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09/04/2020

Testing Questions Abound as Federal Guidance Contradicts State Testing

Testing Questions Abound as Federal
Guidance Contradicts State Testing

Today, LeadingAge Ohio staff has responded to numerous member inquiries related to testing, as the Centers for Medicare & Medicaid Services (CMS) Quality, Survey & Oversight (QSO) 20-38-NH took effect yesterday. The Interim Final Rule went into effect immediately, expanding the definition of ‘facility staff’ to be tested and requiring new testing intervals for nursing homes nationwide, depending on the prevalence of COVID-19 in the county they are located. The proscribed intervals are at odds with Ohio’s nursing home testing program, which has a goal of testing nursing home residents every 10 days, but to date, has only made it through a single round which took 28 days. The memo comes at a time when Ohio’s state lab capacity is stretched thin, and only beginning to feel the impact of the additional testing of schools and universities as they open classes.

Meanwhile, across Ohio, nursing homes are receiving their point of care testing devices from HHS with little guidance in terms of how to use them. The devices will be manufactured by BD or Quidel, and while they can be used to satisfy the requirements in the QSO memo, providers should familiarize themselves with the limitations of each device (life expectancy of the devices, specificity, etc.). Each requires providers to source supplies specific to their device, and only limited supplies are included with the devices upon delivery. LeadingAge has prepared Antigen Testing A-Z as a tool for decision-making, accessing supplies, etc.

Yesterday morning, LeadingAge Ohio met with Administration officials and impressed upon them the stress and chaos caused by the incongruency between federal and state requirements. Administration officials understood the challenges, but has not yet provided guidance whether the state will end or significantly modify its nursing facility testing program to align CMS requirements. A webinar held today by the Congregate Care Unified Response Team (CCURT) was also silent on the QSO guidance. LeadingAge Ohio is meeting again with the Administration on this topic today, so look for further detail in today’s COVID-19 report.

At this time, LeadingAge Ohio offers the following recommendations to members, to be in compliance with the new federal rule:

Upon identification of a single new case of COVID-19 infection in any staff or residents, all staff and residents should be tested, and all staff and residents that tested negative should be retested every 3 days to 7 days until testing identifies no new cases of COVID-19 infection among staff or residents for a period of at least 14 days since the most recent positive result.

Facilities should use their county positivity rate in the prior week as the trigger for staff testing frequency. Reports of COVID-19 county-level positivity rates will be available on this website, see section titled, “COVID-19 Testing”.

CMS directs facilities that the frequency of testing is based on the community COVID-19 activity and County positivity rate in the past week as outlined below:

Low <5% Once a month (Ohio still requires every two week testing)

Medium 5% - 10% Once a week*

High >10% Twice a week*

*This frequency presumes availability of Point of Care testing on-site at the nursing home or where off-site testing turnaround time is <48 hours.

  • If the county positivity rate increases to a higher level of activity, the facility should begin testing staff at the frequency shown in the table above as soon as the criteria for the higher activity are met.
  • If the county positivity rate decreases to a lower level of activity, the facility should continue testing staff at the higher frequency level until the county positivity rate has remained at the lower activity level for at least two weeks before reducing testing frequency

For facilities that have received their antigen machine:

  • Identify the community activity and county positivity rate from the past week
  • Notify the local health department of the QSO memo and the need to test accordingly
  • Utilize the POC antigen device unless the facility chooses to use a different process that can meet the requirement
  • Send in a secured format staff specific results including negative results to the local health department/district
  • Identify remaining supply and notify local health department and EMA of subsequent testing supply need. Ensure that the state is notified of the supply need.
  • Reach out to contracted medical supply vendors to get in the queue to obtain supplies such as Mckesson and Medline
  • Reach out to the antigen machine supplier to identify ability to obtain supplies
  • Keep record of all communication

For facilities that have not received their antigen machine

  • Notify the local health department of the county positivity rate from the past week, confirm community activity, and that the facility has not received the antigen machine
  • Work with the local health department to obtain testing supplies and a lab to process
  • Identify if the local health department or local EMA will be requesting supply from the state
  • Call the facility’s lab that performs routine lab draws to identify their capability to provide swabs and run tests. (The lab may have the capability to perform the swabs for you as well).
  • Call the local hospitals to identify the ability to perform testing, provide supplies, and ability to run the tests
  • Inform the state of current testing issues by emailing CCURT@ODH.OHIO.GOV
  • Keep record of all communication

It is possible that local health departments will yet be unfamiliar with the QSO requirements when you call, but nonetheless, it is important that providers be able to document their compliance with the federal requirement.

CMS’ new rules further require, in accordance with the CARES Act, that laboratories – including nursing homes using point-of-care testing – report COVID-19 test results to state and local health departments. Test results include demographic data, such as race and ethnicity information. It is important that facilities using the POC machines report negative test results to their local health departments; a spreadsheet format is acceptable.

It is important for providers to recognize that details on testing are emerging in real-time, and LeadingAge Ohio will endeavor to provide its members with the most up-to-date information possible. Furthermore, LeadingAge Ohio would like to hear from members who have received their POC devises with insufficient supplies, missing part, or other concerns.

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Our national partner, LeadingAge, is an association of 6,000 not-for-profit organizations dedicated to expanding the world of possibilities for aging. Together, we advance policies, promote practices and conduct research that support, enable and empower people to live fully as they age.