CMS Updates Two Quality and Safety Oversight Memos

On March 10, the Center for Medicare and Medicaid Services (CMS) updated two quality and safety oversight memos to align more closely with the previously updated guidance from the Center for Disease Control and Prevention (CDC). 

QSO-20-28 and QSO-20-39 revisions replace the terms “vaccinated, fully-vaccinated, and unvaccinated” with “up-to-date.”  The change to “up-to-date” will require a shift in current testing and quarantine practices. Employees who are not up-to-date on vaccinations will have different standards for work restrictions if they have COVID infection or exposure. Residents who are up-to-date with vaccines have different quarantine recommendations than those who are not.

The first of two additional updates includes a recommendation to use antigen testing for those who had COVID-19 in the last 90-days to reduce the likelihood of a positive test. PCR tests will more often register a persistent positive than antigen tests. The second update clarifies that visitors who are positive for COVID or meet the criteria for quarantine may not enter the building until they satisfy the quarantine requirements for residents.

Nursing homes and assisted living communities are not required to ensure all staff and residents are boosted. The vaccine mandate covers staff and the requirement for an original vaccination series. However, tracking booster doses for staff and residents will mean less testing and quarantine for those up to date on vaccines. Individuals are considered up-to-date if they have all recommended vaccine doses, including boosters. Below are two examples for you to consider:

• A newly hired staff member received their first COVID vaccine the week employed. These staff are considered up-to-date because they are not yet eligible for a second dose. Once eligible, they either need to receive that dose or stop working until they receive the second dose.
• A staff member has two doses or a primary vaccine series and is eligible for a booster shot but has not yet had the booster. This staff member is not up-to-date on vaccinations. They may continue to work as the vaccine mandate does not cover boosters; however, they will be considered not up-to-date for testing and quarantine.

For questions concerning positive healthcare workers and returning to work, please contact Kari Everson.

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