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GAO-23-104291, COVID-19 IN NURSING HOMES: Outbreak Duration Averaged 4 Weeks and Was Strongly Associated with Community Spread

Issuer
Government Accountability Office
Document type
Report
Date
2020-01-01

Summary

GAO-23-104291 is a Government Accountability Office report to congressional addressees dated December 15, 2022, on COVID-19 outbreaks in nursing homes. It examines how outbreaks affected nursing homes and which nursing home factors were associated with outbreak duration, using CDC and CMS data from June 2020 through December 2021 in a statistical model, a literature review and interviews in California, Florida, Maryland and Michigan. The report finds the average outbreak lasted 4 weeks and that community spread had the strongest association with outbreak duration. It states that, before vaccines, nursing homes in counties with low community spread had outbreaks ending an estimated 7 days earlier, and that 75 percent of outbreaks began with a reported staff case during the first week. Other factors it lists include nursing home size, reported staff shortages and ownership type.

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Full text

                United States Government Accountability Office
                Report to Congressional Addressees




                COVID-19 IN
December 2022




                NURSING HOMES

                Outbreak Duration
                Averaged 4 Weeks
                and Was Strongly
                Associated with
                Community Spread




GAO-23-104291
                                            December 2022

                                            COVID-19 IN NURSING HOMES
                                            Outbreak Duration Averaged 4 Weeks and Was
                                            Strongly Associated with Community Spread
Highlights of GAO-23-104291, a report to
congressional addressees




Why GAO Did This Study                      What GAO Found
The COVID-19 pandemic has had a             GAO analysis of data from the Centers for Disease Control and Prevention
disproportionate effect on the more         (CDC) shows that, from June 2020 through December 2021, nursing homes
than 1 million residents in the nation’s    faced many separate COVID-19 outbreaks, with the average outbreak lasting 4
nursing homes. The initial unknown          weeks. Officials GAO interviewed at six selected nursing homes in four states
nature of the virus and the scope of the    described a range of outbreak experiences, including critical challenges and
pandemic created unprecedented              some successes. For example, two critical challenges included:
challenges. The Department of Health
and Human Services, primarily through       •    Staff shortages. Officials from five nursing homes described experiencing
CMS and CDC, is responsible for                  staffing shortages during outbreaks. For example, officials from one nursing
taking steps to address COVID-19 in              home described a staffing crisis, noting that at one point the home was down
nursing homes, such as issuing                   about 25 percent of its workforce.
relevant requirements and guidance.         •    Low staff morale. Officials from three nursing homes discussed the
Many studies have explored the factors           psychosocial effect the pandemic had on their staff and the difficulties in
associated with the presence or                  maintaining staff morale. For example, officials from one nursing home
severity of COVID-19 in nursing                  described how the outbreaks took away the joy of caregiving from staff, and
homes. However, little was known                 officials believed that many staff were left traumatized.
about the factors associated with the
                                            GAO’s analysis of CDC and Centers for Medicare & Medicaid Services (CMS)
duration of COVID-19 outbreaks within
nursing homes.
                                            data found that transmission of COVID-19 in the community surrounding a
                                            nursing home, known as community spread, had the strongest association with
The CARES Act directs GAO to                the duration of an outbreak. Controlling for other factors, prior to the introduction
monitor the federal pandemic                of COVID-19 vaccines, nursing homes in counties experiencing low community
response. GAO was also asked to             spread had outbreaks that ended an estimated 7 days earlier than nursing
review CMS oversight of nursing             homes in counties experiencing high community spread. GAO also found that
homes in light of the pandemic. This        most outbreaks (75 percent) began with a reported staff case during the first
report examines how COVID-19                week. These results could indicate that, during times of higher community
outbreaks affected nursing homes, and       spread, staff have a greater likelihood of being exposed to the virus in the
determines how nursing home factors
                                            community and bringing it into the nursing home. Other factors GAO found that
were associated with outbreak
                                            had a strong association with outbreak duration included nursing home size,
duration.
                                            reported staff shortages, and ownership type.
GAO analyzed CDC and CMS nursing
home data from June 2020 through            GAO Estimated COVID-19 Outbreak Duration for Nursing Homes with Selected Characteristics
December 2021, in a statistical model,
and conducted a literature review.
GAO also interviewed representatives
from nursing homes and state
agencies from a non-generalizable
sample of four states. The states were
selected for variation in factors such as
number of nursing home beds and
COVID-19 cases.




View GAO-23-104291. For more information,   Note: Using multivariate statistical models, GAO estimated the association of nursing home factors,
contact John Dicken at (202) 512-7114 or    such as facility characteristics, with the likelihood that an ongoing COVID-19 outbreak would end
dickenj@gao.gov.                            during a given week.

                                                                                             United States Government Accountability Office
Contents


Letter                                                                                              1
                       Background                                                                   5
                       Nursing Home COVID-19 Outbreaks Lasted 4 Weeks on Average
                         and Selected Nursing Homes Described a Range of Outbreak
                         Experiences                                                              10
                       Transmission of COVID-19 in the Surrounding Community Had
                         the Strongest Association with Outbreak Duration in Nursing
                         Homes                                                                    17
                       Agency Comments                                                            23

Appendix I             Literature Review—Methodology Description and Results                      27



Appendix II            Detailed Description of Methodology for Multivariate Statistical
                       Models                                                                     44



Appendix III           Nursing Home Officials’ Descriptions of COVID-19 Outbreaks,
                       including Challenges and Successes                                         62



Appendix IV            GAO Contact and Staff Acknowledgments                                      64



Related GAO Products                                                                              65


Tables
                       Table 1: Nursing Home Officials’ Descriptions of COVID-19
                               Outbreaks                                                          13
                       Table 2: Studies Included in GAO’s Review That Focused on
                               Factors Associated with the Presence, Severity, or
                               Duration of COVID-19 Outbreaks in Nursing Homes,
                               January 1, 2020, through October 1, 2021                           29
                       Table 3: Nursing Home Facility Characteristics, Categorical
                               Variables, June 14, 2020, through January 2, 2022                  46
                       Table 4: Infection Prevention and Control Deficiencies Cited in
                               Nursing Homes, by Year, 2017 through 2021                          49



                       Page i                            GAO-23-104291 Nursing Home COVID-19 Outbreaks
          Table 5: Nursing Home Average Daily Staffing Levels, June 14,
                  2020, through January 2, 2022                                                     50
          Table 6: Reported Nursing Home Staff Shortages during the
                  COVID-19 Pandemic, June 14, 2020, through January 2,
                  2022                                                                              51
          Table 7: Nursing Home Resident Demographics, June 14, 2020,
                  through January 2, 2022                                                           52
          Table 8: Number of Weeks Counties Were Designated by CDC as
                  Having High, Substantial, Moderate, or Low Levels of
                  Community Transmission of COVID-19, June 14, 2020,
                  through January 2, 2022                                                           53
          Table 9: Multivariate Regression Results from Cox Proportional
                  Hazard Model, COVID-19 Outbreak Duration by
                  Vaccination Time Period, June 14, 2020, through January
                  2, 2022                                                                           57
          Table 10: Nursing Home Officials’ Descriptions of COVID-19
                  Outbreaks, including Challenges and Successes                                     62

Figures
          Figure 1: New Weekly Confirmed COVID-19 Cases and Deaths
                   among U.S. Nursing Home Residents and Staff, Weeks
                   Ending May 31, 2020, through October 2, 2022                                      9
          Figure 2: Duration of COVID-19 Outbreaks in Nursing Homes,
                   June 14, 2020, through January 2, 2022                                           11
          Figure 3: Average Duration of COVID-19 Outbreaks in Nursing
                   Homes by Month the Outbreak Began, June 14, 2020,
                   through January 2, 2022                                                          12


          Abbreviations

          CDC               Centers for Disease Control and Prevention
          CMS               Centers for Medicare & Medicaid Services
          HHS               Department of Health and Human Services


          This is a work of the U.S. government and is not subject to copyright protection in the
          United States. The published product may be reproduced and distributed in its entirety
          without further permission from GAO. However, because this work may contain
          copyrighted images or other material, permission from the copyright holder may be
          necessary if you wish to reproduce this material separately.




          Page ii                                 GAO-23-104291 Nursing Home COVID-19 Outbreaks
                       Letter




441 G St. N.W.
Washington, DC 20548




                       December 15, 2022

                       Congressional Addressees

                       COVID-19 emerged as a new and highly contagious respiratory disease
                       that has resulted in catastrophic loss of life. These devastating
                       consequences have been particularly pronounced for the nation’s more
                       than 1 million nursing home residents. A disproportionate share of all
                       COVID-19 deaths reported by the Centers for Disease Control and
                       Prevention (CDC) has been among nursing home residents. 1 The initial
                       unknown nature of the virus that causes COVID-19, along with the scope
                       of the pandemic, created unprecedented challenges for the state and
                       federal agencies working to ensure the quality of care delivered in the
                       more than 15,000 Medicare- and Medicaid-certified nursing homes. 2

                       Nursing home residents are at a high risk of infection and death due to
                       COVID-19, as older adults and those with underlying health conditions
                       are at higher risk of severe disease. 3 In addition, the congregate nature of
                       nursing homes, with staff caring for multiple residents and communal
                       spaces, increases the risk that COVID-19 will easily spread. The
                       introduction of COVID-19 vaccines in conjunction with improved infection
                       prevention and control practices coincided with a sharp decline in nursing


                       1Combined nursing home resident and staff deaths from COVID-19 consistently
                       represented about 30 percent of all COVID-19 deaths in the U.S. from May 2020 through
                       February 2021. In May 2021, this percentage declined to about 23 percent and further
                       decreased to about 16 percent in May 2022. See Centers for Disease Control and
                       Prevention, COVID Data Tracker, accessed September 7, 2022,
                       https://covid.cdc.gov/covid-data-tracker.
                       2Federal statutes and their implementing regulations use the terms “skilled nursing facility”
                       (Medicare) and “nursing facility” (Medicaid). For the purposes of this report, we use the
                       term “nursing home” to refer to both skilled nursing facilities and nursing facilities.

                       Medicare, the federal health insurance program for people age 65 and older, individuals
                       under age 65 with certain disabilities, and individuals diagnosed with end-stage renal
                       disease, covers some short-term skilled nursing and rehabilitative care for beneficiaries
                       following an acute care hospital stay. Medicaid, a joint federal-state health program for
                       certain low-income and medically needy individuals, is the nation’s primary payer of long-
                       term services and supports for children and adults with disabilities and aged individuals.
                       3Centers for Disease Control and Prevention, COVID-19: People Who Live in a Nursing
                       Home or Long-Term Care Facility, accessed January 5, 2021,
                       https://www.cdc.gov/coronavirus/2019-ncov/need-extra-precautions/people-in-nursing-ho
                       mes.html.




                       Page 1                                   GAO-23-104291 Nursing Home COVID-19 Outbreaks
home cases and deaths from their initial peaks in December 2020.
However, the emergence of more transmissible virus variants led to the
highest resident and staff case rates in nursing homes thus far in January
2022.

While there have been several studies exploring the factors associated
with the presence and severity of COVID-19 in nursing homes, little is
known about the factors that are associated with the duration of
outbreaks once the virus enters the home. 4

The CARES Act includes a provision directing us to monitor the federal
response to the COVID-19 pandemic. 5 Further, you asked us to examine
the Centers for Medicare & Medicaid Services’ (CMS) oversight of
infection prevention and control protocols and the adequacy of
emergency preparedness standards for emerging infectious diseases in
nursing homes, as well as CMS’s response to the pandemic. Since 2020,
we have examined multiple aspects of the response to COVID-19 in
nursing homes. Some reports are published while work on others is
ongoing. 6

This report (1) examines how COVID-19 outbreaks affected nursing
homes and (2) determines how certain nursing home factors were
associated with the duration of COVID-19 outbreaks.

To understand how COVID-19 outbreaks have affected nursing homes,
we analyzed CDC data on nursing home COVID-19 cases. To help inform
nursing home response efforts, CDC defines the start of a COVID-19

4Studies have found a range of factors, such as COVID-19 transmission in the
surrounding community, racial disparities, and staffing levels, that are associated with the
presence or severity of COVID-19 cases and deaths in nursing homes. See appendix I for
a list of such studies.
5Pub. L. No. 116-136, § 19010(b), 134 Stat. 281, 580 (2020). Throughout the pandemic,
we regularly issued government-wide reports on the federal response to COVID-19. All
government-wide reports are available on GAO’s website at
https://www.gao.gov/coronavirus.
6For example, see GAO, Infection Control Deficiencies Were Widespread and Persistent
in Nursing Homes Prior to COVID-19 Pandemic, GAO-20-576R (Washington, D.C.: May
20, 2020); COVID-19 in Nursing Homes: Most Homes Had Multiple Outbreaks and Weeks
of Sustained Transmission from May 2020 through January 2021, GAO-21-367
(Washington, D.C.: May 19, 2021); and COVID-19 in Nursing Homes: CMS Needs to
Continue to Strengthen Oversight of Infection Prevention and Control, GAO-22-105133
(Washington, D.C.: Sep. 14, 2022).




Page 2                                   GAO-23-104291 Nursing Home COVID-19 Outbreaks
outbreak as the week a nursing home reports a new COVID-19 case in a
resident or staff member and defines the end as when the nursing home
has 2 consecutive weeks where it reports no such cases. 7 Using this
definition of an outbreak, we first generated descriptive statistics,
including the number and duration of outbreaks each of the over 15,000
Medicare- and Medicaid-certified nursing homes experienced. We did not
include the 2 consecutive weeks without a new COVID-19 case when
calculating an outbreak’s duration.

In addition, we interviewed state officials and nursing home officials in a
non-generalizable sample of four states: California, Florida, Maryland,
and Michigan. These states were selected to provide variation across: (1)
geographic location; (2) number of nursing home beds; and (3) number of
nursing home residents and staff with confirmed positive cases of COVID-
19. 8 In each of these four states, we interviewed state survey agency and
state long-term care ombudsman officials, as well as officials from at least
one nursing home. 9 In total, we interviewed officials from six nursing
homes that we selected to obtain variation in factors such as bed count
and profit or not-for-profit status. 10 We asked nursing home officials to
describe how COVID-19 outbreaks affected their nursing home, as well
as to describe the challenges faced while preventing and managing
COVID-19 outbreaks.

Additionally, we interviewed researchers with work related to nursing
homes and COVID-19, as well as national associations with knowledge of
nursing homes issues. These associations included the American Health
Care Association and National Consumer Voice for Quality Long-Term


7See Centers for Disease Control and Prevention, Interim Infection Prevention and
Control Recommendations to Prevent SARS-CoV-2 Spread in Nursing Homes, accessed
April 18, 2022, https://www.cdc.gov/coronavirus/2019-ncov/hcp/long-term-care.html.
8Nursing home characteristics data were as of June 2020, and COVID-19 case rates were
as of November 1, 2020.
9CMS enters into agreements with survey agencies in each state (known as state survey
agencies) to monitor compliance with federal quality of care standards by conducting both
recurring comprehensive standard surveys (inspections) and as-needed investigations.

Under the federal Older Americans Act, every state is required to have an Ombudsman
Program that addresses complaints and advocates for improvements in the long-term care
system, including nursing homes, as a condition of receiving funds under the act.
10We conducted the original interviews from December 2020 through August 2021 and
followed up with officials at each state survey agency, state long-term care ombudsman,
and nursing home from November 2021 through March 2022.




Page 3                                  GAO-23-104291 Nursing Home COVID-19 Outbreaks
Care. We discussed with researchers and association representatives the
challenges faced by nursing homes during the pandemic.

To determine how certain nursing home factors were associated with the
duration of COVID-19 outbreaks, we analyzed CMS data on nursing
home staffing levels, resident demographics, and facility characteristics;
CDC data on county-level COVID-19 community transmission levels and
nursing home COVID-19 cases; and Health Resources and Services
Administration data on county-level metropolitan, micropolitan, and rural
designations. We developed multivariate statistical models to determine
the significance of each selected factor in estimating the probability of an
outbreak ending at any given week from June 14, 2020, through January
2, 2022 (the last full week of the 2021 calendar year).

Specifically, our statistical models controlled for the transmission levels of
COVID-19 in the surrounding community, several nursing home
characteristics, several measures of nursing home staffing levels, and
several other factors, including prior infection prevention and control
deficiencies. We could not control for all factors that may affect outbreak
duration, such as state and local COVID-19 policies, local compliance
with those policies, or nursing home adherence to infection prevention
and control practices. Therefore, our model provides information on
possible associations in the data and does not establish a causal
relationship between the factors and outbreak duration.

