Doctor and senior woman wearing facemasks during coronavirus and flu outbreak. Virus protection. COVID-2019. Taking on masks.

Providers worry they might not have enough time to fully comply with a mandatory flu vaccination reporting measure for workers if the Centers for Medicare & Medicaid Services moves forward as proposed.

CMS included the new requirement for the Quality Reporting Program under the Skilled Nursing Prospective Payment System proposed rule for fiscal 2023, which was released in early April. The measure was developed by the Centers for Disease Control and Prevention. It would require providers to report the percentage of healthcare personnel who received a flu vaccine anytime from the time it first became available through March 31 of the following year.

SNFs would have to submit data through CDC’s National Healthcare Safety Network. The initial data submission period would be from Oct. 1, 2022 through March 31, 2023. The submitted data also would be displayed on CMS’ Care Compare website. Under the SNF QRP, facilities that don’t meet reporting requirements may be subject to a 2% reduction in its annual rate update.

At a minimum, facilities would be required to submit vaccine status at the conclusion of the influenza season. But they also may submit flu vaccine status more frequently, such as monthly throughout the season to the NHSN data base, according to Jessie McGill, RN, curriculum development specialist, American Association of Post-Acute Care Nursing. 

AAPACN detailed its concerns during the rule’s comment period, which ended earlier this month. The group called for CMS to delay implementing the rule if the measure is advanced.

“Beginning data collection this October does not provide the facilities adequate time to establish tracking and reporting processes that would ease the burden of this measure,” McGill told McKnight’s Long-Term Care News on Friday. 

“Furthermore, facilities continue to face challenges with the ongoing COVID-19 PHE and simultaneous national nursing staffing crisis, which means any additional reporting burden uses resources that could instead be directed toward resident care,” she added in her emailed response. 

Caution required 

LeadingAge supports the adoption of the measure since flu vaccination is an important tool in protecting the health and wellbeing of residents and staff, a spokeswoman told McKnight’s on Friday. However, she urged CMS to be cautious in executing reporting requirements.

“As healthcare personnel influenza vaccination data is not currently reported by nursing homes, new processes will need to be implemented,” the spokeswoman noted. “CMS must provide ample notification to providers through varied methods of communication to ensure reporting of this measure.” 

Should CMS choose to enforce the flu vaccine reporting requirement, she said it’s crucial that reporting requirements align with the specifications outlined in this proposed rule. She also said that CMS should require reporting of flu vaccine data only once per season, rather than more frequent reporting, as is currently required of COVID-19 vaccination data. 

“We additionally caution CMS that enforcement of any requirement must follow a traditional citation route without automatic financial penalties, recalling that providers who fail to report this information will be penalized through the QRP construct,” the spokeswoman said.