A proposal by the federal government to expand the Skilled Nursing Facility Quality Reporting Program to include staff COVID-19 vaccination rates is being opposed by the nation’s second largest nursing home association. 

Jodi Eyigor

The Centers for Medicare & Medicaid Services should not adopt the additional measure for fiscal year 2023 as proposed, LeadingAge said in a comments submitted to the agency on Sunday. 

Under the proposal, SNFs would have to report staff COVID-19 vaccination rates to the Centers for Disease Control and Prevention National Healthcare Safety Network starting Oct. 1. Currently, staff vaccination reporting is voluntary.

Like other organizations, LeadingAge asked CMS to reconsider the timing and scope of any  parity adjustment to its new Patient Drive Payment Model. But the association went further in taking a stance against some proposed metrics.

The proposed COVID-19 vaccination coverage measure would require skilled nursing facilities to report worker vaccination rates to gauge “whether SNFs are taking steps to limit the spread of COVID-19 among their HCP, reduce the risk of transmission within their facilities and help sustain the ability of SNFs to continue serving their communities throughout the COVID-19 PHE and beyond.”

LeadingAge argued that adding this measure to the SNF Quality Reporting Program “mistakenly conflates the ability of a nursing home to overcome the independent, individual medical choices of its healthcare personnel with the ability of the nursing home to provide quality care to the residents living within.” 

“While we agree that COVID-19 vaccination rates could be useful for this purpose, one must consider that COVID-19 vaccination rates for both staff and residents are now posted on the nursing home site at data.cms.gov as a result of the new reporting requirements in interim final rule,” wrote Jodi Eyigor, LeadingAge’s director of nursing home quality and policy. 

“Adding a COVID-19 vaccination measure to the QRP for the stated purpose of transparency is not only duplicative and unnecessary, but could also be more confusing,” she added. 

The organization also noted Care Compare is updated only monthly, while quality measures are based on reporting periods. 

“As proposed, consumers viewing the COVID-19 vaccination QRP measure would be viewing average vaccination rates from the prior quarter, rather than the vaccination rates of residents and staff currently living and working in the nursing home,” the comment letter states. “This outdated data defeats the purpose as proposed by CMS.”