Mary Madison, RN, RAC-CT, CDP
Clinical Consultant – Briggs Healthcare
On September 29, 2020, “CMS announced an update to the methodology the agency employs to determine the rate of coronavirus disease 2019 (COVID-19) positivity in counties across the country. Counties with 20 or fewer tests over 14 days will now move to “green” in the color-coded system of assessing COVID-19 community prevalence. Counties with both fewer than 500 tests and fewer than 2,000 tests per 100,000 residents, and greater than 10 percent positivity over 14 days – which would have been “red” under the previous methodology – will move to “yellow.” This information is critical to nursing homes, which are required to test their staff for COVID-19 at a frequency based on the positivity rate of their respective counties.
Under guidance CMS issued on August 26, 2020, nursing homes must test staff at a frequency of once monthly if the facility’s county positivity rate is less than five percent. Staff testing frequency increases to once weekly if the county positivity rate is between five and 10 percent. Finally, testing frequency increases to twice weekly if the county positivity rate exceeds 10 percent.
CMS heard concerns from some governors of rural states that the frequency guidelines did not work well for some rural areas. They were concerned that some rural counties had seemingly high comparative positivity rates as a result of low amounts of testing, rather than actual positivity in the community. This resulted in a significant burden for nursing homes being required to conduct staff testing at a higher frequency than necessary. In response to these concerns, the Trump Administration acted swiftly and decisively, and implemented the change to the positivity rate calculation in order to accommodate rural counties. The new, resulting methodology reduces burden while still requiring facilities to conduct testing to at a frequency that can detect COVID-19 early to keep nursing home residents safe.
The requirement came on the heels of President Trump’s announcement that the Administration would offer point-of-care testing machines to America’s Medicare and Medicaid certified nursing homes – on the condition that they have secured a Clinical Laboratory Improvement Amendments waiver. The administration has also sent over $21 billion to nursing homes to facilitate testing and offset other costs.”
There has been no QSO memorandum issued by CMS regarding this testing/county positivity “updated methodology” nor is there any information regarding same on the CMS COVID-19 Nursing Home Data website. As of the morning of September 30th, this website displays overall data for week ending 9/13/2020 however there is an new Excel spreadsheet for county positivity dated September 28, 2020. The Test Positivity Classification now reads: Counties with test percent positivity <5.0% or with <20 tests in past 14 days: Green; test percent positivity 5.0%-10.0% or with <500 tests and <2000 tests/100k and >10% positivity over 14 days: Yellow; >10.0% and not meeting the criteria for “Green” or “Yellow”: Red. Test positivity is rounded to the nearest tenth of a percent before classifying. The Percent Positive and Tests in prior 14 days for this report is from Data from September 10-September 23. Additionally, you’ll find this note: During the week of Sept 14, 2020, the following updates were made to the county percent test positivity characterization methodology. In order to use a greater amount of data to calculate percent test positivity and improve the stability of values, the indicator was expanded to include 14 days of data instead of 7 days. Further, because there are instances where counties with high test positivity rates may reflect low testing levels rather than high levels of viral transmission, additional criteria were added to re-assign counties with low testing volume to lower nursing home staff testing tiers (i.e., communities with low levels of testing and high test positivity (>10%) are reassigned to either yellow or green testing tiers). Nursing homes may set their testing frequency based on the color-coded reassigned positivity classification.
This spreadsheet (9/28/2020) reflects the updated methodology referred to in the 1st paragraph of this blog.