To provide context to these findings, we conducted a literature review to
determine what is known about the factors associated with COVID-19
outbreaks in nursing homes and identified 40 pertinent studies, which we
reviewed. For a description of our literature review methodology and its
findings, see appendix I.

We assessed the reliability of the various data sets we used by reviewing
relevant CDC, CMS, and Health Resources and Services Administration
data documentation, interviewing knowledgeable agency officials, and
performing tests of the data to identify any outliers or anomalies. We
determined that these datasets were sufficiently reliable for the purposes
of our reporting objectives. For additional information about our
descriptive and statistical analyses and model, see appendix II.

We conducted this performance audit from April 2020 to December 2022
in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our


Page 4                             GAO-23-104291 Nursing Home COVID-19 Outbreaks
             findings and conclusions based on our audit objectives. We believe that
             the evidence obtained provides a reasonable basis for our findings and
             conclusions based on our audit objectives.

             The Department of Health and Human Services (HHS), primarily through
Background   CMS and CDC, has led the response to the COVID-19 pandemic in
             nursing homes. CMS is the federal oversight agency responsible for
             ensuring that nursing homes meet federal quality standards to be eligible
             to participate in the Medicare and Medicaid programs. 11 CDC issues
             guidance with recommendations for preventing and managing infectious
             diseases and operates infectious disease surveillance systems. CDC also
             provides technical assistance through programs aimed at supporting and
             assessing infection prevention and control in nursing homes, and tracking
             infection prevention and control data. 12

             The COVID-19 pandemic has had a disproportionate effect on nursing
             home residents thus far. Nursing home residents are at a high risk of
             infection and death due to COVID-19, as older adults and those with
             underlying health conditions are at a higher risk of severe disease. In
             addition, the congregate nature of nursing homes increases the risk of
             transmission. 13 We have previously reported on a number of COVID-19
             issues in nursing homes, including challenges nursing homes have faced
             and the number and duration of outbreaks early in the pandemic. For
             example, our past work found that most nursing homes had multiple


             11To monitor compliance with these standards, CMS enters into agreements with survey
             agencies in each state to conduct recurring comprehensive standard surveys and as-
             needed investigations. Beginning in March 2020, CMS required state survey agencies to
             conduct focused infection control surveys, a new type of survey in response to the
             pandemic with a narrower scope than a standard survey, for 20 percent of nursing homes
             in their state annually, prioritizing those facilities that report new COVID-19 cases and low
             vaccination rates. If a state survey agency determines that a nursing home violated a
             federal standard, the nursing home is cited for the deficiency.
             12According to CDC officials, this includes developing resources to support
             implementation of prevention and surveillance activities, conducting and supporting onsite
             and remote infection prevention and control assessments, and supporting outbreak field
             investigations.
             13According to CDC, COVID-19 is spread in three main ways: (1) breathing in small
             droplets or particles exhaled by an infected person; (2) having these small droplets and
             particles land on the eyes, nose, or mouth, especially through a cough or a sneeze; and
             (3) touching eyes, nose, or mouth with hands that have the virus on them. See Centers for
             Disease Control and Prevention, How COVID-19 Spreads, accessed April 16, 2022,
             https://www.cdc.gov/coronavirus/2019-ncov/prevent-getting-sick/how-covid-spreads.html.




             Page 5                                   GAO-23-104291 Nursing Home COVID-19 Outbreaks
outbreaks and weeks of sustained COVID-19 transmission from May
2020 through January 2021. 14

Many studies have explored the factors associated with the presence or
severity of COVID-19 in nursing homes, finding a range of associated
factors, such as COVID-19 in the surrounding community, nursing home
size, and racial disparities. For example, several studies all found that
nursing homes with fewer beds were associated with less severe
outbreaks. 15

The duration of an outbreak within a nursing home is also important as it
may indicate how well a nursing home can control the spread of the virus,
as well as having implications related to staffing needs, space constraints,
and resident well-being. For example, CDC guidance recommends a
nursing home maintain dedicated space for residents with confirmed
infections during a COVID-19 outbreak, if possible. 16 This can require
additional nursing staff and strain a home’s available space and
resources. In addition, in March 2020, CMS released guidance restricting
visitation and suspending group dining and activities to prevent the
spread of the virus. Initially these restrictions were at all times; starting in
September 2020, visitation was restricted only during active COVID-19




14For challenges, see, for example, GAO, COVID-19: Urgent Actions Needed to Better
Ensure an Effective Federal Response, GAO-21-191 (Washington, D.C.: Nov. 30, 2020).
For number and duration of outbreaks, see GAO, COVID-19 in Nursing Homes: Most
Homes Had Multiple Outbreaks and Weeks of Sustained Transmission from May 2020
through January 2021, GAO-21-367 (Washington, D.C.: May 19, 2021).
15See appendix I. For example, Elizabeth M. White et al., “Variation in SARS-CoV-2
Prevalence in U.S. Skilled Nursing Facilities,” Journal of the American Geriatrics Society,
vol. 68, no. 10 (2020): 2167-2173, and Sheryl Zimmerman, et al., “Nontraditional Small
House Nursing Homes Have Fewer COVID-19 Cases and Deaths,” JAMDA, vol. 22, no. 3
(2021): 489-493.
16CDC guidance specifies that staff assigned to the COVID-19 unit only work in this unit
when it is in use and that, at a minimum, such staff include the primary nursing assistants
and nurses assigned to care for these residents. See Centers for Disease Control and
Prevention, Interim Infection Prevention and Control Recommendations to Prevent SARS-
CoV-2 Spread in Nursing Homes, accessed July 24, 2022,
https://www.cdc.gov/coronavirus/2019-ncov/hcp/long-term-care.html.




Page 6                                  GAO-23-104291 Nursing Home COVID-19 Outbreaks
outbreaks. 17 These restrictions had unintended consequences on
residents, such as isolation and declining health. 18 The longer a nursing
home is responding to a COVID-19 outbreak, the longer staff and
residents face these issues. However, we found that little was known
about the factors that contribute to the length of outbreaks once the virus
enters the home. 19

CMS has required that nursing homes report COVID-19 information
weekly to CDC, including resident and staff case and death counts, since
May 2020. 20 CDC data show that, for the week ending May 31, 2020,
through the end of 2020, there were fluctuations in new weekly confirmed
cases among residents and staff. The introduction of vaccines in nursing
homes at the end of December 2020, in conjunction with improved
infection prevention and control practices, was a key turning point when
cases and deaths began to decline. COVID-19 nursing home cases and
deaths remained low through the first part of 2021, but, from the summer
of 2021 through the end of that calendar year (coinciding with the
emergence of the COVID-19 Delta variant), nursing home cases began to
rise. Then, in January 2022 (coinciding with the emergence of the
COVID-19 Omicron variant), cases in residents and staff quickly jumped
to levels far exceeding the peak seen prior to the introduction of COVID-


17CMS initially restricted visitation and suspended group dining and activities in March
2020. After the initial restrictions, CMS changed its guidance multiple times—in
September 2020, March 2021, and April 2021—to allow for more visitation and group
activities, while identifying some situations where limitations would be appropriate. In
November 2021, all visitation limitations were fully lifted. See Centers for Medicare &
Medicaid Services, Guidance for Infection Control and Prevention of COVID-19 in Nursing
Homes, QSO-20-14-NH, (Baltimore, Md.: March 13, 2020) and Centers for Medicare &
Medicaid Services, Nursing Home Visitation – COVID-19, QSO-20-39-NH, (Baltimore,
Md.: Sept. 17, 2020), revised March 10, 2021, April 27, 2021, and November 12, 2021.
18We have reported on the worsening of several key indicators of nursing home resident
mental and physical health during 2020 and 2021. Nursing home officials and national
organizations attributed this worsening in part to the isolation residents experienced. See
GAO, COVID-19 in Nursing Homes: CMS Needs to Continue to Strengthen Oversight of
Infection Prevention and Control, GAO-22-105133 (Washington, D.C: Sept. 14, 2022).
19One study in our literature review examined the number of weeks a nursing home was in
the top decile of the national distribution of weekly confirmed resident COVID-19 cases,
which is described as the persistence of the outbreak. The study found that nursing home
quality ratings were associated with COVID-19 persistence. See Christianna S. Williams,
et al., “The association of nursing home quality ratings and spread of COVID-19,” Journal
of the American Geriatrics Society, vol. 69, no. 8 (2021): 2070-2078.
2042 C.F.R. § 483.80(g) (2021).




Page 7                                   GAO-23-104291 Nursing Home COVID-19 Outbreaks
19 vaccines. 21 However, COVID-19 deaths have not risen at the same
rate during these more recent peaks in cases, likely due to protection
from severe illness and death provided by vaccines. 22 See figure 1.




21According to CDC, viruses, such as the virus that causes COVID-19, constantly change
through mutation, and new variants are expected to occur. The Delta variant became the
dominant COVID-19 strain circulating in the U.S. during the week ending July 3, 2021.
The Omicron variant superseded the Delta variant to become the dominant COVID-19
strain circulating in the U.S. during the week ending December 25, 2021. As of April 5,
2022, CDC has reported the presence of multiple sublineages of the Omicron variant in
the U.S., including BA.2; BA.2 became the dominant strain circulating in the U.S. during
the week ending March 26, 2022.
22As of May 1, 2022, according to CDC data, nursing homes reported that 88.2 percent of
residents and 89.7 percent of staff had a complete vaccination—meaning the resident had
received all doses required to be fully vaccinated (two doses of a two-dose mRNA series
or one dose of a single-dose vaccine). Additionally, nursing homes reported that 80.6
percent of residents and 53.2 percent of staff had received an additional primary or
booster dose of the vaccine.




Page 8                                 GAO-23-104291 Nursing Home COVID-19 Outbreaks
Figure 1: New Weekly Confirmed COVID-19 Cases and Deaths among U.S. Nursing Home Residents and Staff, Weeks Ending
May 31, 2020, through October 2, 2022




                                      Page 9                            GAO-23-104291 Nursing Home COVID-19 Outbreaks
                           Notes: Dates refer to the end of a week (e.g., May 31, 2020, refers to the entire week from May 25,
                           2020, through May 31, 2020).
                           According to CDC, data used in this figure are part of a live data set, meaning that facilities can
                           correct the data at any time. This figure reflects data downloaded as of October 24, 2022, and
                           includes data through the week ending October 2, 2022. We excluded data for the week ending May
                           24, 2020, because it is the first week for which data are available and includes cases and deaths from
                           multiple weeks dating back to January 1, 2020.
                           Weekly case and death counts are likely underreported because they do not include data for the
                           nursing homes that did not report COVID-19 data to CDC for that week or from nursing homes that
                           submitted data that failed data quality assurance checks. Additionally, CMS does not require nursing
                           homes to report data prior to May 2020, although nursing homes may do so voluntarily.


                           From June 14, 2020, through January 2, 2022, nursing home COVID-19
Nursing Home               outbreaks lasted an average of 4 weeks. 23 Officials we interviewed at six
COVID-19 Outbreaks         selected nursing homes described a range of experiences during such
                           outbreaks, including many challenges and some areas of success.
Lasted 4 Weeks on
Average and Selected
Nursing Homes
Described a Range of
Outbreak
Experiences
Nursing Homes              Nursing homes experienced many COVID-19 outbreaks from June 14,
Experienced Many           2020, through January 2, 2022, with the average outbreak lasting 4
                           weeks. Specifically, the 15,281 nursing homes in our analysis
COVID-19 Outbreaks from
                           experienced from one to 16 outbreaks, with an average of 7.6 outbreaks
June 2020 through          and a total of 102,992 outbreaks across all homes during our period of
December 2021 with the     review. 24 The average outbreak duration was 4 weeks, ranging from 1
Average Outbreak Lasting   week (42 percent of total outbreaks) to 53 weeks (less than 1 percent of
4 Weeks                    total outbreaks). While shorter outbreaks were more common, nearly all
                           nursing homes (13,898 of 15,281 nursing homes, or 91 percent)
                           experienced at least one longer-lasting outbreak of 5 or more weeks. 25

                           23An outbreak begins when a nursing home reports a new case of COVID-19 in a resident
                           or staff member, and an outbreak ends when the nursing home has 2 consecutive weeks
                           without a new COVID-19 case. The outbreak duration does not include the 2 consecutive
                           weeks without a new COVID-19 case.
                           24During our period of review, 25 nursing homes reported zero COVID-19 outbreaks.

                           25We previously reported that, from May 2020 through January 2021—a shorter period of
                           review than this analysis—most nursing homes had multiple COVID-19 outbreaks (with an
                           average of about three outbreaks), and 85 percent of homes had outbreaks lasting 5 or
                           more weeks. See GAO-21-367.




                           Page 10                                      GAO-23-104291 Nursing Home COVID-19 Outbreaks
                                        (See fig. 2). This illustrates how nursing homes were heavily affected by
                                        the COVID-19 pandemic—requiring nursing home staff to respond to, and
                                        residents to experience, repeated outbreaks and weeks of continued
                                        spread of the virus.

Figure 2: Duration of COVID-19 Outbreaks in Nursing Homes, June 14, 2020, through January 2, 2022




                                        Note: An outbreak begins when a nursing home reports a new case of COVID-19 in a resident or staff
                                        member, and an outbreak ends when the nursing home has 2 consecutive weeks without a new
                                        COVID-19 case. The outbreak duration does not include the 2 consecutive weeks without a new
                                        COVID-19 case.


                                        We found that the average duration of COVID-19 outbreaks beginning
                                        near the end of both 2020 and 2021 were longer than outbreaks
                                        beginning at other points in either year. Specifically, the longest average
                                        outbreaks began in November 2020 and December 2021, lasting an
                                        average of 7 weeks and ranging from 1 to 32 weeks and from 1 to 17
                                        weeks, respectively. (See fig. 3). These trends follow a similar pattern to
                                        the trends seen in the number of COVID-19 cases reported in nursing
                                        homes over the same periods. There were spikes in cases in late 2020,
                                        prior to the availability of vaccines in nursing homes, and at the beginning
                                        of 2022, corresponding with the emergence of the initial COVID-19
                                        Omicron variant. However, the increases in average outbreak duration
                                        appear to precede the spikes in case numbers reported in nursing homes
                                        by approximately 1 month. This may be because any outbreaks beginning


                                        Page 11                                    GAO-23-104291 Nursing Home COVID-19 Outbreaks
                                       before the spike in cases continued to spread due to the growing
                                       caseloads.

Figure 3: Average Duration of COVID-19 Outbreaks in Nursing Homes by Month the Outbreak Began, June 14, 2020, through
January 2, 2022




                                       Note: An outbreak begins when a nursing home reports a new case of COVID-19 in a resident or staff
                                       member, and an outbreak ends when the nursing home has 2 consecutive weeks without a new
                                       COVID-19 case. The outbreak duration does not include the 2 consecutive weeks without a new
                                       COVID-19 case.


                                       High rates of COVID-19 in the community surrounding a nursing home
                                       can increase the risk that the virus will enter the home (for example,
                                       through staff or visitors) and could spread. We found that nursing homes




                                       Page 12                                    GAO-23-104291 Nursing Home COVID-19 Outbreaks
                                           reported that most outbreaks began with a staff case. 26 Specifically, 74.9
                                           percent of all outbreaks began with a reported staff case the first week of
                                           the outbreak, 12.0 percent began with a reported resident case, and 13.1
                                           percent began with both a reported staff and resident case. 27

Nursing Homes Described                    Officials at the six nursing homes we interviewed described a range of
a Range of Outbreak                        experiences during their COVID-19 outbreaks. In describing their
                                           experiences, the nursing home officials highlighted a number of
Experiences, Noting
                                           challenges as well as successes when discussing how they prevented
Challenges and                             and managed outbreaks. See table 1 for a summary of each nursing
Successes                                  home’s experience with COVID-19 outbreaks. For more information on
                                           these nursing homes’ experiences during outbreaks, see Appendix III.

Table 1: Nursing Home Officials’ Descriptions of COVID-19 Outbreaks

Nursing home              Nursing home officials’ descriptions of COVID-19 outbreaks
Nursing home A            This nursing home’s first case was a staff member in July 2020, and it was caught early. The required
                          biweekly COVID-19 testing caught additional staff cases throughout the pandemic. The nursing home’s
                          first resident outbreak was in October 2020 and started with five residents and then spread to an
                          additional 16 residents. The nursing home officials believed that COVID-19 entered the home from a
                          resident who left the home regularly for dialysis. A year later, in October 2021, the home had a second
                          major resident outbreak.
Nursing home B            This nursing home experienced its largest outbreak in December 2021 with the Omicron surge. During
                          this time, 20 percent of its residents and staff tested positive. Officials attributed this outbreak in part to
                          the re-opening of visitation that occurred in November 2021. Prior to the outbreak, the home had only
                          seen a few cases at a time, and its COVID-19-positive residents had avoided severe illness.
Nursing home C            Officials from this nursing home said that it kept COVID-19 out of the facility until May 2020. The first of
                          two resident outbreaks started with a few staff contracting COVID-19 from the community. Soon after,
                          two residents tested positive, then two more, and so on. During the first outbreak, the virus spread slowly,
                          but the second outbreak in late 2020 spread more rapidly—from two residents to 10 or 12 residents
                          almost immediately.
Nursing home D            Early in 2020, a COVID-19 outbreak affected about a dozen residents. The nursing home’s second
                          outbreak in the fall of 2020 was very hard on residents and staff, with 40 residents dying. Officials
                          believed the virus entered the facility through staff as, at the time, the home’s staff and the surrounding
                          community had low vaccination rates. In addition to the emotional toll on residents and staff, the number
                          of resident deaths plus staff attrition resulted in the nursing home losing about 50 percent of its capacity
                          and closing a sister nursing home.


                                           26Our calculation is based on data reported by nursing homes to CDC on a weekly basis.
                                           We do not take into account how many staff or residents were infected during the week,
                                           but just identify which category was reported first. Multiple contagion lines are possible for
                                           any outbreak, including contagion lines that were not detected by the testing regiment in
                                           place at the time.
                                           27This is consistent with our prior reporting where we found that 66 percent of all nursing
                                           homes from May 2020 through January 2021 reported that their longest-lasting COVID-19
                                           outbreak started with a reported staff case the first week of the outbreak. See
                                           GAO-21-367.




                                           Page 13                                    GAO-23-104291 Nursing Home COVID-19 Outbreaks
 Nursing home                             Nursing home officials’ descriptions of COVID-19 outbreaks
 Nursing home E                           Officials from this nursing home said that it kept COVID-19 out of the facility until July 2020. The outbreak
                                          lasted about 5 weeks and culminated with 32 of about 70 residents and 12 staff infected. Eight of those
                                          residents died. After that outbreak, the nursing home did not experience any additional large outbreaks,
                                          only a few isolated cases. Officials could not trace the origin of the outbreak, but believed that COVID-19
                                          was brought into the facility by a staff member.
 Nursing home F                           Early in the pandemic, this nursing home had some staff members test positive, but COVID-19 was not
                                          transferred to the residents. The first resident did not test positive until November 2020. Officials believed
                                          that it was brought into the facility by staff. The home had another outbreak in January 2021 and was
                                          able to contain COVID-19 to just one floor of their three-floor facility for a time, but eventually the virus
                                          spread.
Source: GAO interviews with officials from selected nursing homes in four states. │GAO-23-104291



                                                                 While describing their experiences with COVID-19 outbreaks, officials
                                                                 from all six selected nursing homes highlighted a number of critical
                                                                 challenges their homes faced. Specifically, the challenges they described
                                                                 included staffing issues, physical and psychosocial effects on residents,
                                                                 physical space constraints, and supply issues.

                                                                 •      Staffing issues. Officials from five of the six nursing homes described
                                                                        challenges related to staffing, including staffing shortages and issues
                                                                        with maintaining staff morale. In addition, the long-term care
                                                                        ombudsman and state survey agency officials in all four selected
                                                                        states also highlighted issues around insufficient staffing, particularly
                                                                        how it can negatively affect resident care. 28
                                                                        •     Staff shortages. Officials from five of the six nursing homes
                                                                              described experiencing staff shortages during COVID-19
                                                                              outbreaks. 29 For example, Nursing Home A officials described a

                                                                 28For example, one long-term care state ombudsman described that, because of staffing
                                                                 shortages, staff were only able to address the basic needs of residents, which has
                                                                 resulted in reports of an increase in pressure sores and other issues of resident neglect.
                                                                 Another state long-term care ombudsman described resident concerns of having
                                                                 insufficient staff to meet their needs, where residents of one nursing home described
                                                                 being left on the toilet or bedpan for an hour waiting for staff assistance.
                                                                 29In September 2020 we reported that, as of July 26, 2020, CDC data showed that 18
                                                                 percent of nursing homes were reporting a shortage of aides, about 16 percent were
                                                                 reporting a shortage of nursing staff, about 9 percent were reporting a shortage of other
                                                                 staff, and 2 percent were reporting a shortage of clinical staff. These shortages persisted
                                                                 over time. See GAO, COVID-19: Federal Efforts Could Be Strengthened by Timely and
                                                                 Concerted Actions, GAO-20-701 (Washington, D.C.: Sept. 21, 2020), 131; COVID-19:
                                                                 Urgent Actions Needed to Better Ensure an Effective Federal Response, GAO-21-191
                                                                 (Washington, D.C.: Nov. 30, 2020), 68; COVID-19: Critical Vaccine Distribution, Supply
                                                                 Chain, Program Integrity, and Other Challenges Require Focused Federal Attention,
                                                                 GAO-21-265 (Washington, D.C.: Jan. 28, 2021), 64; and COVID-19: Sustained Federal
                                                                 Action Is Crucial as Pandemic Enters Its Second Year, GAO-21-387 (Washington, D.C.:
                                                                 Mar. 31, 2021), 77.




                                                                 Page 14                                  GAO-23-104291 Nursing Home COVID-19 Outbreaks
          staffing “crisis,” noting that at one point the home lost about 25
          full-time employees, an approximately 25 percent reduction in
          workforce. Nursing Home E officials described losing about half of
          its staff, which resulted in the closing of a section of the home and
          a reliance on traveling nurses and certified nurse assistants to
          replenish its workforce. Nursing Home F officials noted that, with
          such limited staff, they had to make difficult choices, including
          moving the remaining staff between COVID-19 and non-COVID-
          19 units, which increased the risk of spreading the virus to
          uninfected residents. Further, Nursing Home D officials explained
          that being located in a rural area meant that they had fewer
          available staff, which sometimes resulted in “scary” staffing
          shortages.
    •     Staff morale. Officials from three of the six nursing homes
          discussed the psychosocial effect the pandemic had on their staff
          and the difficulties in maintaining staff morale. For example,
          Nursing Home D officials described how the outbreaks took away
          from staff the joy of caregiving and felt that many staff were left
          traumatized. In addition, Nursing Home B officials found it difficult
          to find staff willing to work in the COVID-19 units due to the risk of
          exposure to the virus.
•   Physical and psychosocial effects on residents. Officials from five
    of the six nursing homes described challenges with balancing the
    costs and benefits of nursing home visitation restrictions and other
    changes to resident rights. 30 While visitation restrictions may have
    helped prevent or mitigate the spread of COVID-19 in nursing homes,
    interviewees highlighted the physical and psychosocial harm that
    these restrictions caused for residents and families. For example,
    Nursing Home C officials noted that the home relies heavily on social
    interaction, so, even more than visitation, the suspension of dining
    facility activities resulted in declines in resident physical and mental
    health. Specifically, the staff began to see unplanned resident weight
    loss and an increased need for anti-depressant drugs. Officials told us
    many of the residents just “gave up.” All four selected states’ long-




30These challenges are consistent with our prior reporting, which found worsening mental
and physical health indicators among nursing home residents during the first year of the
pandemic. See GAO-22-105133.




Page 15                                GAO-23-104291 Nursing Home COVID-19 Outbreaks
    term care ombudsmen and two of the four states’ survey agencies
    also highlighted this challenge. 31
•   Physical space constraints. Officials from five of the six nursing
    homes described how the nursing homes’ physical space limited their
    ability to comply with COVID-19 infection control guidelines. For
    example, Nursing Home E officials explained that, in order to isolate
    COVID-19-positive residents, the home had to shuffle healthy
    residents from one room to another, which may have unintentionally
    spread the virus. In addition, Nursing Home C officials described how
    they had to keep expanding the boundaries of the COVID-19 unit as
    more and more residents were diagnosed with the virus. Among the
    four selected states, one long-term care ombudsmen and officials
    from two state survey agencies also noted this challenge. 32
•   Supply issues. Officials from five of the six nursing homes discussed
    difficulty acquiring sufficient personal protective equipment early in the
    pandemic. 33 Officials at Nursing Home E explained that the limited
    supply of N95 respirators exacerbated an outbreak in July 2020, as
    many residents and some staff had to use regular procedure masks
    instead, which are not as protective against the virus. Three selected
    states’ long-term care ombudsmen and officials at all four states’
    survey agencies also described this as a challenge early in the
    pandemic. 34



31One state long-term care ombudsman said that her staff had witnessed loneliness,
weight loss, and significant cognitive declines among residents they had known prior to
the pandemic; the official said that residents who had previously recognized ombudsmen
staff now looked at them “shell-shocked and blank.” Another state’s long-term care
ombudsman said that some residents appeared to have aged 10 years over a 2- or 3-
month time period.
32Officials at the two state survey agencies said that the physical layout and aging
infrastructure of nursing homes made it difficult to establish separate COVID-19 zones
and isolation rooms.
33This is consistent with our prior reporting on nursing home supply shortages during the
COVID-19 pandemic. For example, in September 2020 we reported that, as of July 26,
2020, CDC data showed that 22 percent of nursing homes were reporting that they did not
have a 1-week supply of one or more types of personal protective equipment (N95
respirators, surgical masks, gloves, eye protection, or gowns). However, as we reported in
January 2021, by December 6, 2020, this number had decreased to 10 percent of nursing
homes. See GAO-20-701, 129; GAO-21-191, 67; and GAO-21-265, 63.
34One state long-term care ombudsman described how residents could not get the
therapy they needed as providers would not come in to a home that lacked adequate
personal protective equipment.




Page 16                                  GAO-23-104291 Nursing Home COVID-19 Outbreaks
                        While describing their experiences with COVID-19 outbreaks, officials
                        from five of the six nursing homes we interviewed also noted some areas
                        of success. For example, officials from three nursing homes described
                        having success early in the pandemic preventing COVID-19 from entering
                        the home. Nursing Home B officials attributed their early success to
                        county actions that resulted in low levels of COVID-19 in the community
                        surrounding the nursing home. Specifically, Nursing Home B is located in
                        an isolated area and the county decided to close roads into the area to
                        keep travelers out. Nursing Homes A and C officials discussed proactive
                        measures that they took to prevent COVID-19, such as suspending new
                        admissions, restricting residents to their rooms, and adopting face mask
                        requirements. However, ultimately, all six selected nursing homes had
                        COVID-19 outbreaks.

                        Based on our analyses, we determined that transmission of COVID-19 in
Transmission of         the community surrounding a nursing home—known as community
COVID-19 in the         spread—had the strongest association with the duration of an outbreak in
                        the home, followed by the size of the nursing home, whether the nursing
Surrounding             home reported staff shortages, and the type of nursing home ownership. 35
Community Had the       Specifically, prior to the introduction of COVID-19 vaccines, being a small,
                        for-profit nursing home that did not report staffing shortages and was
Strongest Association   located in a county experiencing low community spread was associated
with Outbreak           with a higher probability of a COVID-19 outbreak ending roughly 12 days
                        earlier when compared to a large, government-owned nursing home that
Duration in Nursing     reported staff shortages and was located in a county experiencing high
Homes                   community spread.


                        35These factors were statistically significant at a p-value less than 0.05 and had a
                        significant effect on the probability of an outbreak ending in a given week, which we
                        defined as at least plus or minus 1 day (parameter estimate of at least plus or minus 0.14)
                        in either one of the two models. We created two models—one for prior to the introduction
                        of COVID-19 vaccines in nursing homes and one for after the introduction of vaccines in
                        nursing homes. Additional factors were also statistically significant at a p-value less than
                        0.05, but their impact on outbreak duration was smaller. See table 9 in appendix II for a list
                        of all factors analyzed.
                        CDC COVID-19 community transmission levels—high, substantial, moderate, or low—
                        describe the amount of COVID-19 spread within each county based on the total new
                        cases per 100,000 persons within the last 7 days and the percentage of positive
                        diagnostic and screening nucleic acid amplification tests during the last 7 days. Health
                        care facilities use these transmission levels to determine infection control interventions.
                        This is unique from CDC COVID-19 community levels, which the agency recommends
                        that individuals and communities use to decide which prevention actions to take based on
                        the latest information.




                        Page 17                                   GAO-23-104291 Nursing Home COVID-19 Outbreaks
                   Using multivariate statistical models, we estimated the association of
                   nursing home factors with the likelihood that an ongoing COVID-19
                   outbreak would end during a given week over two different time periods—
                   prior to the introduction of COVID-19 vaccines in nursing homes and after
                   the introduction of vaccines in nursing homes. 36 Generally, the magnitude
                   of the association of a given factor on outbreak duration was lower in the
                   period after the introduction of vaccines compared to the period prior to
                   the introduction of vaccines. 37 This was the case for community spread,
                   nursing home size, and nursing home-reported staff shortages, but to
                   varying degrees.

Community Spread   Community spread of COVID-19 had the strongest association with the
                   duration of an outbreak in a nursing home throughout our period of
                   review. Specifically, we found that nursing homes located in counties
                   experiencing low, moderate, or substantial levels of community spread
                   had a higher probability of their outbreaks ending during a given week—
                   meaning their outbreaks were shorter—when compared to nursing homes
                   in counties with high community spread.

                   The magnitude of the association of community spread on outbreak
                   duration was particularly pronounced prior to the introduction of vaccines.
                   Specifically, in the period of time prior to the introduction of vaccines, our
                   model estimated that the duration of a COVID-19 outbreak in a nursing
                   home located in a county experiencing low community spread was
                   approximately 7 days shorter than homes located in counties
                   experiencing high community spread. Even after the introduction of
                   COVID-19 vaccines, community spread was still associated with outbreak
                   duration—the outbreak duration was an estimated 5 days shorter for


                   36We ran two models—one for the period of time prior to the introduction of COVID-19
                   vaccines (June 14, 2020, through January 3, 2021) and one for the period of time after
                   introduction of COVID-19 vaccines in nursing homes (January 4, 2021, through January 2,
                   2022). The first nursing home vaccine clinics were held on December 21, 2020. According
                   to CDC, it takes 2 weeks or more for a vaccine to reach full effectiveness, so we set the
                   start date for the period after the introduction of vaccines as 2 weeks after the first vaccine
                   clinics. See appendix II for a detailed description of our methodology.
                   37Throughout the pandemic there have been changes to federal, state, and local COVID-
                   19 policies, improvements in infection prevention and control practices, increased
                   availability of personal protective equipment, and improvements to and increased
                   availability for COVID-19 testing. We have previously reported on the importance of
                   infection prevention and control practices and CDC continues to emphasize the
                   importance of rigorous infection prevention and control practices to prevent the spread of
                   COVID-19 in nursing homes. See GAO-22-105133.




                   Page 18                                   GAO-23-104291 Nursing Home COVID-19 Outbreaks
                    homes located in counties experiencing low community spread compared
                    to homes located in counties experiencing high community spread.

                    The number of ongoing outbreaks in a given week throughout the period
                    of review was typically much lower in nursing homes located in counties
                    experiencing low community spread compared to nursing homes located
                    in counties experiencing high community spread. These results could
                    indicate that, during times of higher levels of community spread, staff
                    have a greater likelihood of being exposed to the virus in the community
                    and then bringing it into the nursing home. 38 As we previously noted, the
                    first week of most outbreaks (about 75 percent) coincided with a reported
                    staff case rather than a reported resident case. The importance of
                    community spread in determining the probability of an outbreak ending is
                    consistent with what we found in our literature review, with many studies
                    finding that community spread was associated with the presence and
                    severity of COVID-19 within a nursing home. 39

Nursing Home Size   The size of a nursing home, as measured by the number of Medicare- or
                    Medicaid-certified beds, was also strongly associated with the duration of
                    a COVID-19 outbreak in a nursing home throughout our period of review.
                    Specifically, we found that small (fewer than 50 beds) and medium (50 to
                    99 beds) nursing homes had a higher probability of their outbreaks ending
                    during a given week—meaning their outbreaks were shorter—when
                    compared to large (100 to 199 beds) and very large (200 or more beds)
                    nursing homes.




                    38We recognize that staff may live or visit counties outside of the one where the nursing
                    home is located, but there are no data available to determine this. In addition, visitors,
                    when allowed, could also bring COVID-19 into the nursing home, but there are no data
                    available on nursing home visitors.
                    39For example, one study found that the prevalence of COVID-19 in the community was
                    the strongest predictor of COVID-19 cases and deaths in nursing homes. See Rebecca J.
                    Gorges and R. Tamara Konetzka, “Staffing Levels and COVID-19 Cases and Outbreaks in
                    U.S. Nursing Homes,” Journal of the American Geriatrics Society, vol. 68, no. 11 (2020):
                    2462-2466. Another study found that county-level COVID-19 rates and per-capita income
                    were the most significant predictors of COVID-19 outbreaks within nursing homes. See
                    Margaret M. Sugg et al., “Mapping community-level determinants of COVID-19
                    transmission in nursing homes: A multi-scale approach,” Science of the Total
                    Environment, vol. 752 (2021). And a third study identified a nursing home’s county
                    infection rate as one of the strongest predictors of COVID-19 infection. See Christopher
                    L.F. Sun et al., “Predicting Coronavirus Disease 2019 Infection Risk and Related Risk
                    Drivers in Nursing Homes: A Machine Learning Approach,” JAMDA, vol. 21, no. 11 (2020):
                    1533-1538.




                    Page 19                                   GAO-23-104291 Nursing Home COVID-19 Outbreaks
                  The association of nursing home size with outbreak duration remained
                  fairly consistent both before and after the introduction of vaccines.
                  Specifically, in the period of time prior to the introduction of vaccines, our
                  model estimated that the duration of a COVID-19 outbreak in a small
                  nursing home was just over 2.5 days shorter than large and very large
                  homes and, after the introduction of vaccines, the association decreased
                  slightly to just under an estimated 2.5 days shorter.

                  These findings may be a result of smaller homes simply having fewer
                  residents and staff who can get infected by the virus, so the outbreaks do
                  not continue for as long as in larger nursing homes. However, it could
                  also be affected by other differences between smaller and larger nursing
                  homes, such as fewer staff and visitors entering smaller nursing homes,
                  which could decrease the likelihood of continued transmission of the
                  virus. The importance of nursing home size being associated with the
                  probability of an outbreak ending is consistent with what we found in our
                  literature review, with multiple studies finding that larger homes were
                  associated with the presence of COVID-19 or higher numbers of COVID-
                  19 cases. 40

Staff Shortages   Nursing home-reported staff shortages were also strongly associated with
                  the duration of COVID-19 outbreaks prior to the introduction of vaccines.
                  We found that nursing homes that reported staff shortages had a lower
                  probability of their outbreaks ending during a given week—meaning their




                  40For example, one study found that, as of May 2020, larger nursing home size was
                  significantly associated with both an increased probability of having a COVID-19 case and
                  having a larger outbreak. See Hannah R. Abrams et al., “Characteristics of U.S. Nursing
                  Homes with COVID-19 Cases,” Journal of the American Geriatrics Society, vol. 68, no. 8
                  (2020): 1653-1656. Another study found that, from March to August 2020, large nursing
                  homes (150 or more beds) reported 2.6 fewer staff COVID-19 cases per 100 beds
                  compared with small nursing homes (less than 50 beds). See Kira L. Ryskina et al.,
                  “Characteristics of Nursing Homes by COVID-19 Cases among Staff: March to August
                  2020,” JAMDA, vol. 22, no. 5 (2021): 960-965.




                  Page 20                                 GAO-23-104291 Nursing Home COVID-19 Outbreaks
outbreaks were longer—when compared to homes that did not report staff
shortages. 41

Prior to the introduction of vaccines, the magnitude of the association of
reported staff shortages on outbreak duration was substantial, but the
association was minimal after the introduction of vaccines. Specifically,
our model estimated that, prior to the introduction of vaccines, the
duration of an outbreak at a nursing home reporting staff shortages was
over a day longer than homes that did not report shortages. After the
introduction of vaccines, the magnitude of the association of nursing
home-reported staff shortages on outbreak duration decreased to less
than half a day.

These findings may be due to the associated effects of staff shortages.
For instance, nurse staff may need to cover more residents and rooms or
temporary staff from other homes or health care settings may need to fill
the vacancies, both of which could inadvertently cause the virus to be
brought into the home or spread throughout more of the home. As
previously noted, nursing homes, state survey agencies, and state long-
term care ombudsmen we interviewed described staff shortages and
associated challenges, such as adhering to CDC-recommended infection
prevention and control practices, as concerns during the pandemic.

We also analyzed variables that directly measure actual nursing home
staff levels, rather than perceived shortages reported by nursing home
officials, and found less clear results. For instance, prior to the
introduction of vaccines, the greater the percentage of new employees,
the longer an outbreak lasted, but, while statistically significant, the
magnitude of the association was small. After the introduction of
vaccines, we found the inverse association—the greater the percentage
of new employees, the shorter an outbreak lasted—and, again, the
magnitude of the association was statistically significant but small. In
addition, we found that the associations of other staffing variables, such

41A few studies analyzed the association of various factors with the likelihood of nursing
homes reporting staff shortages. For example, two studies found that in mid-2020 reported
shortages were greater in nursing homes with COVID-19 cases among residents and
staff, as well as in homes with lower quality scores and those serving more Medicaid
beneficiaries. See Diane M. Gibson and Jessica Greene, “State Actions and Shortages of
Personal Protective Equipment and Staff in U.S. Nursing Homes,” Journal of the American
Geriatrics Society, vol. 68, no. 12 (2020): 2721-2726; and Brian E. McGarry et al., “Severe
Staffing and Personal Protective Equipment Shortages Faced By Nursing Homes During
the COVID-19 Pandemic,” Health Affairs, vol. 39, no. 10 (2020): 1812-1821.




Page 21                                 GAO-23-104291 Nursing Home COVID-19 Outbreaks
            as average hours per employee per week and number of employees per
            resident, on outbreak duration were not always statistically significant.

            Our literature review identified one study that analyzed a measure of
            outbreaks over time and it found an inverse association with nurse
            staffing ratings. 42 However, our nuanced results are consistent with other
            studies in our literature review. For example, one study found that,
            whereas higher staffing levels increase the probability of having at least
            one COVID-19 case, higher nurse aide and total nursing hours were
            associated with a lower probability of a larger outbreak and fewer
            deaths. 43 Another study found that the average number of unique staff
            members working in a facility on a given day was strongly associated with
            COVID-19 outcomes in nursing homes, but that, after staff size was
            controlled for, there was no clear relationship between COVID-19
            outcomes and more traditional measures of staffing. 44

Ownership   The type of nursing home ownership—whether the home is for-profit,
            non-profit, or government-owned—was also strongly associated with
            COVID-19 outbreak duration at times during our period of review. We
            found that nursing homes designated as non-profit or government-owned
            had a lower probability of their outbreaks ending during a given week—
            meaning their outbreaks were longer—when compared to homes
            designated as for-profit. For instance, our model estimated that the
            duration of an outbreak in a government-owned nursing home was about
            1.5 days longer than in for-profit homes after the introduction of vaccines.

            The studies in our literature review that found an association between
            COVID-19 outcomes in nursing homes and nursing home ownership
            generally found that non-profit homes did better than for-profit homes on
            the presence or severity of cases and the number of deaths. For

            42The study examined the total number of weeks a nursing home was in the top decile of
            the national distribution of weekly confirmed resident COVID-19 incidence and found that
            nursing homes with lower nurse staffing ratings had 18 to 22 percent more weeks with
            high COVID-19 incidence than homes with the highest staffing rating. See Christianna S.
            Williams et al., “The Association of Nursing Home Quality Ratings and Spread of COVID-
            19,” Journal of the American Geriatrics Society, vol. 69, no. 8 (2021): 2070-2078.
            43See Rebecca J. Gorges and R. Tamara Konetzka, “Staffing Levels and COVID-19
            Cases and Outbreaks in U.S. Nursing Homes,” Journal of the American Geriatrics Society,
            vol. 68, no. 11 (2020): 2462-2466.
            44See Brian E. McGarry et al., “Larger Nursing Home Staff Size Linked To Higher Number
            Of COVID-19 Case In 2020,” Health Affairs, vol. 40, no. 8 (2021): 1261-1269.




            Page 22                                GAO-23-104291 Nursing Home COVID-19 Outbreaks
                  example, one study of California nursing homes found that as of May 1,
                  2020, the size of COVID-19 outbreaks was 12.7 times larger in for-profit
                  nursing homes than in their non-profit counterparts. 45 One study,
                  however, found an inverse association—that, between March and August
                  2020, for-profit nursing homes were associated with fewer staff COVID-19
                  cases when compared to non-profit homes. 46 While our results were
                  unexpected based on the general findings of the studies we reviewed, we
                  analyzed a longer period of time and measured a different outcome—
                  outbreak duration rather than the presence or severity of COVID-19
                  cases or deaths.

                  We provided a draft of this report to HHS for review and comment. HHS
Agency Comments   provided technical comments, which we addressed as appropriate. HHS
                  comments noted some considerations for potential further analysis and
                  potential methodological limitations, and our report describes limitations.
                  HHS comments also highlighted how critical infection prevention and
                  control practices within nursing homes are to reducing the risk of COVID-
                  19 transmission, a point that we and others have also made.

                  We are sending copies of this report to the appropriate congressional
                  committees, the Secretary of HHS, and other interested parties. In
                  addition, the report is available at no charge on the GAO website at
                  http://www.gao.gov.

                  If you or your staff have any questions about this report, please contact
                  me at (202) 512-7114 or at dickenj@gao.gov. Contact points for our
                  Offices of Congressional Relations and Public Affairs may be found on




                  45See Ram Gopal, Xu Han, and Niam Yaraghi, “Compress the Curve: A Cross-Sectional
                  Study of Variations in COVID-19 Infections across California Nursing Homes,” BMJ Open,
                  vol. 11 (2021): e042804.
                  46See Kira L. Ryskina et al., “Characteristics of Nursing Homes by COVID-19 Cases
                  among Staff: March to August 2020,” JAMDA, vol. 22, no. 5 (2021): 960-965.




                  Page 23                               GAO-23-104291 Nursing Home COVID-19 Outbreaks
the last page of this report. GAO staff who made key contributions to this
report are listed in Appendix IV.




John E. Dicken
Director, Health Care




Page 24                          GAO-23-104291 Nursing Home COVID-19 Outbreaks
List of Addressees

The Honorable Patrick Leahy
Chairman
The Honorable Richard Shelby
Vice Chairman
Committee on Appropriations
United States Senate

The Honorable Ron Wyden
Chairman
The Honorable Mike Crapo
Ranking Member
Committee on Finance
United States Senate

The Honorable Patty Murray
Chairman
The Honorable Richard Burr
Ranking Member
Committee on Health, Education, Labor, and Pensions
United States Senate

The Honorable Gary C. Peters
Chairman
The Honorable Rob Portman
Ranking Member
Committee on Homeland Security and Governmental Affairs
United States Senate

The Honorable Rosa L. DeLauro
Chair
The Honorable Kay Granger
Ranking Member
Committee on Appropriations
House of Representatives

The Honorable Frank Pallone, Jr.
Chairman
The Honorable Cathy McMorris Rodgers
Republican Leader
Committee on Energy and Commerce
House of Representatives


Page 25                         GAO-23-104291 Nursing Home COVID-19 Outbreaks
The Honorable Bennie G. Thompson
Chairman
The Honorable John Katko
Ranking Member
Committee on Homeland Security
House of Representatives

The Honorable Carolyn B. Maloney
Chairwoman
The Honorable James Comer
Ranking Member
Committee on Oversight and Reform
House of Representatives

The Honorable Richard E. Neal
Chair
The Honorable Kevin Brady
Republican Leader
Committee on Ways and Means
House of Representatives

The Honorable Michael F. Bennet
United States Senate




Page 26                         GAO-23-104291 Nursing Home COVID-19 Outbreaks
Appendix I: Literature Review—Methodology
              Appendix I: Literature Review—Methodology
              Description and Results


Description and Results

              To understand what is known about the factors associated with COVID-
              19 outbreaks in nursing homes, we conducted a systematic literature
              review from January 1, 2020, through October 1, 2021.

Methodology   We conducted a systematic literature review of studies using data to
              examine the association of any factor with COVID-19 outbreaks in U.S.
              nursing homes. We searched across five research platforms (EBSCO,
              Scopus, SSRN, ProQuest, and Dialog’s 96 databases), focusing on those
              databases that covered health and medical issues. 1 We conducted
              additional targeted internet searches using the Harvard Kennedy School
              Think Tank Search to capture additional studies. After reviewing the initial
              returns from our search, we expanded and updated our search strategy to
              increase the relevance and breadth of our returns. We ultimately
              searched the original five research platforms plus PubMed and Google
              Scholar, covering the time period of January 1, 2020, through October 1,
              2021.

              We identified a total of 49 studies that met our selection criteria, and we
              conducted a high-level quality review to assess the reliability and
              methodological soundness of those studies. We considered studies to be
              sufficiently reliable if they had been peer-reviewed and published in an
              academic journal, if they were included in a federal or state government
              publication with similarly rigorous review processes, or if they were
              prepared by or on behalf of a federal or state government entity. 2 As a
              result of this process, we determined that 43 studies were sufficiently
              reliable for our use. We excluded three of those studies because, upon
              further review, they did not meet our original criteria—to select studies

              1For instance, Embase, EMCare, HSELINE: Health and Safety, Global Health, Medline,
              and the New England Journal of Medicine.
              2If studies did not meet this criterion, we considered them to be sufficiently reliable if they
              met all of the following three criteria: (1) the study was marked as provisional (e.g., pre-
              publication status) for a peer-reviewed journal or government publication with a similarly
              rigorous review process; (2) the study was transparent about its data sources and
              methods, those sources and methods appeared appropriate for the researchable
              questions, and the study discussed possible limitations; and (3) the study reported all
              relevant results, and conclusions and recommendations were adequately supported by
              those results.
              Due to the rapidly evolving nature of the COVID-19 pandemic, we recognized that recent
              studies may not have had time to complete the full peer review process. We chose to
              include studies still pending peer review because they could cover emerging issues or use
              more timely and complete data than studies from earlier in the pandemic. Four of the final
              40 studies were marked as provisional at the time of selection. All four of those studies
              were published by the time of our reporting—three in peer reviewed journals.




              Page 27                                    GAO-23-104291 Nursing Home COVID-19 Outbreaks
          Appendix I: Literature Review—Methodology
          Description and Results




          that examined the association of one or more factors with COVID-19
          outbreaks in U.S. nursing homes. This resulted in a total of 40 selected
          studies.

          To review these selected studies, we applied a framework of three
          analytical categories describing the type of analysis conducted for each
          study: presence, severity, and duration of COVID-19 outbreaks in nursing
          homes. Some studies conducted more than one of these types of
          analyses.

          •   Presence of COVID-19 outbreaks. Studies investigating the
              presence of COVID-19 outbreaks assessed the association of state,
              county, nursing home, or resident factors with a categorical or binary
              outcome relating to whether or not COVID-19 affected a nursing
              home. For example, some studies compared nursing homes that had
              at least one COVID-19 case or death with homes that did not have
              any COVID-19 cases or deaths. Eighteen studies were categorized as
              assessing presence.
          •   Severity of COVID-19 outbreaks. Studies investigating the severity
              of COVID-19 outbreaks assessed the association of state, county,
              nursing home, or resident factors with a continuous outcome, such as
              by comparing the cumulative number of COVID-19 cases or deaths in
              each nursing home. Thirty-three studies were categorized as
              assessing severity.
          •   Duration of COVID-19 outbreaks. Studies investigating the duration
              of COVID-19 outbreaks assessed the association of state, county,
              nursing home, or resident factors with the amount of time that each
              nursing home was experiencing COVID-19 outbreaks. One study was
              categorized as assessing duration.


Results   Table 2 lists the 40 studies we reviewed.




          Page 28                               GAO-23-104291 Nursing Home COVID-19 Outbreaks
                                            Appendix I: Literature Review—Methodology
                                            Description and Results




Table 2: Studies Included in GAO’s Review That Focused on Factors Associated with the Presence, Severity, or Duration of
COVID-19 Outbreaks in Nursing Homes, January 1, 2020, through October 1, 2021

                                                  Methodological focus of study
                                               Factors                    Factors
                                             associated        Factors associated
                                               with the      associated with the
                                              presence         with the   duration
                                             of COVID-       severity of of COVID-
                            Authors               19          COVID-19       19
                                             outbreaks       outbreaks outbreaks
                            Journal          in nursing      in nursing in nursing
      Title                 Publication date   homes           homes       homes   Summary of key findings
1     “Is There a Link      He, Mengying,                                   –         In California from April 23, 2020, through
      between Nursing       Yumeng Li, and                                              June 2, 2020, nursing homes with a five-star
      Home Reported         Fang Fang                                                   rating and a higher percentage of White
      Quality and COVID-    JAMDA                                                       residents were less likely to have COVID-19
      19 Cases? Evidence                                                                cases and deaths compared to other nursing
      from California       July 2020                                                   homes in the state, after adjusting for nursing
      Skilled Nursing                                                                   home size, ownership, and years of
      Facilities”                                                                       operation.
2     “Nursing Home         Unruh, Mark                          –           –         As of mid-April 2020, nursing homes in
      Characteristics       Aaron et al.                                                Connecticut, New Jersey, and New York with
      Associated with       JAMDA                                                       the highest percentages of Medicaid patients
      COVID-19 Deaths in                                                                had an 8.6 percentage point greater
      Connecticut, New      July 2020                                                   probability of six or more COVID-19 deaths
      Jersey, and New                                                                   than nursing homes with the lowest
      York”                                                                             percentages of these patients in the same
                                                                                        three states. Other characteristics associated
                                                                                        with COVID-19 deaths included having
                                                                                        patients with higher activities of daily living
                                                                                        scores, more total beds, higher occupancy
                                                                                        rates, and being for-profit.
3     “Nurse Staffing and   Harrington,                          –           –         Between March and May 2020, California
      Coronavirus           Charlene et al.                                             nursing homes with total registered nurse
      Infections in         Policy, Politics, &                                         staffing levels under 0.75 hours per resident
      California Nursing    Nursing Practice                                            day had a two times greater probability of
      Homes”                                                                            having COVID-19 resident infections.
                            July 7, 2020                                                Nursing homes with lower Medicare five-star
                                                                                        ratings on total nurse and registered nurse
                                                                                        staffing levels (adjusted for acuity), higher
                                                                                        total health deficiencies, and more beds had
                                                                                        a higher probability of having COVID-19
                                                                                        residents.




                                            Page 29                               GAO-23-104291 Nursing Home COVID-19 Outbreaks
                                          Appendix I: Literature Review—Methodology
                                          Description and Results




                                                Methodological focus of study
                                              Factors                   Factors
                                            associated       Factors associated
                                              with the     associated with the
                                             presence        with the   duration
                                            of COVID-      severity of of COVID-
                           Authors               19         COVID-19       19
                                            outbreaks      outbreaks outbreaks
                           Journal          in nursing     in nursing in nursing
    Title                  Publication date   homes          homes       homes   Summary of key findings
4   “Characteristics and   Chatterjee, Paula                   –           –         In nursing homes from the District of
    Quality of US          et al.                                                     Columbia and 23 states reporting COVID-19
    Nursing Homes          JAMA Network                                               cases from April 22, 2020, through April, 29,
    Reporting Cases of     Open                                                       2020, homes that reported COVID-19 cases
    Coronavirus Disease                                                               had similar mean scores as those that did
    2019 (COVID-19)”       July 29, 2020                                              not on overall five-star ratings, as well as star
                                                                                      ratings on deficiencies and staffing.
                                                                                      Compared to homes that did not report
                                                                                      cases, those that did had higher rates of
                                                                                      health deficiencies, emergency
                                                                                      preparedness deficiencies, reported
                                                                                      incidents, and substantiated complaints.
                                                                                      Rates of COVID-19 were nearly twice as
                                                                                      high in counties where homes reported
                                                                                      COVID-19 cases than in those without
                                                                                      reported cases.
5   “Characteristics of    Abrams, Hannah                                 –         In all nursing homes from 30 states with
    U.S. Nursing Homes     R. et al.                                                  facility-level COVID-19 data as of May 11,
    with COVID-19          Journal of the                                             2020, larger facility size, urban location,
    Cases”                 American                                                   greater percentage of African American
                           Geriatrics Society                                         residents, non-chain status, and state were
                                                                                      significantly related to the increased
                           August 2020                                                probability of having a COVID-19 case. Five-
                                                                                      star rating, prior infection violation, Medicaid
                                                                                      dependency, and ownership were not
                                                                                      significantly related. The size of the outbreak
                                                                                      was significantly associated with facility size,
                                                                                      for-profit status, and state but not with other
                                                                                      studied characteristics.
6   “Mapping               Sugg, Margaret                                 –         As of June 30, 2020, county-level COVID-19
    Community-Level        M. et al.                                                  rates, per-capita income, average household
    Determinants of        Science of the                                             size, population density, unemployment, and
    COVID-19               Total                                                      a higher percentage of African Americans, in
    Transmission in        Environment                                                combination with nursing home staffing
    Nursing homes: A                                                                  levels (licensed practical nurses and total
    Multi-Scale            August 25, 2020                                            staff) and number of fines issued in 2020
    Approach”                                                                         were associated with an increased risk of
                                                                                      COVID-19 cases in nursing homes. Lower
                                                                                      overall quality rating and staffing rating
                                                                                      increased the risk of COVID-19 cases, but
                                                                                      the results were not statistically significant.




                                          Page 30                               GAO-23-104291 Nursing Home COVID-19 Outbreaks
                                          Appendix I: Literature Review—Methodology
                                          Description and Results




                                                Methodological focus of study
                                              Factors                   Factors
                                            associated       Factors associated
                                              with the     associated with the
                                             presence        with the   duration
                                            of COVID-      severity of of COVID-
                           Authors               19         COVID-19       19
                                            outbreaks      outbreaks outbreaks
                           Journal          in nursing     in nursing in nursing
    Title                  Publication date   homes          homes       homes   Summary of key findings
7   “Staffing Levels and   Gorges, Rebecca                                –         As of June 14, 2020, higher registered
    COVID-19 Cases         J. and R. Tamara                                           nurse-hours were associated with a higher
    and Outbreaks in       Konetzka                                                   probability of a nursing home experiencing
    U.S. Nursing Homes”    Journal of the                                             any COVID-19 cases. However, among
                           American                                                   nursing homes with at least one case, higher
                           Geriatrics Society                                         nurse aide hours and total nursing hours
                                                                                      were associated with a lower probability of
                           August 28, 2020                                            experiencing an outbreak and with fewer
                                                                                      deaths. The strongest predictor of cases and
                                                                                      outbreaks in nursing homes was per capita
                                                                                      cases in the county.
8   “COVID-19 Infections Li, Yue et al.                                   –         Among Connecticut nursing homes with at
    and Deaths among     Journal of the                                               least one confirmed COVID-19 case, as of
    Connecticut Nursing American                                                      April 16, 2020, every 20-minute increase in
    Home Residents:      Geriatrics Society                                           registered nurse staffing (per resident day)
    Facility Correlates”                                                              was associated with 22 percent fewer
                         September 2020                                               confirmed cases. Compared with one- to
                                                                                      three-star facilities, four- or five-star facilities
                                                                                      had 13 percent fewer confirmed cases, and
                                                                                      facilities with a high concentration of
                                                                                      Medicaid residents or racial/ethnic minority
                                                                                      residents had 16 percent and 15 percent
                                                                                      more confirmed cases, respectively, than
                                                                                      their counterparts. Among nursing homes
                                                                                      with at least one COVID-19 death, every 20-
                                                                                      minute increase in registered nurse staffing
                                                                                      significantly predicted 26 percent fewer
                                                                                      COVID-19 deaths. Other characteristics did
                                                                                      not show statistically significant associations
                                                                                      with COVID-19 deaths.
9   “Association of        Figueroa, Jose F.        –                      –         For 4,254 nursing homes across eight states
    Nursing Home           et al.                                                     from January 1, 2020, through June 30,
    Ratings on Health      JAMA                                                       2020, nursing homes with high ratings on
    Inspections, Quality                                                              nurse staffing had fewer COVID-19 cases
    of Care, and Nurse     September 15,                                              than nursing homes with low ratings on
    Staffing with COVID-   2020                                                       nurse staffing. There was no significant
    19 Cases”                                                                         association between high- and low-
                                                                                      performing nursing homes in the health
                                                                                      inspections or quality measures domains
                                                                                      with COVID-19 cases.




                                          Page 31                               GAO-23-104291 Nursing Home COVID-19 Outbreaks
                                            Appendix I: Literature Review—Methodology
                                            Description and Results




                                                  Methodological focus of study
                                                Factors                   Factors
                                              associated       Factors associated
                                                with the     associated with the
                                               presence        with the   duration
                                              of COVID-      severity of of COVID-
                             Authors               19         COVID-19       19
                                              outbreaks      outbreaks outbreaks
                             Journal          in nursing     in nursing in nursing
     Title                   Publication date   homes          homes       homes   Summary of key findings
10   “Association         Bui, David P. et                       –           –         During March through June 2020, 14 (11
     Between CMS          al.                                                           percent) of 123 West Virginia nursing homes
     Quality Ratings and Morbidity and                                                  experienced COVID-19 outbreaks.
     COVID-19 Outbreaks Mortality Weekly                                                Compared with one-star–rated (lowest
     in Nursing Homes— Report                                                           rating) nursing homes, the odds of a COVID-
     West Virginia, March                                                               19 outbreak were 87 percent lower among
     17-June 11, 2020”    September 18,                                                 two- to three-star–rated facilities and 94
                          2020                                                          percent lower among four- to five-star–rated
                                                                                        facilities.
11   “A Study of the         Rowan, Patricia          –                      –         Through July 22, 2020, nursing homes in
     COVID-19 Outbreak       et al.                                                     Connecticut with a high staffing rating had
     and Response in         Connecticut                                                significantly fewer COVID-19 cases and
     Connecticut Long-       Department of                                              deaths per licensed bed than nursing homes
     Term Care Facilities”   Public Health                                              with a lower staffing rating. Nursing homes in
                                                                                        Connecticut located in communities with a
                             September 30,                                              greater incidence of COVID-19 were more
                             2020                                                       likely to experience higher numbers of cases
                                                                                        and deaths. Nursing homes in Connecticut
                                                                                        with a larger share of residents that received
                                                                                        dialysis and cancer treatments, which tend to
                                                                                        be delivered off site, had more cases per
                                                                                        licensed bed. The total number of residents
                                                                                        and the share of the licensed beds that were
                                                                                        filled also significantly predicted greater
                                                                                        COVID-19 spread.
12   “Variation in SARS-     White, Elizabeth                               –         As of late April and early May 2020, a
     CoV-2 Prevalence in     M. et al.                                                  difference in county prevalence of 1,000
     U.S. Skilled Nursing    Journal of the                                             COVID-19 cases per 100,000 (1 percent)
     Facilities”             American                                                   was associated with a 33.6 percentage point
                             Geriatrics Society                                         difference in the probability of an outbreak
                                                                                        for Genesis HealthCare-owned nursing
                             October 2020                                               homes (sample of 341 nursing homes in 25
                                                                                        states) and non-Genesis nursing homes
                                                                                        (sample of 3,016 nursing homes in 12 states)
                                                                                        combined, and a difference of 12.5 cases per
                                                                                        facility for Genesis nursing homes. A 10-bed
                                                                                        difference in facility size was associated with
                                                                                        a 0.9 percentage point difference in the
                                                                                        probability of outbreak. No consistent
                                                                                        relationship was found between nursing
                                                                                        home Five-Star ratings or past infection
                                                                                        control deficiency citations and probability or
                                                                                        severity of outbreak.




                                            Page 32                               GAO-23-104291 Nursing Home COVID-19 Outbreaks
                                          Appendix I: Literature Review—Methodology
                                          Description and Results




                                                Methodological focus of study
                                                Factors                 Factors
                                              associated     Factors associated
                                                with the   associated with the
                                               presence      with the   duration
                                              of COVID-    severity of of COVID-
                             Authors               19       COVID-19       19
                                              outbreaks    outbreaks outbreaks
                             Journal          in nursing   in nursing in nursing
     Title                   Publication date   homes        homes       homes   Summary of key findings
13   “Prevalence of          Bowblis, John                                –         Through mid-June 2020, just under one-third
     COVID-19 in Ohio        and Robert                                               of nursing homes in Ohio had at least one
     Nursing Homes:          Applebaum                                                resident with COVID-19, with over 82
     What’s Quality Got to   Journal of Aging                                         percent of all cases in the state coming from
     Do with It?”            & Social Policy                                          37 percent of nursing homes. Overall
                                                                                      findings on the association between facility
                             October 11, 2020                                         quality and the prevalence of COVID-19
                                                                                      showed that having any resident case of the
                                                                                      virus or even having a high caseload of
                                                                                      residents with the virus is not more likely in
                                                                                      nursing homes with lower quality ratings.
14   “Comparative            Braun, Robert          –                      –         From May 17, 2020, through July 2, 2020,
     Performance of          Tyler et al.                                             there were no statistically significant
     Private Equity-         JAMA Network                                             differences in staffing levels, COVID-19
     Owned US Nursing        Open                                                     cases or deaths, or deaths by any cause
     Homes During the                                                                 between private equity-owned nursing
     COVID-19                October 28, 2020                                         homes and for-profit, nonprofit, and
     Pandemic”                                                                        government-owned facilities. For-profit,
                                                                                      nonprofit, and government-owned nursing
                                                                                      homes were more likely to have at least a 1-
                                                                                      week supply of N95 masks and a 1-week
                                                                                      supply of medical gowns than private equity-
                                                                                      owned nursing homes.
15   “Mortality Rates from   Dean, Adam,            –                      –         In 355 New York nursing homes with
     COVID-19 Are Lower      Atheendar                                                available data from March 1, 2020, through
     in Unionized Nursing    Venkataramani,                                           May 31, 2020, health care worker unions
     Homes”                  and Simeon                                               were associated with a 1.29 percentage
                             Kimmel                                                   point decrease in the COVID-19 mortality
                             Health Affairs                                           when compared with nursing homes without
                                                                                      these unions. Unions were also associated
                             November 2020                                            with greater access to personal protective
                                                                                      equipment.




                                          Page 33                               GAO-23-104291 Nursing Home COVID-19 Outbreaks
                                         Appendix I: Literature Review—Methodology
                                         Description and Results




                                               Methodological focus of study
                                             Factors                   Factors
                                           associated       Factors associated
                                             with the     associated with the
                                            presence        with the   duration
                                           of COVID-      severity of of COVID-
                          Authors               19         COVID-19       19
                                           outbreaks      outbreaks outbreaks
                          Journal          in nursing     in nursing in nursing
     Title                Publication date   homes          homes       homes   Summary of key findings
16   “Racial and Ethnic    Li, Yue et al.                                –         For COVID-19 data reported the week of
     Disparities in COVID- Journal of the                                            May 25, 2020, nursing homes with a high-
     19 Infections and     American                                                  proportion of racial and ethnic minorities
     Deaths Across U.S. Geriatrics Society                                           were 76 percent more likely to have at least
     Nursing Homes”                                                                  one new resident case compared to nursing
                           November 2020                                             homes with a low-proportion of racial and
                                                                                     ethnic minorities. In addition, similar across-
                                                                                     facility disparities were found for the weekly
                                                                                     count of new COVID-19 deaths among
                                                                                     residents and in the weekly count of new
                                                                                     COVID-19 confirmed cases among staff. No
                                                                                     substantial disparities in self-reported
                                                                                     shortages of staff or personal protective
                                                                                     equipment were found.
17   “Stemming the Tide   Lipsitz, Lewis A.        –                      –         In response to the COVID-19 pandemic, a
     of COVID-19          et al.                                                     statewide effort in Massachusetts offered all
     Infections in        Journal of the                                             360 nursing homes in the state weekly
     Massachusetts        American                                                   webinars and answers to questions
     Nursing Homes”       Geriatrics Society                                         regarding infection control procedures. The
                                                                                     effort also targeted a subset of 123 nursing
                          November 2020                                              homes with previous infection control
                                                                                     deficiencies for intervention, which included
                                                                                     on-site and virtual consultations. During the
                                                                                     9-week intervention period from May 10,
                                                                                     2020, through July 5, 2020, both resident
                                                                                     and staff COVID-19 infection rates started
                                                                                     higher in the targeted subset of nursing
                                                                                     homes, then rapidly declined to the same low
                                                                                     level as other nursing homes. Adherence to
                                                                                     infection control processes, especially proper
                                                                                     wearing of personal protective equipment
                                                                                     and cohorting, was significantly associated
                                                                                     with declines in weekly infection and
                                                                                     mortality rates.




                                         Page 34                               GAO-23-104291 Nursing Home COVID-19 Outbreaks
                                         Appendix I: Literature Review—Methodology
                                         Description and Results




                                               Methodological focus of study
                                              Factors                  Factors
                                            associated      Factors associated
                                              with the    associated with the
                                             presence       with the   duration
                                            of COVID-     severity of of COVID-
                           Authors               19        COVID-19       19
                                            outbreaks     outbreaks outbreaks
                           Journal          in nursing    in nursing in nursing
     Title                 Publication date   homes         homes       homes   Summary of key findings
18   “Predicting           Sun, Christopher                   –           –         As of April 20, 2020, the strongest predictors
     Coronavirus Disease   L.F. et al.                                               of COVID-19 cases in 1,146 nursing homes
     2019 Infection Risk   JAMDA                                                     in Massachusetts, Georgia, and New Jersey
     and Related Risk                                                                were the nursing home’s county’s infection
     Drivers in Nursing    November 2020                                             rate and the number of separate units in the
     Homes: A Machine                                                                nursing home; other predictors included the
     Learning Approach”                                                              county’s population density, the nursing
                                                                                     home’s historical health deficiency citations,
                                                                                     and the nursing home’s resident density (in
                                                                                     persons per 1,000 square feet). In addition,
                                                                                     the nursing home’s historical percentage of
                                                                                     non-Hispanic White residents was identified
                                                                                     as a protective factor.
19   “The Role of the     LeRose, Jennifer         –                      –         In May 2020, Michigan nursing homes
     Social Vulnerability J. et al.                                                  located in the most vulnerable areas of the
     Index in Personal    Infection Control                                          state, which was determined using the
     Protective Equipment & Hospital                                                 Centers for Disease Control and
     Shortages, Number    Epidemiology                                               Prevention’s social vulnerability index, were
     of Cases, and                                                                   2.3 times more likely to experience personal
     Associated Mortality November 13,                                               protective equipment shortages than homes
     During the           2020                                                       located in the least vulnerable areas. In
     Coronavirus Disease                                                             addition, nursing homes located in the most
     2019 (COVID-19)                                                                 vulnerable areas had 1.6 times the number
     Pandemic in                                                                     of COVID-19 cases and 1.9 times the
     Michigan Skilled                                                                mortality rate compared to nursing homes
     Nursing Facilities”                                                             located in the least vulnerable areas.
20   “Nursing Home Staff   Chen, M. Keith,         –                      –         During the 11-week period from March 13,
     Networks and          Judith A.                                                 2020, to May 31, 2020, 5.1 percent of 50
     COVID-19”             Chevalier, and                                            million smartphone users who visited a
                           Elisa F. Long                                             nursing home for at least one hour also
                           Proceedings of                                            visited another nursing home and nursing
                           the National                                              homes, on average, shared connections with
                           Academy of                                                an estimated 7.1 other homes. Comparing
                           Sciences                                                  demographically and geographically situated
                                                                                     nursing homes of similar quality suggested
                           December 28,                                              that 49 percent of nursing home COVID-19
                           2020                                                      cases were attributable to shared staff
                                                                                     transmitting the virus across multiple nursing
                                                                                     homes.




                                         Page 35                               GAO-23-104291 Nursing Home COVID-19 Outbreaks
                                             Appendix I: Literature Review—Methodology
                                             Description and Results




                                                   Methodological focus of study
                                                Factors                    Factors
                                              associated        Factors associated
                                                with the      associated with the
                                               presence         with the   duration
                                              of COVID-       severity of of COVID-
                             Authors               19          COVID-19       19
                                              outbreaks       outbreaks outbreaks
                             Journal          in nursing      in nursing in nursing
     Title                   Publication date   homes           homes       homes   Summary of key findings
21   “Compress the           Gopal, Ram, Xu                                  –         For California nursing homes as of May 1,
     Curve: A Cross-         Han, and Niam                                               2020, the size of COVID-19 outbreaks
     Sectional Study of      Yaraghi                                                     among residents in for-profit nursing homes
     Variations in COVID-    BMJ Open                                                    was 12.7 times larger than their non-profit
     19 Infections across                                                                counterparts. Higher star ratings for health
     California Nursing      January 6, 2021                                             inspections were associated with a lower
     Homes”                                                                              number of infections among both staff and
                                                                                         residents and higher star ratings for staffing
                                                                                         were associated with a lower number of
                                                                                         infections among residents. Conversely,
                                                                                         higher star ratings for quality measures were
                                                                                         associated with a higher number of infections
                                                                                         among staff and residents.
22   “Factors Associated     Gorges, Rebecca           –                      –         As of September 13, 2020, nursing homes in
     with Racial             J. and R. Tamara                                            which more than 40 percent of residents
     Differences in          Konetzka                                                    were non-White experienced case and death
     Deaths Among            JAMA Network                                                counts that were 3.3-fold higher than those
     Nursing Home            Open                                                        of nursing homes with low proportions of
     Residents with                                                                      non-White residents. These differences in
     COVID-19 Infection      February 10,                                                resident deaths by race were associated with
     in the U.S.”            2021                                                        nursing home size and community-level
                                                                                         outbreak severity, but not with aggregate
                                                                                         health status of residents or other nursing
                                                                                         home characteristics.
23   “Nontraditional Small   Zimmerman,                –                      –         Green House and other small nursing home
     House Nursing           Sheryl et al.                                               models are considered nontraditional due to
     Homes Have Fewer        JAMDA                                                       their size (10-12 beds), universal caregivers,
     COVID-19 Cases                                                                      and other home-like features. From January
     and Deaths”             March 2021                                                  20, 2020, through July 31, 2020, 219 Green
                                                                                         House and other similar small nursing homes
                                                                                         located in 20 states had lower COVID-19
                                                                                         incidence and mortality rates compared to
                                                                                         392 geographically proximate traditional
                                                                                         nursing homes, especially among the higher
                                                                                         and extreme values.
24   “Predicting COVID-      Poltavskiy,                          –           –         As of May 31, 2020, publicly reported
     19 at Skilled Nursing   Eduard et al.                                               nursing home metrics were associated with
     Facilities in           BMJ Open                                                    COVID-19 presence in California nursing
     California: Do the      Quality                                                     homes. Specifically, nursing home health
     Stars Align?”                                                                       inspection star ratings, emergency room
                             March 3, 2021                                               visits, and short-stay hospitalizations were
                                                                                         significantly associated with nursing homes
                                                                                         reporting COVID-19 cases.




                                             Page 36                               GAO-23-104291 Nursing Home COVID-19 Outbreaks
                                            Appendix I: Literature Review—Methodology
                                            Description and Results




                                                  Methodological focus of study
                                                Factors                   Factors
                                              associated       Factors associated
                                                with the     associated with the
                                               presence        with the   duration
                                              of COVID-      severity of of COVID-
                             Authors               19         COVID-19       19
                                              outbreaks      outbreaks outbreaks
                             Journal          in nursing     in nursing in nursing
     Title                   Publication date   homes          homes       homes   Summary of key findings
25   “High-Minority          Weech-                   –                      –         As of October 25, 2020, nursing homes with
     Nursing Homes           Maldonado,                                                 a high percentage of minority residents
     Disproportionately      Robert et al.                                              reported 6.5 COVID-19 deaths as compared
     Affected by COVID-      Frontiers in                                               to 2.6 deaths for nursing homes that had no
     19 Deaths”              Public Health                                              racial or ethnic minorities. After controlling for
                                                                                        interstate differences, facility-level resident
                             March 22, 2021                                             characteristics, resource availability, and
                                                                                        organizational characteristics, nursing homes
                                                                                        with a high percentage of minority residents
                                                                                        had 61 percent more COVID-19 deaths as
                                                                                        compared to nursing homes with no
                                                                                        minorities.
26   “Assessment of          Travers, Jasmine         –                      –         From January 20, 2020, through July 19,
     Coronavirus Disease     L. et al.                                                  2020, nursing homes with any Black
     2019 Infection and      JAMDA                                                      residents showed significantly more COVID-
     Mortality Rates                                                                    19 infections and deaths than nursing homes
     among Nursing           April 2021                                                 with no Black residents. There were 13.6
     Homes with Different                                                               percentage points more infections and 3.5
     Proportions of Black                                                               percentage points more deaths in nursing
     Residents”                                                                         homes with 50 percent or greater Black
                                                                                        residents than in nursing homes with no
                                                                                        Black residents. Although facility
                                                                                        characteristics explained some of the
                                                                                        differences found in multivariable analyses,
                                                                                        county-level factors and rurality explained
                                                                                        more of the differences.
27   “Short-Term Impact      Mor, Vincent et          –                      –         Two hundred and eighty nursing homes in 21
     of Nursing Home         al.                                                        states owned and operated by Genesis
     SARS-CoV-2              Journal of the                                             Healthcare were divided into two COVID-19
     Vaccinations on New     American                                                   vaccination groups based on the date the
     Infections,             Geriatrics Society                                         nursing home had its initial vaccine clinic—
     Hospitalizations, and                                                              early vaccination group (December 18, 2020,
     Deaths”                 April 16, 2021                                             through January 2, 2021) and late
                                                                                        vaccination group (January 3, 2021, through
                                                                                        January 18, 2021). After 1 week, early
                                                                                        vaccinated nursing homes had a predicted
                                                                                        2.5 fewer incident COVID-19 infections per
                                                                                        100 at-risk residents per week compared
                                                                                        with what would have been expected based
                                                                                        on the experience of the late vaccinated
                                                                                        nursing homes. The rates remained
                                                                                        significantly lower for several weeks.




                                            Page 37                               GAO-23-104291 Nursing Home COVID-19 Outbreaks
                                              Appendix I: Literature Review—Methodology
                                              Description and Results




                                                    Methodological focus of study
                                                Factors                     Factors
                                              associated         Factors associated
                                                with the       associated with the
                                               presence          with the   duration
                                              of COVID-        severity of of COVID-
                             Authors               19           COVID-19       19
                                              outbreaks        outbreaks outbreaks
                             Journal          in nursing       in nursing in nursing
     Title                   Publication date   homes            homes       homes   Summary of key findings
28   “SARS-CoV-2 in          Ehrlich, Hanna Y.          –                      –         The Connecticut Department of Public
     Nursing Homes after     et al.                                                       Health began point prevalence survey testing
     3 Months of Serial,     Emerging                                                     in nursing homes in early May 2020, and this
     Faciltywide Point       Infectious                                                   type of testing was formally recommended
     Prevalence Testing,     Diseases                                                     on May 11, 2020, and mandated weekly in
     Connecticut, USA”                                                                    staff effective June 14, 2020. The state
                             May 2021                                                     initially prioritized a subset of 34 Connecticut
                                                                                          nursing homes to receive test kits and these
                                                                                          nursing homes performed their first round of
                                                                                          testing on or before May 20, 2020. After
                                                                                          adjusting for community incidence of COVID-
                                                                                          19, the implementation of serial point
                                                                                          prevalence survey testing in the 34 nursing
                                                                                          homes was associated with a significant
                                                                                          decrease in nursing home COVID-19
                                                                                          incidence rates compared to the pre-
                                                                                          implementation period.
29   “Shifting US Patterns   Kumar, Amit et             –                      –         During the first 6 weeks of a 30-week study
     of COVID-19             al.                                                          period, which started on June 1, 2020,
     Mortality by Race       JAMDA                                                        nursing homes with a higher proportion of
     and Ethnicity from                                                                   Black residents reported more COVID-19
     June-December           May 2021                                                     deaths per 1,000 followed by nursing homes
     2020”                                                                                with a higher proportion of Hispanic
                                                                                          residents. Between 7 and 12 weeks, nursing
                                                                                          homes with a higher proportion of Hispanic
                                                                                          residents reported more deaths per 1,000,
                                                                                          followed by nursing homes with a higher
                                                                                          proportion of Black residents. However, after
                                                                                          23 weeks (mid-November 2020), nursing
                                                                                          homes serving a higher proportion of White
                                                                                          residents reported more deaths per 1,000
                                                                                          than nursing homes serving a high
                                                                                          proportion of Black and Hispanic residents.




                                              Page 38                               GAO-23-104291 Nursing Home COVID-19 Outbreaks
                                          Appendix I: Literature Review—Methodology
                                          Description and Results




                                                Methodological focus of study
                                              Factors                   Factors
                                            associated       Factors associated
                                              with the     associated with the
                                             presence        with the   duration
                                            of COVID-      severity of of COVID-
                           Authors               19         COVID-19       19
                                            outbreaks      outbreaks outbreaks
                           Journal          in nursing     in nursing in nursing
     Title                 Publication date   homes          homes       homes   Summary of key findings
30   “Characteristics of   Ryskina, Kira L.         –                      –         From March to August 2020, after
     Nursing Homes by      et al.                                                     accounting for local COVID-19 prevalence,
     COVID-19 Cases        JAMDA                                                      nursing homes in the highest quartile of
     Among Staff: March                                                               confirmed resident cases reported 18.9 more
     to August 2020”       May 2021                                                   staff cases per 100 beds compared with
                                                                                      nursing homes that had no resident cases.
                                                                                      Large nursing homes (150 or more beds)
                                                                                      reported 2.6 fewer staff cases per 100 beds
                                                                                      compared with small nursing homes (<50
                                                                                      beds) and for-profit nursing homes reported
                                                                                      0.8 fewer staff cases per 100 beds compared
                                                                                      with nonprofit nursing homes. Higher
                                                                                      occupancy and more direct-care hours per
                                                                                      day were associated with more staff cases.
                                                                                      Estimates associated with resident
                                                                                      demographics, payer mix, or regional
                                                                                      socioeconomic characteristics were not
                                                                                      statistically significant.
31   “The BNT162b2         Domi, Marsida et         –                      –         Dividing the 2,501 nursing homes from the
     Vaccine Is            al.                                                        first 17 states to hold vaccine clinics into
     Associated with       Journal of the                                             three groups—vaccine clinic ending the
     Lower New COVID-      American                                                   week of December 27, 2020 (cohort 1),
     19 Cases in Nursing   Geriatrics Society                                         January 3, 2021 (cohort 2), or January 10,
     Home Residents and                                                               2021 (cohort 3)—found that resident and
     Staff”                May 6, 2021                                                staff cases trended downward in all three
                                                                                      cohorts following the vaccine clinic. Time
                                                                                      following the first clinic at 5 and 6 weeks was
                                                                                      consistently associated with fewer resident
                                                                                      cases, resident deaths, and staff cases.
                                                                                      Other factors associated with fewer resident
                                                                                      and staff cases included facilities with less
                                                                                      than 50 beds and high nurse staffing per
                                                                                      resident day. Higher Hispanic non-White
                                                                                      resident census was associated with fewer
                                                                                      resident cases and deaths.




                                          Page 39                               GAO-23-104291 Nursing Home COVID-19 Outbreaks
                                          Appendix I: Literature Review—Methodology
                                          Description and Results




                                                Methodological focus of study
                                              Factors                   Factors
                                            associated       Factors associated
                                              with the     associated with the
                                             presence        with the   duration
                                            of COVID-      severity of of COVID-
                           Authors               19         COVID-19       19
                                            outbreaks      outbreaks outbreaks
                           Journal          in nursing     in nursing in nursing
     Title                 Publication date   homes          homes       homes   Summary of key findings
32   “Trends in COVID-19   Gilman, Matlin           –                      –         From May 25, 2020 to April 18, 2021, death
     Death Rates by        and Mary T.                                                rates in nursing homes categorized into the
     Racial Composition    Bassett                                                    highest and lowest quintiles of White
     of Nursing Homes”     Journal of the                                             residents varied over time. Specifically, high-
                           American                                                   White quintile nursing homes initially had a
                           Geriatrics Society                                         lower death rate than low-White quintile
                                                                                      nursing homes. However, by late December
                           May 15, 2021                                               2020, high-White quintile nursing homes had
                                                                                      experienced 3 months of higher community
                                                                                      spread and its death rate had increased to
                                                                                      nearly three times that of low-White quintile
                                                                                      nursing homes. Through the first few months
                                                                                      of 2021, death rates declined substantially
                                                                                      for both groups of nursing homes, but,
                                                                                      overall, high-White quintile nursing homes
                                                                                      had more total deaths than low-White quintile
                                                                                      nursing homes despite having fewer beds
                                                                                      and higher star ratings.
33   “The Association of   Williams,                –                               As of January 10, 2021, higher nursing home
     Nursing Home          Christianna S. et                                          quality ratings were associated with COVID-
     Quality Ratings and   al.                                                        19 incidence and mortality, as well as with
     Spread of COVID-      Journal of the                                             fewer high-incidence weeks, after controlling
     19”                   American                                                   for local community COVID-19 spread and
                           Geriatrics Society                                         relevant facility-level factors. For example,
                                                                                      nursing homes with a lower overall rating
                           May 31, 2021                                               (one- to three-stars) had about 10 percent
                                                                                      more weeks with high COVID-19 incidence
                                                                                      than the highest (five-star) rated homes, and
                                                                                      nursing homes with an overall star rating of
                                                                                      one- to three-stars also had about 13 to 16
                                                                                      percent higher incidence and 8 to 10 percent
                                                                                      higher cumulative COVID-19 mortality than
                                                                                      five-star homes. Higher county COVID-19
                                                                                      incidence was also strongly and consistently
                                                                                      associated with higher nursing home COVID-
                                                                                      19 incidence and mortality, as well as
                                                                                      number of high-incidence weeks.




                                          Page 40                               GAO-23-104291 Nursing Home COVID-19 Outbreaks
                                          Appendix I: Literature Review—Methodology
                                          Description and Results




                                                Methodological focus of study
                                               Factors                  Factors
                                             associated      Factors associated
                                               with the    associated with the
                                              presence       with the   duration
                                             of COVID-     severity of of COVID-
                            Authors               19        COVID-19       19
                                             outbreaks     outbreaks outbreaks
                            Journal          in nursing    in nursing in nursing
     Title                  Publication date   homes         homes       homes   Summary of key findings
34   “Trends in Racial and Li, Yue et al.           –                      –         From April 13, 2020, through June 19, 2020,
     Ethnic Disparities in Infection Control                                          Connecticut nursing homes caring for
     Coronavirus Disease & Hospital                                                   predominately racial and ethnic minority
     2019 (COVID-19)       Epidemiology                                               residents tended to have higher COVID-19
     Outcomes among                                                                   incidence and fatality rates. Specifically,
     Nursing Home          June 16, 2021                                              compared to nursing homes with a low
     Residents”                                                                       proportion of racial and ethnic minority
                                                                                      residents, the adjusted COVID-19 incidence
                                                                                      rate ratios for the nursing homes with a high
                                                                                      proportion of racial and ethnic minority
                                                                                      residents were 1.18 in week 1 of the study
                                                                                      period and 1.54 in week 10, showing a 30
                                                                                      percent relative increase. Adjusted
                                                                                      disparities in COVID-19 fatalities similarly
                                                                                      increased over time.
35   “COVID-19 Cases        Cai, Shubing, Di                   –           –         From June 7, 2020, through August 23,
     and Death in Nursing   Yan, and Orna                                             2020, the racial and ethnic composition of
     Homes: The Role of     Intrator                                                  nursing homes and their communities were
     Racial and Ethnic      JAMDA                                                     both associated with the likelihood of having
     Composition of                                                                   COVID-19 cases and death in nursing
     Facilities and Their   July 2021                                                 homes. The racial and ethnic composition of
     Communities”                                                                     the community played an independent role in
                                                                                      the likelihood of COVID-19 cases and death
                                                                                      in nursing homes, even after accounting for
                                                                                      the COVID-19 infection rate in the
                                                                                      community. In addition, the relationship
                                                                                      between nursing home characteristics and
                                                                                      the probability of COVID-19 cases or death
                                                                                      varied with the racial and ethnic composition
                                                                                      of the community. For example, although an
                                                                                      hour increase in registered nurse hours per
                                                                                      resident per day was associated with 2.8
                                                                                      percentage point reduction in the probability
                                                                                      of COVID-19 cases in nursing homes located
                                                                                      in high-minority communities, such
                                                                                      relationship was smaller in low-minority
                                                                                      communities.




                                          Page 41                               GAO-23-104291 Nursing Home COVID-19 Outbreaks
                                           Appendix I: Literature Review—Methodology
                                           Description and Results




                                                 Methodological focus of study
                                               Factors                   Factors
                                             associated       Factors associated
                                               with the     associated with the
                                              presence        with the   duration
                                             of COVID-      severity of of COVID-
                            Authors               19         COVID-19       19
                                             outbreaks      outbreaks outbreaks
                            Journal          in nursing     in nursing in nursing
     Title                  Publication date   homes          homes       homes   Summary of key findings
36   “Larger Nursing        McGarry, Brian           –                      –         From June 7, 2020, through September 27,
     Home Staff Size        E. et al.                                                  2020, sample nursing homes (7,154 nursing
     Linked to Higher       Health Affairs                                             homes without resident COVID-19 cases by
     Number of COVID-                                                                  the start of the study period) in the lowest
     19 Cases in 2020”      August 2021                                                quartile of staff size had 6.2 resident cases
                                                                                       and 0.9 deaths per 100 beds, compared with
                                                                                       11.9 resident cases and 2.1 deaths per 100
                                                                                       beds among nursing homes in the highest
                                                                                       quartile. Staff size, including staff members
                                                                                       not involved in resident care, was strongly
                                                                                       associated with COVID-19 outcomes, even
                                                                                       after nursing home size was accounted for.
                                                                                       Staffing quality measures, including direct
                                                                                       care staff-to-resident ratios and skill mix,
                                                                                       were not significant predictors of COVID-19
                                                                                       cases or deaths.
37   “Interpreting COVID-   Das Gupta,                                     –         From June 1, 2020, through January 31,
     19 Deaths among        Debasree et al.                                            2021, nursing homes with a higher overall
     Nursing Home           PLOS ONE                                                   quality rating were associated with lower
     Residents in the US:                                                              rates of COVID-19 deaths. However, this
     The Changing Role      September 1,                                               association diminished over the study period.
     of Facility Quality    2021                                                       In addition, the duration of self-reported staff
     Over Time”                                                                        shortages by nursing homes were
                                                                                       associated with COVID-19 mortality rates
                                                                                       and the adverse role of staff shortages did
                                                                                       not change over the study period. Nursing
                                                                                       home ownership and shortage of personal
                                                                                       protective equipment were not associated
                                                                                       with COVID-19 mortality at any point during
                                                                                       the study period, but community level
                                                                                       variables (such as local COVID-19 death
                                                                                       rate) were significant determinants of nursing
                                                                                       home mortality outcomes.
38   “State Social          Li, Yue et al.                                 –         From June to August 2020, stronger state
     Distancing             Scientific Reports                                         social distancing measures were associated
     Restrictions and                                                                  with lower weekly rates of new COVID-19
     Nursing Home           January 20, 2022                                           confirmed cases and related deaths among
     Outcomes”                                                                         nursing home residents, as well as lower
                                                                                       weekly COVID-19 new confirmed case rate
                                                                                       among nursing home staff. The magnitude of
                                                                                       these associations was larger for nursing
                                                                                       homes serving disproportionately more racial
                                                                                       and ethnic minority residents.




                                           Page 42                               GAO-23-104291 Nursing Home COVID-19 Outbreaks
                                                       Appendix I: Literature Review—Methodology
                                                       Description and Results




                                                               Methodological focus of study
                                                          Factors                       Factors
                                                        associated           Factors associated
                                                          with the         associated with the
                                                         presence            with the   duration
                                                        of COVID-          severity of of COVID-
                                       Authors               19             COVID-19       19
                                                        outbreaks          outbreaks outbreaks
                                       Journal          in nursing         in nursing in nursing
         Title                         Publication date   homes              homes       homes   Summary of key findings
39       “Nursing Home                 Cronin,                    –                            –         From the start of the pandemic through
         Quality, COVID-19             Christopher J.                                                     September 13, 2020, a nursing home’s
         Deaths, and Excess            and William N.                                                     overall five-star rating was highly predictive
         Mortality”                    Evans                                                              of COVID-19 mortality, with five-star nursing
                                       Journal of Health                                                  homes having 15 percent fewer resident
                                       Economics                                                          COVID-19 deaths than one-star nursing
                                                                                                          homes. This relationship between quality and
                                       January 21, 2022                                                   COVID-19 deaths did not continue after
                                                                                                          September 13, 2020, through April 25, 2021.
                                                                                                          Conversely, higher-quality nursing homes
                                                                                                          had much higher non-COVID-19 mortality,
                                                                                                          with five-star nursing homes experiencing
                                                                                                          11.4 percent more non-COVID-19 deaths
                                                                                                          than one-star homes as of September 13,
                                                                                                          2020. This relationship strengthened over
                                                                                                          time through April 2021.
40       “Firm Finances and  Begley, Taylor A.,                   –                            –         For a sample of 7,045 nursing homes, as of
         the Spread of       and Daniel                                                                   October 18, 2020, those nursing homes with
         COVID-19: Evidence Weagley                                                                       less liquidity and those experiencing more
         from Nursing Homes” SSRN                                                                         severe cash flow shocks had more cases of
                                                                                                          COVID-19. For example, increased Medicaid
                                       July 28, 2022                                                      nursing home reimbursement rates was
                                                                                                          associated with much lower rates of COVID-
                                                                                                          19 and the difference was largest for nursing
                                                                                                          homes with the highest share of Medicaid
                                                                                                          residents.
Source: Studies GAO reviewed. │GAO-23-104291

                                                       Notes: We selected studies for inclusion in our review if they used data to examine the association of
                                                       any factor with COVID-19 outbreaks in U.S. nursing homes.
                                                       Studies listed in the table used nationwide data except where specific states are indicated in the
                                                       summary.




                                                       Page 43                                       GAO-23-104291 Nursing Home COVID-19 Outbreaks
Appendix II: Detailed Description of
                        Appendix II: Detailed Description of
                        Methodology for Multivariate Statistical Models


Methodology for Multivariate Statistical
Models
                        This appendix describes our methods for analyzing how certain nursing
                        home factors were associated with the duration of COVID-19 outbreaks.
                        To do this, we used Centers for Disease Control and Prevention (CDC),
                        Centers for Medicare & Medicaid Services (CMS), and Health Resources
                        and Services Administration data to develop Cox proportional hazard
                        statistical models, which simultaneously evaluate the association between
                        many factors on the probability of a specified outcome and the
                        significance of the relationship. Specifically, our models estimated the
                        probability of an outbreak ending at any given week from June 14, 2020,
                        through January 2, 2022, controlling for a host of factors, such as nursing
                        home characteristics and levels of COVID-19 in the surrounding
                        community, among others. The following describes our definitions, data
                        sources, and methodology.

CDC COVID-19 Nursing    We used CDC’s COVID-19 nursing home data as the foundation for our
Home Data               statistical model. CDC collects weekly nursing home-level COVID-19
                        information, including cases, deaths, and shortages of staff and supplies,
                        from all Medicare- or Medicaid-certified nursing homes. 1 We analyzed the
                        data for the week ending June 14, 2020, through the week ending
                        January 2, 2022, the last full week of the 2021 calendar year. CMS began
                        requiring nursing homes to report COVID-19 data to CDC in May 2020.
                        Reporting information retroactively to the beginning of the pandemic was
                        voluntary and the data do not clearly distinguish between nursing homes
                        that opted to report information prior to this time and those that did not.
                        Therefore, we started our analysis with data for the week ending June 14,
                        2020, and excluded data from the first 3 weeks of reporting because
                        these data contained information from multiple weeks dating back to
                        February 2020.

COVID-19 Outbreaks in   According to CDC, a COVID-19 outbreak starts the week a nursing home
Nursing Homes           reports a new COVID-19 case in a resident or staff member and ends
                        when the nursing home has 2 consecutive weeks (not included in the
                        outbreak duration) where they report no new staff or resident cases. 2
                        Using this definition of an outbreak, we analyzed CDC’s COVID-19

                        1The CDC data on COVID-19 in nursing homes were accessed on May 12, 2022, for the
                        week ending May 1, 2022, from https://data.cms.gov/covid-19/covid-19-nursing-home-
                        data. Nursing homes report aggregate data to CDC on a weekly basis. According to CDC,
                        data used in this analysis are part of a live data set, meaning that facilities can correct the
                        data at any time.
                        2See Centers for Disease Control and Prevention, Interim Infection Prevention and
                        Control Recommendations to Prevent SARS-CoV-2 Spread in Nursing Homes, accessed
                        September 7, 2022, https://www.cdc.gov/coronavirus/2019-ncov/hcp/long-term-care.html.




                        Page 44                                   GAO-23-104291 Nursing Home COVID-19 Outbreaks
                               Appendix II: Detailed Description of
                               Methodology for Multivariate Statistical Models




                               nursing home data for descriptive statistics, including the number and
                               duration of nursing home outbreaks each nursing home experienced.

                               From June 14, 2020, through January 2, 2022, 15,281 nursing homes
                               reported data to CDC and we found that those homes had a total of
                               102,992 outbreaks. Nursing homes had an average of 7.6 outbreaks and
                               a median of eight outbreaks (2,435 nursing homes) over the review
                               period, ranging from zero (25 nursing homes) to 16 (one nursing home)
                               outbreaks. Forty-two percent of the outbreaks (43,753 of 102,992
                               outbreaks) lasted 1 week, with outbreak duration averaging 4 weeks
                               (6,316 outbreaks) and ranging to 53 weeks (one outbreak).

Other Data Sources             We used additional data sources to create measures of independent
                               variables for the regression analysis. In order to understand our universe
                               of nursing homes, we examined the descriptive information for each
                               variable.

Nursing Home Characteristics   CMS’s publicly available nursing home provider information file contains
                               information on a number of characteristics, such as number of beds and
                               non-profit or for-profit status, of nursing homes certified to participate in
                               Medicare or Medicaid. 3 This file contained information on 15,622 nursing
                               homes during our period of review. To determine whether a nursing home
                               was located in a metropolitan or micropolitan core based statistical area,
                               or neither, we merged the provider information file with Health Resources
                               and Services Administration’s publicly available county-level Area Health
                               Resources Files. 4 Using the merged file, we examined the breakdown of
                               all Medicare- and Medicaid-certified nursing homes by facility
                               characteristic for all categorical variables. (See table 3). In addition, for
                               two continuous variables, we calculated the average across all nursing



                               3The CMS publicly available nursing home provider information files were accessed on
                               July 22, 2022, from https://data.cms.gov/provider-data/dataset/4pq5-n9py.
                               4The Health Resources and Services Administration publicly available 2020 and 2021
                               Area Health Resources Files (county-level data) were accessed on July 22, 2022, from
                               https://data.hrsa.gov/data/download.

                               The Health Resources and Services Administration defines core based statistical areas as
                               the following: (a) Metropolitan—at least one urbanized area of 50,000 or more population
                               plus adjacent territory that has a high degree of social and economic integration with the
                               core as measured by commuting ties; and (b) Micropolitan—at least one urban cluster of
                               at least 10,000 but less than 50,000 population, plus adjacent territory that has a high
                               degree of social and economic integration with the core as measured by commuting ties.
                               We categorized all counties that did not meet the prior two criteria as rural.




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homes, finding that nursing homes had an average of 106 beds and an
average of 78 residents during our period of review.

