CMS Staff Insights: Interview with Holly Norelli – May 20,2021

Regulation | May 20, 2021 | by Jill Schumann

Holly Norelli, LNHA, Deputy Director, Division of Nursing Homes at CMS, joined the May 20, 2021 LeadingAge Coronavirus Update Call.

Holly Norelli, Licensed Nursing Home Administrator, Deputy Director, Division of Nursing Homes at CMS, joined the May 20, 2021 LeadingAge Coronavirus Update Call. She responded to questions from Ruth Katz and from callers.

Q: Providers have been through the ringer this year and some of the paperwork and reporting requirements have seemed onerous. There are additional requirements in the Interim Final Rule – what is the thinking on this additional reporting?

A: First I want to acknowledge the burden you have all been through in this past year. When we at CMS think through reporting requirements, we consider the burden that will be placed on providers. We weigh that against the value and insights additional data might provide. We will use this data to give us an understanding of whether we are getting closer to reaching herd immunity and where the gaps may be.

Q: Are you hearing from nursing homes that some are still having challenges accessing immunizations for staff and residents now that the Long Term Care Partnership has ended?

A: Yes, we are hearing that challenges remain. Providers are asking how they are supposed to offer the vaccine when they can’t get access to it. We would expect documentation of their efforts to obtain the vaccine or access to vaccinations. But if facilities have done that and they have documentation we will not penalize them. We need to think about access in a variety of ways. Nursing homes are staffed 24/7/365 and people who work evenings and nights and weekends may have greater access issues in getting vaccinated.

Q: If people have specific questions, where can they get information?

A: CMS has several email addresses that you can use to ask questions of us. Here is the triage email address -

Q One of the challenges we are all concerned about is vaccine hesitancy. What are you doing to address that?

A: Early in the year we conducted Fireside Chats with Dr. Fleisher, QIOs, and others We learned from the wisdom of “vaccine converters” whom we convened in focus groups. We listened to their concerns and the stories of how they came to agree to the vaccine, and used that information in our communications. We continue to conduct weekly provider calls. There are also videos of the focus groups I just mentioned.

Q: Nursing homes have been reporting for a long time on resident flu shots and other types of vaccines. Why in this new requirement are we reporting on staff?

A: We know that vaccine hesitancy is higher among staff than residents. There was a need for us to understand vaccination rates across the country. When we see areas of concern, we can deploy QIOs and CDC/ local public health personnel to see whether there are access issues or what else might be helpful.

Q: Is it likely that the flu short reporting will extend to staff as well?

A: We typically only implement requirements when there appears to be a strong need and right now we are focused on COVID vaccines

Q: In the beginning of the rule, it says that CMS is considering similar reporting for other settings and there is an opportunity to comment. What are you looking for in the comments?

A: We will be using those insights to inform whether to extend the requirement into other settings. I would be happy to connect you with colleagues who are more focused on those other settings who can help to answer questions.

Q: You have a unique professional history as a practicing licensed nursing home administrator who has moved to CMS. Why did you decide to do that and what has it been like?

A: Sometimes it is difficult. I am a nursing home administrator and had not thought about making a switch. But when the opportunity arose, I saw it as a way for me to help CMS understand the impact of decisions and regulations on the provider community. I am a voice not only from a provider perspective, but also for residents. We all have the goal of providing quality care.

Q: We are always hopeful that we can move toward a regulatory approach that is more collaborative and less punitive. What are your thoughts?

A: That is a difficult issue. We need to look at the levers we have to influence the outcomes we all want to achieve. We ask whether what we are doing is working and moving us toward our goals. We would like to have more nursing home roundtables to talk about how we can move forward together in a positive way.

Q: There is a great deal of emphasis on education about COVID-19 and vaccinations in the new requirements (F887). Do we need to have an expert on staff?

A: Surveyors will not expect line staff to have deep expertise. We are looking at how many people are vaccinated in the facility. We want to see proof that everyone is given the information they need and the opportunity to be vaccinated. There are useful links in recent memo.

Q: Can a nursing home staff member offer a medical or religious objection to an employer who has made vaccination a condition of employment?

A: CMS does not require vaccination – only education and offering a vaccination. That question would best be answered from a legal perspective or in line with other guidelines.

Q: How often does education need to be provided to people who are vaccine hesitant?

A: You only have to prove that you have offered education once. Our focus is on people who have not been vaccinated and we want to see that the effort has been made.

Q: With point of care test reporting, why do we need to upload each result even if it is negative?

A: This part of the mandate comes from the CLIAA office, not our office. I acknowledge that it is time consuming, and we are hoping that if we move to herd immunity, some of the regulations and reporting requirements will change.