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SNF Regulations: Important Updates for Compliance

Laurie Laxton

Written by

Laurie Laxton, RN, BSN, CMAS, CCFA, RAC-CT, IP-BC, QCP

Principal Product Manager

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The skilled nursing facility (SNF) landscape is continually evolving, which underscores the need to stay abreast of current SNF regulations. In this three-part blog series, we’re providing highlights from AAPACN 2024 about important topics at the conference — including the latest updates related to SNF regulations.

In my presentation at AAPACN 2024, “Don’t Let Your Infection Control Program Live in Isolation,” I provided a comprehensive overview of the latest updates, guidelines, and regulations from the Centers for Disease Control and Prevention (CDC), Centers for Medicare & Medicaid Services (CMS), and CDC’s National Healthcare Safety Network (NHSN) — as well as the latest data around infection control in SNFs and how it has impacted elderly residents.

My first post, “AAPACN 2024: Hot Topics for Skilled Nursing Facilities,” covered two common themes that were important at the conference: infection surveillance and Enhanced Barrier Precautions (EBP).

In this second post of the series, we’ll discuss the latest SNF regulations from CDC and NHSN — as well as key findings of a recent report from the U.S. Department of Health and Human Services Office of Inspector General (OIG).

SNF regulations: CDC and NHSN updates

Over the past year, a number of important updates were issued by CDC and NHSN.

NHSN updates

OIG report January 2024 key findings:

  • CDC and nursing homes experienced many difficulties when over 12,000 facilities enrolled in NHSN during May 2020.
  • The addition of data variables which included personally identifiable information required upgrades to security access levels, presenting additional challenges.
  • 25% of nursing homes lacked confidence in the quality of NHSN data reported.

NHSN reporting updates:  

  • Reporting requirements for some variables will expire after December 2024, but reporting vaccination-related data will still be mandatory.
  • CDC will continue to support voluntary reporting of COVID-19 data and other infection and quality measures.
  • CDC is exploring the potential to leverage the current national enrollment of nursing homes for reporting on other health outcomes.
  • Contingency plans must be in place for staffing changes to ensure reporting deadlines are met.

NHSN: Regulatory updates and reporting requirements

NHSN issued several regulatory updates and offered new resources over the past year:

  • LTCF COVID-19 Module: Surveillance Pathway Updates issued in June 2023. Those responsible for submitting to the NHSN are well aware of these updates, including the removal of the mandatory COVID-19 surveillance pathway items being reported weekly.
    • Though federal requirements for vaccines have expired, a regulatory requirement is still in place regarding educating and offering the COVID-19 vaccine to staff and residents — as well as educating and offering residents the flu vaccine. For a summary of CMS vaccine regulations, see the #GetVaccinated toolkit from the American Health Care Association and National Center for Assisted Living.
  • LTCF COVID-19/Respiratory Pathogens Module. In October 2023, CDC released training for this new module in which long-term care facilities may voluntarily report influenza and respiratory syncytial virus (RSV) vaccinations for residents to help track the triple threat of respiratory viruses during the season. Once COVID-19 data is reported, the module will then allow RSV and influenza vaccination data to be uploaded.

In January, more updates were released and include the definition of “up-to-date” when it comes to vaccinations, the requirement for resident weekly reporting, and the staff one-week-per-month requirement for the remainder of 2024:

Additional NHSN mandatory reporting and related resources include:

Optional NHSN reporting

It can be challenging to find time to participate in optional NHSN reporting, which may include:

  • Influenza vaccine (residents) and cases
  • RSV vaccine (residents) and cases
  • Healthcare-associated infection (HAI) module for urinary tract infections (UTIs)
  • Lab-identified events for difficile and multidrug-resistant organisms (MDROs)
  • Prevention process measures: hand hygiene, gloves/gown adherence

In this context, the NHSN Annual Facility Survey is required for facilities that are currently or planning to report:

  • HAI (e.g. UTIs)
  • Lab-identified events for difficile or MDROs
  • Prevention process measures

The survey is due by March 1 each year, with leniency for late submissions. However, the survey is not required for facilities participating exclusively in the COVID-19 Module.

To learn more, access these NHSN Annual Facility Survey resources:

SNF regulations: CDC updates

CDC also issued several updates over the past year, including:

  • Respiratory guidelines: On March 1, 2024, CDC updated and simplified its respiratory virus recommendations. However, the updated guidelines do not affect healthcare facilities. CDC offers separate, specific guidance for healthcare settings related to COVID-19, influenza, and general infection prevention and control.
  • Guidelines on Prevention of Transmission of Pathogens in Healthcare Settings: At the end of 2023, CDC released draft guidelines that include three major sections: Overview of Transmission of Pathogens in Healthcare Settings; Fundamental Elements Needed to Prevent Transmission of Pathogens in Healthcare Settings; and Precautions to Prevent Transmission of Pathogens in Healthcare Settings.
  • Masking updates: As of May 8, 2023, updates to the Interim Infection Prevention and Control Recommendations for Healthcare Personnel During the Coronavirus Disease 2019 (COVID-19) Pandemic include updated recommendations for universal source control and admission testing in nursing homes — as well as an Appendix to assist facilities with how and when to implement broader use of source control.

In our next blog post, we’ll wrap up our three-part series by discussing additional updates to SNF regulations and other hot topics covered at AAPACN 2024.

To learn more about how the right technology can help your facility stay on track with the latest SNF regulations, visit our clinical solutions page for more information, and set up a demo.

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