CMS Updates Guidance on Routine Testing of non 'up-to-date' staff members

Last week, CMS published an update to QSO-20-38-NH, the Long-Term Care (LTC) Facility Testing Requirements for Staff and Residents. Within this update, facilities are now required to test residents and staff, including individuals providing services under arrangement and volunteers, for COVID-19 based on community transmission rates set by federal CDC. In this most recent update CMS has replaced the term “vaccinated” with “Up-to-date with all recommended COVID-19 vaccine doses” and deleted the term “unvaccinated”. In addition, the update includes the recommendations for testing individuals within 90 days after recovering from COVID-19.
Included in this updated guidance was specific guidance on routine testing of staff, who are not up-to-date. By definition, “Up-to-Date” means a person has received all recommended COVID-19 vaccines, including any booster dose(s) when eligible. Routine testing frequency for those staff members who are NOT ‘up-to-date' should be based on community transmission or the extent of the virus in the community. This metric uses a two factor calculation:
  1. Total number of new cases per 100,000 persons within the last 7 days and;
  2. Percentage of positive diagnostic and screening nucleic acid amplification tests (NAAT) during the last 7 days.
Staff, who are up-to date, do not have to be routinely tested.
Facilities should use their community transmission level as the trigger for staff testing frequency. Reports of COVID-19 level of community transmission are available on the CDC COVID-19 Integrated County View site:

Please see the COVID-19 Testing section on the CMS COVID-19 Nursing Home Data webpage: for information on how to obtain current and historic levels of community transmission on the CDC website.

MHCA has inquired about the availability of HETL for processing routine testing samples of non 'up-to-date' staff persons as well as the compliance when lab turnaround time extends beyond 48hrs or POC testing methods are in short supply as indicated in the memo.

Staff Contact: