Update on “Up to Date” Status

As you know, on May 19, the Centers for Disease Control & Prevention (CDC) released this statement strengthening COVID-19 booster recommendations. Included in this statement is the recommendation that all individuals aged 50 and older should receive a second booster. This strengthening of the recommendation from “may receive” to “should receive” has additionally resulted in a change to the definition of “up to date.” This change to the definition of “up to date” has many implications for nursing homes, including those outlined in this LeadingAge article.
 
We recently received an update on the timeline for the modifications that must be made in response to this change in definition.
 
NHSN Reporting
The definition for “up to date” in relation to the NHSN reporting will not be changed to include this new recommendation for those over 50 until at least June 26, 2022. See the attached guidance from NHSN.
 
Nursing Home Operations
CMS originally told LeadingAge that they understood that it would take nursing home some time to adjust and update their policies and procedures related to the operational issues affected by this May 19 definition change. LeadingAge is now advising us that nursing homes need to start working now on modifying their operations to reflect this definition change and should plan to expand their staff routine screening testing within a week or so to incorporate those 50 and over who are not “up to date.” I have confirmed this timeline with DPH FLIS and DPH HAI-AR has sent out this attached newsletter.

Operation issues impacted by this definition update include:
  • The rule requiring nursing homes to track and securely document the status of individuals receiving any boosters. This requirement would extend to second boosters.
  • The requirement under the COVID-19 Vaccine Immunization for Residents and Staff interim final rule released in May 2021 to educate residents and staff on the benefits of COVID-19 vaccination and to offer vaccination or assist in accessing vaccination as needed. Nursing homes should educate residents and staff on benefits of and eligibility for a second booster and assist residents and staff in accessing the second booster as needed, consistent with this rule.
  • Implications on use of source control for residents and staff, resident quarantine after admission and close contact exposure, staff work restriction after high-risk exposure, and staff routine screening testing based on community transmission rate. (If you are in need of test kits, please let me know.)