In January 2021, the Centers for Medicare & Medicaid Services (CMS) implemented a revised COVID-19 Focused Infection Control Survey for Acute and Continuing Care (ACC) for providers which included home health and hospice. This was the focused survey tool that surveyors would use for hospice and home health agency providers for any type of survey being conducted except a complaint survey where the complaint allegation is not related to infection control. At the same time, CMS clarified guidance for screening of individuals entering a health care facility which would include hospice inpatient units. See previous NAHC Report coverage here. Late on February 4, 2022 CMS revised the memo pertaining to the Focused Infection Control (FIC) survey tool and visitor screening.
CMS developed the FIC survey and tool at the beginning of the PHE to help surveyors and facilities absorb the critical infection prevention and control practices for combating COVID-19. CMS believes ACC facilities, including home health and hospice providers, have incorporated COVID-19 management strategies into their infrastructure and operations, and there is no longer a need to continue the required use of the special FIC survey and tool on a national basis. Therefore, CMS is rescinding the survey requirement to conduct FIC surveys.
State Survey Agencies (SAs) and Accrediting Organizations (AOs) should now return to the existing standard survey processes and continue to assess COVID-19 infection prevention and control elements by focusing on the regulatory requirements, while incorporating lessons learned about infection control oversight during the PHE. For example, the Medicare and Medicaid Programs; Omnibus COVID-19 Health Care Staff Vaccination Interim Final Rule guidance requires home health and hospice providers to develop and maintain approved policies and procedures for minimizing transmission of infectious disease that are established based on nationally recognized standards of practice. Surveyors will assess whether those polices are developed appropriately and followed.
While the contents of the FIC survey tool are generally still applicable, if providers wish to continue use of the tool as a template for their own self-assessment CMS encourages them to carefully review the Centers for Disease Control and Prevention (CDC) guidelines as there have been changes to the recommendations since the original tool and update were released (see the “Additional Resource Links” section in the memo linked above for more information on CDC guidelines).
Regarding visitation restrictions CMS stated it recognizes that restricting visitation from family and other loved ones during the COVID-19 pandemic has taken a physical and emotional toll on patients. While the COVID-19 Public Health Emergency (PHE) remains, CMS finds continued federal guidance on visitation restrictions for ACC providers are no longer necessary, which is consistent with the nursing home guidance in QSO-22-39. Facilities should continue to adhere to basic COVID-19 infection prevention principles consistent with national standards of practice.
Providers should note that there may be more prescriptive requirements at the State level for infection control and visitor screening and visitation restrictions. CMS expects health care staff and surveyors (AOs, contractors, Federal, State, and Local) to comply with basic infection control practices such as hand hygiene, wearing masks, and the use of other personal protective equipment, as appropriate for the situation (i.e., standard, contact, airborne, etc).
Surveyors should focus on the regulatory requirements for each provider and supplier type and whether the facility consistently follows processes that are based on national standards of practice. Guidelines produced by the CDC are an example of a source for national standards.
Any COVID-19 infection prevention policy developed by a health care facility to meet the Medicare conditions should be approved by the facility’s governing body, or equivalent group as defined by regulation, before implementation. Health care providers should review their own infection prevention and control policies and practices to prevent the spread of infectious disease and illness, including COVID-19.
Should COVID-19 case rates increase in certain geographic locations, CMS instructs that concerned SAs should strongly consider doing a FIC survey in consultation with the applicable CMS location office.