The Office of the Inspector General (“OIG”) has released the last of three reports analyzing the impact of Covid-19 on nursing home residents and issuing recommendations to improve response and care in nursing homes during future infectious disease events. The reports were published as part of a three-part review of the impact of Covid-19 upon nursing home residents and staff and issued recommendations to the Centers for Medicare and Medicaid Services (“CMS”) to better protect seniors during future infectious disease outbreaks, emergencies, or other disruptions to the health care system.
The first report[1] in the series, issued in June 2021, found that two in five Medicare beneficiaries in nursing homes either had or likely had Covid-19 in 2020. Some Medicare beneficiaries in nursing homes seemed to be at greater risk than others. Specifically, Black beneficiaries, Hispanic beneficiaries, and Asian beneficiaries were more likely than White beneficiaries to have or likely have Covid-19. In addition, overall mortality for Medicare beneficiaries in nursing homes increased by almost one-third in 2020 from the 2019 level.
This second report,[2] issued in January 2023, focused on nursing homes themselves and scrutinized the extent to which nursing homes had residents who were diagnosed with Covid-19 or likely Covid-19 and the characteristics of nursing homes with extremely high infection rates. The third report,[3] released in February 2024, featured specific challenges nursing homes faced and the strategies they used to deal with them. In particular, the report identified:
- Nursing homes faced monumental and ongoing staffing challenges, including a significant loss of staff and substantial difficulties in hiring, training, and retaining new staff. Many nursing homes used outside staffing agencies to fill gaps, which had significant downsides.
- Nursing homes continued to struggle with costs, testing protocols, personal protective equipment (PPE) compliance, and vaccination rates after initial challenges were resolved.
- Nursing homes identified challenges with implementing effective infection control practices and opportunities for improvement.
In response to these challenges and the findings of OIG’s review, OIG recommends that CMS:
- Implement and expand upon its policies and programs to strengthen the nursing home workforce.
- Reassess nurse aide training and certification requirements.
- Update the nursing home requirements for infection control to incorporate lessons learned from the pandemic.
- Provide effective guidance and assistance to nursing homes on how to comply with updated infection control requirements.
- Facilitate sharing of strategies and information to help nursing homes overcome challenges and improve care.
CMS has not explicitly stated its concurrence or nonconcurrence for the five recommendations. While it is impossible to predict whether CMS will formally adopt any of the five recommendations, CMS did provide a formal response to OIG in late 2023 that provides some insight into the “give and take” between multiple agencies within the Department of Health and Human Services.
OIG’s review consisted of in-depth, structured interviews of nursing home administrators and other staff members from twenty-five nursing homes between December 2021 and July 2022. The nursing homes studied represent a diverse sample with respect to geographic location, size, profit status, and the prevalence of COVID-19 in a facility, among other characteristics.
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[1] The first report in the series is available at https://oig.hhs.gov/reports-and-publications/all-reports-and-publications/covid-19-had-a-devastating-impact-on-medicare-beneficiaries-in-nursing-homes-during-2020/.
[2] The second report in the series is available at https://oig.hhs.gov/reports-and-publications/all-reports-and-publications/more-than-a-thousand-nursing-homes-reached-infection-rates-of-75-percent-or-more-in-the-first-year-of-the-covid-19-pandemic-better-protections-are-needed-for-future-emergencies/.
[3] The third report in the series is available at https://oig.hhs.gov/reports-and-publications/all-reports-and-publications/lessons-learned-during-the-pandemic-can-help-improve-care-in-nursing-homes/.