Out with the Old and In with the New: CDC Issues New Testing Guidance for Nursing Homes

In a sure sign that the COVID-19 pandemic is far from over at least for nursing homes and other long-term care facilities, the U.S. Centers for Disease Control and Prevention (“CDC”) published revised guidance for testing nursing home residents and staff.  CDC also updated its general overview of testing for SARS-CoV-2 (the “coronavirus”).

While the CDC’s nursing home testing guidance generally tracks the testing portion of the Centers for Medicare and Medicaid Services (“CMS”) memorandum regarding nursing home reopening recommendations, it also provides some much needed details and context for CMS’s recommendations and provides alternative recommendations for situations in which viral testing capacity is limited.

As a preface to its guidance, CDC stresses that rapid-results testing for the coronavirus is an important tool, together with infection prevention and control measures, to maximize prevention, detection and mitigation efforts by nursing homes.  Accordingly, the agency urges providers to develop a plan for testing both residents and staff.  Also, in keeping with previous guidance on the issue of testing, CDC states that antibody testing should generally not be used as the sole basis to diagnose infection or inform infection prevention and control action.  Rather, viral nucleic acid or antigen testing should be used.  Further, CDC does not recommend testing the same individual more than once in a 24-hour period, though it does not provide a rationale for the recommendation.

CDC breaks down its guidance into three main categories:  (1) viral testing of health care personnel, (2) viral testing of residents, and (3) viral testing in response to an outbreak.

Health Care Personnel Testing – In addition to reiterating existing recommendations for screening health care personnel (including contract staff, other healthcare staff in the facility, and volunteers) at the beginning of each shift by performing temperature checks and asking about symptoms, CDC recommends performing initial testing of all such personnel, with weekly testing thereafter.  CDC states that the schedule for testing may be adjusted by state and local officials depending on the prevalence of the virus in the broader community.  The agency also suggests that providers have a plan for contact tracing and meeting staffing needs should healthcare personnel test positive.

Resident Testing – Residents should be screened with temperature checks and questions about symptoms at least daily, and those residents who are not known to have previously been diagnosed with COVID-19 should be tested.  In addition, CDC recommends that clinicians consider testing residents for other causes of respiratory illness, such as influenza.  Again, just as with healthcare personnel, CDC recommends that providers develop a plan for contact tracing in the event that a resident tests positive for coronavirus.

Testing in Response to an Outbreak – CDC considers a single new case of coronavirus among health care personnel or a single nursing home-onset case among residents to constitute an outbreak.  In such situations, testing of all healthcare personnel and residents is recommended to identify infected individuals quickly and allow rapid implementation of infection prevention and control measures.  CDC suggests that if viral testing capacity is limited, residents and healthcare personnel who are in close contact with the infected individual be tested first.  Testing should be repeated as follows:

• Residents – All residents that previously tested negative should be tested every three (3) to seven (7) days until at least 14 days have elapsed since the last positive result. Where testing capacity is limited, repeat testing should be performed on residents who leave and return to the facility or have known exposure to a case, such as where a resident’s roommate tests positive.
• Healthcare Personnel – All healthcare personnel that previously have tested negative should be tested every three (3) to seven (7) days until at least 14 days have elapsed since the last positive result. Where testing capacity is limited, repeat testing should be directed first to healthcare personnel who also work at other facilities where coronavirus cases have been identified.

As the reopening process continues to unfold in each state, nursing homes cannot become complacent in their approach to the pandemic.  Rather, they must remain vigilant and be prepared for what lies ahead, both in terms of planning and response as cases may spike in the broader community.  And as always, proper documentation in the form of assessments, policies and procedures, will play a critical role in demonstrating that a provider has undertaken reasonable efforts to plan for and respond to the pandemic.