CMS State Survey Guidance under COVID-19

CMS has temporarily modified their state survey process during this COVID-19 emergency. This article describes these details.
March 24, 2020
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Below is important information regarding the State Survey results from Kirkland Nursing Home in Washington State, the epicenter of COVID-19 in the U.S., and the way in which CMS intends to utilize this information to alter the inspection process for at least the next 3 weeks.

CMS released their inspection report of Kirkland Nursing Home, which they are utilizing for their new targeted plan for healthcare facility inspections in response to COVID-19.

Inspectors found 3 immediate jeopardy situations, including:

• Facility failed to rapidly identify and manage ill residents

• Facility did not notify DOH about the increasing rate of respiratory infection among residents

• Facility failed to institute a sufficient back-up plan when their primary clinician fell ill and was absent

Based on this information CMS has created a targeted plan for inspecting nursing homes. President Trump’s emergency declaration allows CMS to diverge from normal practices.

CMS noted there are 147 nursing homes across 27 states with at least one resident with COVID-19. CMS and the CDC are collaborating and utilizing this information to determine where the virus may go next and for the performance of inspections. This type of targeting is in full effect immediately with CMS postponing all routine inspections at this time.

CMS will focus on only the following types of inspections during the next three-week time frame

• Complaint inspections triaged at Immediate Jeopardy. These will include the targeted infection control inspection regardless of the reason for the Immediate Jeopardy inspection.

• Targeted Infection Control inspections of facilities identified in collaboration with CMS and the CDC, and inspections will be both onsite and offsite

CMS has also noted providers are to perform self-assessments utilizing the ‘checklist’ provided to State Surveyors to perform inspections. The checklist is located at the end of a memorandum issued to the State Survey Agencies titled Prioritization of Survey Activities at Areas of focus include:

• Standard precautions – hand hygiene, PPE, and transmission-based precautions

• Resident care

• Infection Prevention and control

• Visitor entry

• Education, monitoring and screening of staff

• Emergency preparedness – staffing emergencies

It is noted the State Surveyor may request this document, or self-assessment, and it is encouraged to share the self-assessment results with state or local health departments’ Healthcare-Associated Infections (HAI) Program.

Long-term Care Providers are reminded they are to have a system in place to identify possible communicable diseases or infections. In addition, the health department should be notified if a resident has a severe respiratory infection or there is a cluster (> 3 residents) of respiratory illness. Note local and state reporting guidelines may vary so check with your local health department. The CDC website should also be monitored for information and resources to assist in preventing the spread of infection.

Please reach out if you need additional guidance or assistance. Trinity Rehab Services is here to assist our partners in moving forward.