DHHS Adopts CMS COVID Testing Revisions (SNF/AL)  

 Yesterday, the Michigan Department of Health & Human Services (MDHHS) issued an Epidemic Order to update current long term care (LTC) COVID testing protocols. The new Order simply identifies content changes to the previous October 12, 2021 Epidemic Order.

Effective with the October 18, 2022, changes, LTC facilities – including Skilled Nursing Facilities (SNF) as well as Adult Foster Care (AFC) and Homes for the Aged (HFA) licensed to care for 13 or more individuals – are directed to follow the COVID testing requirements outlined in the Center for Medicare & Medicaid Services (CMS) Memo QSO-20-38-NH Revised 9/23/22. 

In addition, the new Epidemic Order removes several prior components, including:

♦️ Section 2(c) and its subsections:

(c) Facilities subject to this Order are responsible for requesting, obtaining, and maintaining a record of vaccination status for all residents and staff members, including:

    (1) A facility’s own electronic medical record system reflecting a resident’s receipt of vaccination dose(s); or

    (2) Michigan Care Improvement Registry (MCIR) or other official immunization record from a local health department, hospital, pharmacy, or health system (including individual doctor’s office) that includes the name, date of birth, medical record number, or other unique identifiers to link the record to the vaccinated resident or staff; or

    (3) A staff member’s presentation of a valid CDC vaccination card.

♦️ Section 2(d):

(d) Asymptomatic individuals who have recovered from COVID-19 in the past 3 months are exempted from testing so long as the Facility’s electronic medical records system contains documentation of the resident’s diagnosis, or the staff member has provided medical documentation of the diagnosis, a copy of which shall be maintained by the Facility for at least twelve months.

NOTE: Providers should now follow the revised QSO Memo which points to the Centers for Disease Control & Prevention (CDC) guidance to exempt an individual from testing for 30 days post active infection.

♦️ Section 2(g)(2) is revised to state: “Facilities must manage staff who decline testing when required in accordance with QSO-20-38-NH.”

These changes are effective immediately.