CMS Issues Three (3) QSO Notifications Today Re: COVID-19

Mary Madison, RN, RAC-CT, CDP
Clinical Consultant – Briggs Healthcare

Today, CMS issued three (3) QSO notices regarding activities surrounding the COVID-19 status in the U.S.  Seema Verma (CMS) announced the posting of these notifications just minutes ago this afternoon during the COVID-19 Task Force’s afternoon briefing [FYI: these briefings have been televised nationally the past 3 days at 4:30pm (CT)]:

  • QSO-20-12-AllSuspension of Survey Activities

    CMS is committed to taking critical steps to ensure America’s health care facilities and clinical laboratories are prepared to respond to the threat of the COVID-19 and other respiratory illness. Specifically, CMS is suspending non-emergency inspections across the country, allowing inspectors to turn their focus on the most serious health and safety threatslike infectious diseases and abuse. This shift in approach will also allow inspectors to focus on addressing the spread of the coronavirus disease 2019 (COVID-19). CMS is issuing this memorandum to State Survey Agencies to provide important guidelines for the inspection process in situations in which a COVID-19 is suspected.

    Effective immediately, survey activity is limited to the following (in Priority Order):
    • All immediate jeopardy complaints (cases that represents a situation in which entity noncompliance has placed the health and safety of recipients in its care at risk for serious injury, serious harm, serious impairment or death or harm) and allegations of abuse and neglect;
    • Complaints alleging infection control concerns, including facilities with potential COVID-19 or other respiratory illnesses;
    • Statutorily required recertification surveys (Nursing Home, Home Health, Hospice, and ICF/IID facilities);
    • Any re-visits necessary to resolve current enforcement actions;
    • Initial certifications;
    • Surveys of facilities/hospitals that have a history of infection control deficiencies at the immediate jeopardy level in the last three years;
    • Surveys of facilities/hospitals/dialysis centers that have a history of infection control deficiencies at lower levels than immediate jeopardy.

    This is a 12-page notification with 2 important attachments:

    Attachment A- Survey Planning in Facilities with Active or Suspected Cases of COVID-19 Cases Attachment B- Infection Prevention, Control & Immunizations

    Attachment B (last 6 pages of this QSO) is CMS-20054…Infection Prevention, Control & Immunizations (Critical Element Pathway).

    It is VITAL that you review both attachments with your team ASAP.

 

  • QSO-20-14-NHGuidance for Infection Control and Prevention of Coronavirus Disease 2019 (COVID-19) in nursing homes

    This is another must-read 4-page notification.

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This notification provides guidance for limiting the transmission of COVID-19 for nursing homes:

    • How should facilities monitor or limit visitors?
    • How should facilities monitor or restrict health care facility staff?
    • When should nursing homes consider transferring a resident with suspected or confirmed infection with COVID-19 to a hospital?When should a nursing home accept a resident who was diagnosed with COVID-19 from a hospital?
    • Other considerations for facilities
    • What other resources are available for facilities to help improve infection control and prevention?

 

  • QSO-20-13-HospitalsGuidance for Infection Control and Prevention Concerning Coronavirus Disease (COVID-19): FAQs and Considerations for Patient Triage, Placement and Hospital Discharge
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This 6-page notification is geared towards hospital settings but is a must-read for, in my humble opinion, for post-acute partners of hospitals – long-term care facilities as well as home health agencies, assisted living facilities, etc.  This notification provides guidance for addressing patient triage and placement of patients with known or suspected COVID-19:

  • Which patients are at risk for severe disease for COVID-19?
  • How should facilities screen visitors and patients for COVID-19?
  • How should facilities monitor or restrict health care facility staff?
  • What are recommended infection prevention and control practices, including considerations for patient placement, when evaluating and care for a patient with known or suspected COVID-19?
  • Do all patients with known or suspected COVID-19 infection require hospitalization?
  • Are there specific considerations for patients requiring diagnostic or therapeutic interventions?
  • When is it safe to discontinue Transmission-based Precautions for hospitalized patients with COVID-19?
  • Can hospitals restrict visitation of patients?
  • What are the considerations for discharge to a subsequent care location for patients with COVID-19?
  • What are the implications of the Medicare Hospital Discharge Planning Regulations for Patients with COVID-19?
  • Can hospitals restrict visitation of patients?

All 3 QSO notifications contain hyperlinks to related, valuable resources for COVID-19 and the protection of the community at large as well as specific communities such as hospitals and nursing homes.

Again, please share all 3 CMS notifications with your team as soon as possible to protect everyone – patients/residents, staff, visitors, volunteers, etc.