AFL 20-43.2 From the California Department of Public Health
May 13, 2020
TO: Skilled Nursing Facilities (SNFs)
SUBJECT: SNF Coronavirus Disease 2019 (COVID-19) Daily Reporting
(This AFL supersedes AFL 20-43.1)
AUTHORITY: Title 42 Code of Federal Regulations (CFR) section 483.80
Proclamation of Emergency (PDF)
All Facilities Letter (AFL) Summary
- This AFL requires all SNFs to report daily COVID-19 facility data to the California Department of Public Health (CDPH) via an online survey. This reporting is to ensure that California has the information necessary to respond to the COVID-19 outbreak and to provide resources and support to SNFs.
- This AFL has been updated to reflect the Centers for Medicare and Medicaid Services (CMS) new interim final rule; effective May 8, 2020, SNFs must:
- Report COVID-19 data to the Centers for Disease Control and Prevention (CDC); CDPH will report this information on behalf of facilities through the SNF COVID-19 Survey. Facilities must first enroll in the CDC’s National Health Safety Network (NHSN) system and then confer rights to CDPH.
- Notify residents, residents’ representatives, and families of residents of confirmed or suspected COVID–19 cases in the facility among residents and staff.
On May 8, 2020, CMS published an interim final rule requiring SNFs to report COVID-19 facility data to the CDC and to notify residents, residents’ representatives, and families of residents of when there are COVID-19 positive residents or healthcare workers in the facility. The report must include, but is not limited to, the following:
- Suspected and confirmed COVID-19 infections among residents and staff, including residents previously treated for COVID-19
- Total deaths and COVID-19 deaths among residents and staff
- Personal protective equipment (PPE) and hand hygiene supplies in the facility
- Ventilator capacity and supplies in the facility
- Resident beds and census
- Access to COVID-19 testing while the resident is in the facility
- Staff shortages
- Other information specified by the Secretary
CDPH will report this data on behalf of facilities via the online SNF COVID-19 Survey.
For CDPH to submit data to NHSN, SNFs must first enroll in NHSN and then confer rights to the NHSN CDPH group to upload data on their behalf, accept that the rights for their data are viewable to CDPH, and not grant rights to groups other than CDPH to upload COVID-19 data on their behalf. Facilities will need to enroll in NHSN by no later than May 17, 2020 and confer rights to CDPH by no later than May 22, 2020.
Beginning May 14, 2020, SNFs must report to CDPH via the SNF COVID-19 Survey by no later than 12:00 P.M. Pacific Time daily. To ensure consistent reporting across the state, CDPH is including a data dictionary (PDF). SNFs are encouraged to review the data dictionary (PDF) in its entirety before inputting data into the COVID-19 Survey.
Enrolling in NHSN
The instructions below provide an overview of how to enroll in NHSN. For full details on how to enroll, please refer to the NHSN Long-Term Care Facility COVID-19 Module and Enrollment in Long-term Care Facility COVID-19 Module (PDF).
1. Prepare for NHSN Enrollment
- Review applicable training materials.
- Prepare your computer to interact with NHSN (e.g. change spam-blocker settings to allow emails from firstname.lastname@example.org and SAMS-NO-REPLY@cdc.gov).
2. Register the Facility with NHSN
- Review and accept the NHSN Rules of Behavior (after selecting Agree, you will be guided to the NHSN Registration page).
- Complete the NHSN Registration Form.
3. Register with the Security Access Management System (SAMS)
- Open the “Invitation to Register with SAMS” email; open the link provided in the email to begin the SAMS registration.
- Accept the SAMS Rules of Behavior.
- Complete SAMS Registration page.
4. Complete NHSN Enrollment
- Login to the SAMS website using the username and password created in the SAMS Registration page.
- Complete the NHSN LTC Enrollment.
5. Accept the NHSN Agreement to Participate and Consent
- After receiving an email from NHSN, login to the SAMS website.
- Review and accept the NHSN Agreement to Participate and Consent.
After successfully enrolling in NHSN, the facility must confer rights to the NHSN CDPH group so that CPDH can report on behalf of the facility. CDPH will send facilities an email invite to join the NHSN-CDPH Group with instructions on how to confer rights to CDPH. Once you confer rights to CDPH, CDPH can start uploading your CDPH SNF COVID-19 Survey data to NHSN and you will not need to report COVID-19 data directly to NHSN.
Accessing the CDPH SNF COVID-19 Survey
To access the survey, follow the instructions below:
If you are completing this survey from a web browser:
- Go to the SNF COVID-19 Survey to launch the survey (Google Chrome is recommended; it does not work in Internet Explorer).
