testing of asymptomatic staff is no longer recommended but may be done at the facility’s discretion.
    • Review the facility’s policy for those with a health or religious waiver to determine if your facility’s policy requires more frequent testing regardless of the presence of COVID-19 symptoms.
  • Recommendations for testing people who have recovered from COVID-19 have been updated.
  • Read the memorandum including 483.80 Infection Control in QSO-20-38-NH Revised 9/23/22 here.

Screening of nursing home staff and residents

  • Facilities are required to test residents and staff for COVID-19 infection based on parameters and at a frequency set by the Secretary of HHS.
  • The definition of “establishment staff” is unchanged.
  • Facilities should prioritize individuals with signs and symptoms of COVID-19 infection first, and then conduct testing triggered by an outbreak investigation, as outlined:
  • Ask facility staff, regardless of their vaccination status, to report any of the following criteria to occupational health or another point of contact designated by the facility so that it can be managed responsibly :
  • A positive viral test for SARS-CoV-2,
  • Symptoms of COVID-19, or
  • A higher risk exposure to someone infected with SARS CoV-2

Definitions

“High-risk exposure” refers to exposure of an individual’s eyes, nose, or mouth to material potentially containing SARS-CoV-2, particularly if present in the room for a procedure generating aerosols 3 . This can happen when staff do not wear adequate personal protective equipment while caring for or interacting with a person.

“Close contact” refers to someone who has been within 6 feet of a COVID-19 positive person for a cumulative total of 15 minutes or more in a 24 hour period.

Screening of staff and residents with symptoms or signs of COVID-19

  • A symptomatic employee should be tested as soon as possible and restricted appropriately, regardless of their vaccination status.
  • If COVID-19 is confirmed, staff should follow CDC guidance – follow link: https://www.cdc.gov/coronavirus/2019-ncov/hcp/guidance-risk-assessment-hcp.html
  • Staff who do not test positive for COVID-19 but have symptoms should follow facility policies to determine when they can return to work.
  • A symptomatic resident, regardless of immunization status, should be tested as soon as possible and put on transmission-based precautions per CDC guidelines. Once the test results are obtained, the facility should take appropriate action based on the results. A word of warning: COVID-19 is not the only reason for signs and symptoms of infection and should be considered when the COVID-19 test is negative and especially when symptoms continue to manifest.

Screening of staff at higher risk and residents who have had close contact

  • In general, asymptomatic healthcare workers who have been at higher risk do not require work restrictions, regardless of their vaccination status, if they do not develop symptoms or test positive for SARS. -CoV-2.
  • Asymptomatic patients and healthcare professionals in close contact with someone infected with SARS-CoV-2 should undergo a series of three viral tests for SARS-CoV-2 infection. Testing is recommended immediately (but not earlier than 24 hours after exposure) and, if negative, again 48 hours after the first negative test and, if negative, again 48 hours after the second negative test . This will usually be day 1 (where the exposure day is day 0), day 3 and day 5.
  • Due to difficulties in interpreting the result, the test is not recommended for asymptomatic people who have recovered from SARS-CoV-2 infection within the previous 30 days. Testing should be considered for those who have recovered within the previous 31-90 days; however, antigen testing instead of NAAT is recommended. Indeed, some people may remain positive for NAAT but not be contagious during this time.

Screening staff and residents during an outbreak investigation

  • An outbreak investigation is initiated when a single new case of COVID-19 occurs among residents or staff to determine if others have been exposed.
  • An outbreak investigation is not triggered when a resident with known COVID-19 is admitted directly to the TBP or when a resident known to have close contact with someone with COVID-19 is admitted directly to the PTB and develops COVID-19 before PTB is discontinued.
  • Upon identification of a new case of COVID-19 infection in staff or residents, testing should begin immediately (not earlier than 24 hours after exposure, if known).
  • There are two options for a facility approach to outbreak testing – a contact tracing approach or widespread facility-wide testing.

Routine staff testing

  • Routine testing of asymptomatic staff is no longer recommended but may be done at the facility’s discretion.

Resident Screening – New Admissions

  • Facilities are directed to the CDC’s interim infection prevention and control recommendations for healthcare personnel during the coronavirus disease 2019 (COVID-19) pandemic under Management of admissions and residents leaving the establishment for testing information for residents newly admitted or readmitted to the facility and those leaving the facility for 24 hours or more.
    • Admissions in counties where levels of community transmission are high must be tested on admission (testing for admission to lower levels of community transmission is at the discretion of the facility).
    • Testing is recommended on admission and, if negative, again 48 hours after the first negative test and, if negative, again 48 hours after the second negative test.
    • They should also be advised to carry out a source check for 10 days after admission.
    • Residents leaving the facility for 24 hours or more should be managed as an admission.

Test refusal

  • Institutions should have procedures in place to address staff who refuse testing. Procedures should ensure that staff who show symptoms and refuse testing are not permitted to enter the building until the return to work criteria are met.
  • When a outbreak test is in progress and a staff member refuses to do so, the person should not enter the building until the outbreak test is complete.
  • Residents can exercise their right to decline COVID-19 testing.
  • Facilities must have procedures in place to deal with residents who refuse testing and are managed in accordance with CDC guidelines for the use of transmission-based precautions.

other considerations

  • Testing is not necessary for asymptomatic people who have recovered from SARS-CoV-2 infection in previous years. 30 days.
  • Testing should be considered for those who have recovered in the past 31-90 days.
    • If testing is done, the use of an antigen test instead of a nucleic acid amplification test (NAAT) is recommended.

Please contact Lori Davenport, Director of Regulatory and Clinical Affairs at [email protected] with any questions.

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