Revised Definitions of “Up-to-Date” COVID Vaccinations & CMS Survey Guidance
The National Healthcare Safety Network (NHSN) has modified its definition of “up to date” for long-term care facilities submitting COVID-19 data. According to the NHSN, residents are now considered up to date with their COVID-19 vaccinations if they’ve gotten all recommended doses in their primary vaccine series, plus at least one booster dose, during the October 2021 – June 2022 surveillance period.
NHSN also considers those people who have recently received all recommended doses in the primary vaccine series but aren’t yet eligible for a booster to be up to date. However, a second booster for those who are eligible isn’t necessary to meet the revised definition.
This move is in contrast to the recent change by the Centers for Disease Control and Prevention (CDC) in its definition of “up to date” for both LTC residents and staff. CDC now says that individuals aged 50 and older—as well as those 6 months and older who are moderately or severely immunocompromised—should get a second booster four months or more after the first one to be considered up to date with their vaccinations. CDC made this move after it noticed a steady increase in COVID cases and related hospitalizations among individuals in this age group.
CMS also reduced survey frequency in keeping with the normal process for oversight of any Medicare requirement as well as in response to high rates of compliance in initial surveys. State Survey Agencies (SAs) and Accrediting Organizations (AOs) are no longer expected to perform these reviews on every survey. SAs and AOs are now only expected to conduct reviews of the staff vaccination requirement during initial and recertification surveys and in response to specific complaint allegations regarding non-compliance with the staff vaccination requirement.
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