- Start to type your Skilled Nursing Facility and select from the drop down to auto populate facility specific information and continue to fill out the remaining questions.
Note:Some questions are conditional and will appear based on your answers, so please try to answer accurately.
If you will be completing this survey from the Survey123 field application on a mobile device:
- Ensure that you have downloaded Survey123 from your mobile device’s App Store
- From the device you will be using to fill out the form, go to SNF COVID-19 Survey.
- On the landing page, select “Open in the Survey123 field app”
- This will launch the Survey123 Application and automatically download the survey to your App
Note:The next time you want to fill this survey out, simply open your Survey123 App, select the previously downloaded Skilled Nursing Facility Survey form, and select “Collect.”
SNFs must report via the SNF COVID-19 Survey by no later than 12:00 P.M. Pacific Time daily. The first report will be for cumulative data from January 1, 2020 to May 14, 2020. Subsequent daily reporting will be for new incidents from the last reporting date. Facilities should refer to the SNF COVID Dashboard to check on their reported cumulative counts.
Submissions of this reporting information will take the place of daily reporting to CDPH district offices and CMS/CDC, related to the information specified above. All other reporting requirements to CDPH district offices will continue using the standard reporting process. Please note, that even if you are already receiving assistance from the CDPH Healthcare Acquired Infection (HAI) Infection Control strike teams, you must still fill out this survey daily.
Information from this survey will be shared with the local public health office emergency teams so we can work collaboratively with facilities to quickly find solutions; however, facilities should still notify their local Medical Health Operational Area Coordinator (MHOAC) for PPE resource requests.
Notification to Residents, Residents’ Representatives, and Families of Residents
It is vitally important for facilities to notify residents, resident representatives, and family members when there are COVID-19 positive residents or healthcare workers in the facility to keep them informed of the conditions at the facility and to comply with new federal requirements. Pursuant to Title 42 CFR section 483.80, facilities must inform residents, their representatives, and families of those residing in facilities by 5 P.M. the next calendar day following the occurrence of either:
- A single confirmed infection of COVID-19, or
- Three or more residents or staff with new-onset of respiratory symptoms occurring within 72 hours of each other
This information must:
- Not include personally identifiable information
- Include information on mitigating actions implemented to prevent or reduce the risk of transmission, including if normal operations of the facility will be altered
- Include any cumulative updates for residents, their representatives, and families at least weekly or by 5 p.m. the next calendar day following the subsequent occurrence of either: each time a confirmed infection of COVID-19 is identified, or whenever three or more residents or staff with new onset of respiratory symptoms occur within 72 hours of each other
This notification will provide an opportunity to inform families of the safety measures your facility is taking to protect their loved ones. Constant communication and transparent information are useful tools for all facilities to use with their healthcare worker staff, residents, and community.
Failure to Report
Failure to report resident or staff incidences of communicable disease or infection, including confirmed COVID-19 cases (or Persons Under Investigation for COVID-19), or provide timely notification to residents and their representatives of these incidences, as required, may result in a federal and/or separate state enforcement action.
CMS will provide facilities with an initial two-week grace period to begin reporting cases in the NHSN system (which ends at 11:59 p.m. on May 24, 2020). Facilities that fail to begin reporting after the third week (by 11:59 p.m. on May 31st) will receive a warning letter reminding them to begin reporting the required information to CDC. For facilities that have not started reporting in the NHSN system by 11:59 p.m. on June 7th, ending the fourth week of reporting, CMS will impose a per day (PD) CMP of $1,000 for one day for the failure to report that week. For each subsequent week that the facility fails to submit the required report, the noncompliance will result in an additional one-day PD CMP imposed at an amount increased by $500. Facilities that fail to comply with the daily SNF reporting requirement may also be subject to a B citation.
CDPH will report to CMS on behalf of SNFs that comply with CDPH daily reporting requirements and that have conferred rights to the CDPH Group.
For the purposes of this AFL the following definitions apply:
- “COVID suspect” means, persons with symptoms of COVID-19 or persons who are asymptomatic that have been exposed to a lab-confirmed case of COVID-19.
- “COVID laboratory positive means, an individual who has at least one respiratory specimen that tested positive for the virus that causes COVID-19 by a CDC laboratory, state or local public health laboratory, or commercial laboratory using Food and Drug Administration (FDA)-validated COVID-19 nucleic acid amplification (NAA) test.
If you have any questions about this AFL, please contact COVID-19SNFSURVEY@cdph.ca.gov.
Original signed by Heidi W. Steinecker
Heidi W. Steinecker