In a January 13 letter, the Centers for Medicare & Medicaid Services (CMS) responded to LeadingAge’s ongoing advocacy around nursing home reporting requirements. LeadingAge has repeatedly called on CMS to address duplication created by concurrent reporting of resident vaccination status through both the National Healthcare Safety Network (NHSN) and the Minimum Data Set (MDS). CMS acknowledged the issue and maintained the importance of timely data such as that provided by NHSN reporting. CMS did not defend the importance of maintaining the MDS data reporting.

LeadingAge notes that the resident vaccination data collected through the MDS is currently utilized in the Skilled Nursing Facility (SNF) Quality Reporting Program (QRP). However, the SNF QRP utilizes data from NSHN for other measures. Revising the SNF QRP measure, COVID-19 Vaccine: Percent of Patients/Residents Who Are Up to Date, to utilize resident vaccination data reported through NHSN would eliminate the necessity of reporting this data on the MDS. As this measure is not currently endorsed by the consensus-based entity, it would appear that CMS could initiate this revision independently through notice and comment rulemaking. LeadingAge urges CMS not to neglect this issue and to take action to revise the SNF QRP measure and eliminate duplicative MDS reporting of resident vaccination status.