Table 3: Nursing Home Facility Characteristics, Categorical Variables, June 14,
2020, through January 2, 2022

                                                  Number of nursing     Percentage of
Nursing home facility characteristics             homes (n = 15,622)   nursing homes
Ownership type
     For-profit                                              10,651               68.2
     Nonprofit                                                3,384               21.7
     Government-owned                                           834                5.3
     Mixed ownershipa                                           753                4.8
Certification type
     Medicare-only                                              667                4.3
     Medicaid-only                                              348                2.2
     Medicare and Medicaid                                   14,606               93.5
Facility type
     Hospital-based                                             699                4.5
     Freestanding                                            14,923               95.6
Location typeb
     Metropolitan                                            11,297               72.3
     Micropolitan                                             2,144               13.7
     Rural                                                    2,173               13.9
     Transitioning area                                           5                  0
Change of ownership in last 12 months
     Home had a change of ownership                           1,128                7.2
     Home did not have a change of                           14,494               92.8
     ownership
Average number of Medicare- and Medicaid-certified beds
     Less than 50 beds                                        1,946               12.5
     50 to 99 beds                                            5,948               38.1
     100 to 199 beds                                          6,834               43.8
     200 or more beds                                           894                5.7
Special Focus Facility statusc
     Special Focus Facility                                      68                0.4
     Special Focus Facility candidate                           975                6.2
     Both Special Focus Facility home and                       101                0.6
     candidate




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                                                                 Number of nursing                        Percentage of
 Nursing home facility characteristics                           homes (n = 15,622)                      nursing homes
       Not a Special Focus Facility or                                              14,478                                92.7
       candidate
 Continuing care residential communityd
       Continuing care residential                                                    1,872                               12.0
       community
       Not a continuing care residential                                            13,750                                88.0
       community
 Resident and family councilse
       Resident council only                                                        11,601                                74.3
       Family council only                                                                28                               0.2
       Both resident and family councils                                              3,481                               22.3
       Separate resident council and family                                               18                               0.1
       council
       No resident or family councils                                                    494                               3.2
 Overall Five-Star ratingf
       Average rating of four or five stars                                           5,420                               34.7
       Average rating of three stars                                                  3,308                               21.2
       Average rating of one or two stars                                             6,894                               44.1
 Health inspections Five-Star ratingf
       Average rating of four or five stars                                           3,739                               23.9
       Average rating of three stars                                                  3,645                               23.3
       Average rating of one or two stars                                             8,238                               52.7
 Staffing Five-Star ratingf
       Average rating of four or five stars                                           3,571                               22.9
       Average rating of three stars                                                  4,326                               27.7
       Average rating of one or two stars                                             7,725                               49.5
 Quality measure Five-Star ratingf
       Average rating of four or five stars                                           7,371                               47.2
       Average rating of three stars                                                  4,096                               26.2
       Average rating of one or two stars                                             4,155                               26.6
Source: GAO analysis of Centers for Medicare & Medicaid Services data and the Health Resources and Services Administrations’ Area
Health Resources Files. │GAO-23-104291

Notes: Percentages do not always add to 100 due to missing data and rounding. The percentage of
nursing homes with missing data, if any, was less than 1 percent for each category.
a
 ”Mixed ownership” refers to nursing homes that changed their ownership type at any point over the
period of review.
b
 The Health Resources and Services Administration defines core based statistical areas as the
following: (a) Metropolitan—at least one urbanized area of 50,000 or more population plus adjacent
territory that has a high degree of social and economic integration with the core as measured by
commuting ties; and (b) Micropolitan—at least one urban cluster of at least 10,000 but less than
50,000 population, plus adjacent territory that has a high degree of social and economic integration




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                           with the core as measured by commuting ties. We categorized all counties that did not meet the prior
                           two criteria as rural. In addition, we considered a “transitioning area” to be a county where the
                           statistical area designation changed at some point during the period of review.
                           c
                             Nursing homes with chronic noncompliance with federal standards can be selected for the Special
                           Focus Facility program, which requires state survey agencies to conduct more frequent oversight and
                           the nursing homes to improve performance or risk termination from the Medicare and Medicaid
                           programs.
                           d
                            Continuing care resident communities offer multiple housing options and levels of care. A nursing
                           home is typically the most service-intensive housing option. Residents may move from one level to
                           another based on their particular needs, while typically still remaining in the community.
                           e
                            Resident and family councils are usually organized and managed by nursing home residents or the
                           residents’ families to address concerns and improve the quality of care and life for the resident.
                           The Five-Star Quality Rating System assigns each nursing home participating in the Medicare or
                           f

                           Medicaid programs an overall “star” rating, ranging from one to five. Nursing homes with five stars are
                           considered to have much above average quality, while nursing homes receiving one star are
                           considered to have much below average quality. Calculation of the overall star rating is based on
                           separate ratings that nursing homes receive for each of three components: health inspections,
                           staffing, and quality measures. We calculated the average overall and component ratings for each
                           nursing home during our period of review.


Nursing Home History of    CMS maintains data on nursing home surveys and deficiencies, including
Infection Prevention and   the dates of surveys and the number and type of deficiencies cited. 5 To
Control Deficiencies       determine the number of infection prevention and control deficiencies
                           each nursing home received and the average number of these
                           deficiencies cited per nursing home, we merged three different CMS
                           datasets—the Certification and Survey Provider Enhanced Reports
                           system data, the publicly available nursing home inspection dates file,
                           and the publicly available nursing home health citations file. 6 (See table

                           5In general, CMS requires that state survey agencies conduct standard surveys, or
                           evaluations, approximately once each year of the state’s nursing homes and investigate
                           both complaints from the public and facility-reported incidents regarding resident care or
                           safety. Beginning in March 2020, CMS required state survey agencies to conduct focused
                           infection control surveys, a new type of survey in response to the pandemic with a
                           narrower scope than a standard survey. State survey agencies are required to perform
                           focused infection control surveys for 20 percent of nursing homes in their state annually,
                           prioritizing those facilities that report new COVID-19 cases and low vaccination rates. If a
                           surveyor from a state survey agency determines that a nursing home violated a federal
                           standard during a survey or investigation, a nursing home receives a deficiency code
                           specific to that standard, known as a deficiency.
                           6For this analysis, we analyzed the deficiency code F-880 for nursing homes that were
                           cited for not meeting federal standards for establishing and maintaining an infection
                           prevention and control program. This code went into effect as part of CMS’s restructuring
                           of its deficiency codes on November 28, 2017, replacing a prior deficiency code that had
                           been in effect for several years. For infection prevention and control deficiencies cited in
                           2017 prior to this restructuring, we used the prior code.

                           The CMS publicly available nursing home survey dates files were accessed on March 28,
                           2022, from https://data.cms.gov/provider-data/dataset/svdt-c123. The publicly available
                           nursing home health citations files were accessed on April 12, 2022, from
                           https://data.cms.gov/provider-data/dataset/r5ix-sfxw.




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                        4.) These files contained information on 13,614 nursing homes with
                        deficiencies in 2017 and 12,343 nursing homes with deficiencies in 2021.

                        Table 4: Infection Prevention and Control Deficiencies Cited in Nursing Homes, by
                        Year, 2017 through 2021

                                                                                 Total number of          Average infection
                                                     Number of               infection prevention    prevention and control
                                                       surveyed                       and control deficiencies per surveyed
                         Year                    nursing homes                       deficiencies             nursing home
                         2017                                14,184                                6,527                 0.5
                         2018                                14,594                                6,874                 0.5
                         2019                                14,776                                6,913                 0.5
                         2020                                15,406                                9,775                 0.6
                         2021                                14,128                                6,738                 0.5
                        Source: GAO analysis of Centers for Medicare & Medicaid Services data. │GAO-23-104291



Nursing Home Staffing   CMS’s payroll-based journal collects employee-level payroll information
                        for various types of nursing home staff, including registered nurses,
                        licensed practical nurses, and nurse aides, from all Medicare- or
                        Medicaid-certified nursing homes. This dataset included information from
                        15,419 nursing homes during our period of review. 7 Using the payroll-
                        based journal data, we determined the daily staffing levels during our
                        period of review for the 32 types of staff CMS requires nursing homes to
                        report. 8 (See table 5.)




                        7According to CMS officials, 878 nursing homes had data issues outside of their control
                        from December 11, 2021, through December 31, 2021, possibly resulting in missing
                        payroll data for that time period. CMS provided us with a list of the affected nursing
                        homes, and 874 were in our database. We checked to see if those homes had staffing
                        levels consistent with projections based on prior month and prior year data and we
                        excluded any outbreaks that had incomplete data.
                        8Nursing homes must submit accurate information on direct-care staffing to CMS’s payroll-
                        based journal each quarter. This information must be based on payroll and other verifiable
                        and auditable data. CMS allows nursing homes to submit staffing information for 40
                        different types of staff, including both nurse staff and non-nurse staff. However, the
                        agency only requires reporting for the 32 types of direct-care staff. According to CMS, the
                        remaining eight types of staff (dentist, podiatrist, vocational service worker, clinical
                        laboratory service worker, diagnostic x-ray service worker, blood service worker,
                        housekeeping service worker, other service worker) are voluntary for nursing homes to
                        report because they either do not meet the definition of direct-care or are not paid by
                        nursing homes, so CMS could not audit their data. Due to concerns with the reliability of
                        the data for these eight types of staff, we did not include them in our analysis.




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Table 5: Nursing Home Average Daily Staffing Levels, June 14, 2020, through
January 2, 2022

                                   Minimum hours        Average hours Maximum hours
Type of staff                      worked per day       worked per day worked per day
Administrator                                     7.6             7.7              7.8
Medical director                                  2.6             2.9              3.3
Other physician                                   4.4             4.9              5.1
Physician assistant                               5.2             5.9              6.3
Registered nurse director of                      7.8             7.9              8.0
nursing
Registered nurse with                             7.7             7.7              7.8
administrative duties
Registered nurse                                  8.3             8.4              8.5
Licensed practical nurse with                     7.9             8.0              8.1
administrative duties
Licensed practical nurse                          8.5             8.6              8.7
Certified nurse aide                              7.8             7.9              8.0
Nurse aide in training                            7.3             7.6              7.8
Medication aide/technician                        8.3             8.5              8.6
Nurse practitioner                                5.7             6.0              6.1
Clinical nurse specialist                         7.1             7.5              7.8
Pharmacist                                        3.4             3.8              4.2
Dietitian                                         6.7             6.8              7.0
Paid feeding assistant                            6.9             7.1              7.3
Occupational therapist                            6.0             6.2              6.3
Occupational therapy                              6.2             6.4              6.5
assistant
Occupational therapy aide                         6.7             6.9              7.1
Physical therapist                                5.9             6.2              6.4
Physical therapy assistant                        6.2             6.4              6.5
Physical therapy aide                             6.6             6.7              6.8
Respiratory therapist                             8.1             8.4              8.5
Respiratory therapy                               8.1             8.5              8.8
technician
Speech/language pathologist                       5.1             5.5              5.7
Therapeutic recreation                            7.2             7.4              7.5
specialist
Qualified activities                              7.4             7.6              7.7
professional
Other activities staff                            7.0             7.1              7.2




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                                                                             Minimum hours               Average hours Maximum hours
                               Type of staff                                 worked per day              worked per day worked per day
                               Qualified social worker                                          7.6                     7.7         7.8
                               Other social worker                                              7.5                     7.6         7.7
                               Mental health service worker                                     7.0                     7.2         7.4
                              Source: GAO analysis of Centers for Medicare & Medicaid Services data. │GAO-23-104291

                              Note: The 32 staff types listed in the table are those CMS requires nursing homes to report to its
                              payroll-based journal.


Reported Nursing Home Staff   Using CDC’s COVID-19 nursing home data, discussed above, we
Shortages during the COVID-   determined the average number of weeks during our period of review that
19 Pandemic                   nursing homes reported facing staff shortages. (See table 6.) The dataset
                              included information reported from 15,466 nursing homes during our
                              period of review.

                              Table 6: Reported Nursing Home Staff Shortages during the COVID-19 Pandemic,
                              June 14, 2020, through January 2, 2022

                               Types of reported staffing shortages                                    Average number of weeks nursing
                                                                                                               homes reported shortage
                               Shortage of nursing staff                                                                           14.1
                               Shortage of clinical staff                                                                           1.8
                               Shortage of aides                                                                                   15.8
                               Shortage of other staff                                                                              8.0
                              Source: GAO analysis of Centers for Disease Control and Prevention data. │GAO-23-104291



Resident Demographics         CMS’s Minimum Data Set collects information on each resident’s
                              strengths and needs, as well as resident demographic information,
                              through regular comprehensive assessments conducted by all nursing
                              homes certified to participate in Medicare or Medicaid. 9 The dataset
                              included information for 15,416 nursing homes during our period of
                              review. Using admission, quarterly, and annual assessments in the
                              Minimum Data Set, we determined the average demographic makeup of
                              all Medicare- and Medicaid-certified nursing homes during our period of
                              review. (See table 7.) We also determined each nursing home’s case-

                              9The CMS Minimum Data Set is reported by nursing homes, which are required to
                              complete resident assessments at regular intervals as part of federal requirements to
                              participate in the Medicare and Medicaid programs. Nursing homes are required to
                              conduct resident assessments at entry, quarterly, at discharge, and if there are any
                              significant changes or corrections. During standard surveys, surveyors can evaluate
                              whether a nursing home’s assessments meet federal standards for accuracy.




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                              mix—that is, a numeric representation of the acuity of residents within a
                              nursing home—using CMS’s methodology. 10 We found that the total
                              average case-mix score in nursing homes was 43.8, ranging from 0.5 to
                              568.9.

                              Table 7: Nursing Home Resident Demographics, June 14, 2020, through January 2,
                              2022

                                                                                                          Percentage of residents within a
                               Nursing home resident demographics                                                           nursing home
                               Resident age
                                     Less than 50                                                                                      3.1
                                     50 to less than 65                                                                              13.7
                                     65 to less than 75                                                                              22.4
                                     75 to less than 85                                                                              30.0
                                     Greater than 85                                                                                 30.8
                               Resident gender
                                     Male                                                                                            40.9
                                     Female                                                                                          59.1
                               Resident race and ethnicity
                                     White                                                                                           75.1
                                     Black or African American                                                                       12.7
                                     Hispanic or Latino                                                                                5.1
                                     Asian                                                                                             1.8
                                     Native Hawaiian or Other Pacific                                                                  0.2
                                     Islander
                                     American Indian or Alaska Native                                                                  0.4
                                     Mixed ethnicity                                                                                   0.4
                                     Unknown                                                                                           4.7
                              Source: GAO analysis of Centers for Medicare & Medicaid Services data. │GAO-23-104291

                              Note: Percentages do not always add to 100 due to rounding.


Community Conditions during   CDC county-level COVID-19 community transmission data contain the
the COVID-19 Pandemic         daily levels of community transmission by county, known as community
                              spread. The dataset included information on 3,222 counties. Using this
                              data, we analyzed the number of weeks during our period of review that

                              10We used CMS’s methodology to calculate the numeric case-mix index value associated
                              with the resource utilization group obtained from non-therapy index maximizing
                              classification.




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                     the level of COVID-19 community spread in each county was categorized
                     by CDC as high, substantial, moderate, or low. 11 (See table 8.)

                     Table 8: Number of Weeks Counties Were Designated by CDC as Having High,
                     Substantial, Moderate, or Low Levels of Community Transmission of COVID-19,
                     June 14, 2020, through January 2, 2022

                                                                               Minimum                    Average          Maximum
                      CDC levels of community                                 number of                 number of          number of
                      spread                                                     weeks                     weeks              weeks
                      High                                                                  0                    50.0           80.4
                      Substantial                                                           0                    11.9           37.0
                      Moderate                                                              0                    13.4           41.7
                      Low                                                                   0                        6.7        82.0
                     Source: GAO analysis of Centers for Disease Control and Prevention (CDC) data. │GAO-23-104291

                     Note: CDC calculated the level of community transmission using two indicators: (1) the total new
                     cases per 100,000 persons within the last 7 days and (2) the percentage of positive diagnostic and
                     screening nucleic acid amplification tests during the last 7 days. If the two indicators suggest different
                     transmission levels, the higher level is selected. Possible transmission categories are high (counties
                     with 100 or more cumulative cases per 100,000 population or a cumulative test positivity result of
                     10.0 percent or higher in the past 7 days), substantial (counties with 50-99 cumulative cases per
                     100,000 population or a cumulative test positivity result between 8.0-9.9 percent in the past 7 days),
                     moderate (counties with 10-49 cumulative cases per 100,000 population or a cumulative test positivity
                     result between 5.0-7.9 percent in the past 7 days), or low (counties with fewer than 10 cumulative
                     cases per 100,000 population in the past 7 days and a cumulative percent test positivity result below
                     5 percent in the past 7 days).


Analyzing the Data   We merged the CDC COVID-19 nursing home data with the data sets
                     described in the sections above, creating a single analytic data file for our
                     study period of June 14, 2020, through January 2, 2022.

Exclusions           We merged the data using weekly COVID-19 outbreaks as our unit of
                     analysis. First, we excluded 117 nursing homes that had 50 weeks or
                     more of CDC COVID-19 nursing home data that was missing or did not
                     pass quality control. Second, we excluded 24 nursing homes that did not

                     11CDC calculated the level of community transmission using two indicators: (1) the total
                     new cases per 100,000 persons within the last 7 days and (2) the percentage of positive
                     diagnostic and screening nucleic acid amplification tests during the last 7 days. If the two
                     indicators suggest different transmission levels, the higher level is selected. Possible
                     transmission categories are high (counties with 100 or more cumulative cases per
                     100,000 population or a cumulative test positivity result of 10.0 percent or higher in the
                     past 7 days), substantial (counties with 50-99 cumulative cases per 100,000 population or
                     a cumulative test positivity result between 8.0-9.9 percent in the past 7 days), moderate
                     (counties with 10-49 cumulative cases per 100,000 population or a cumulative test
                     positivity result between 5.0-7.9 percent in the past 7 days), or low (counties with fewer
                     than 10 cumulative cases per 100,000 population in the past 7 days and a cumulative
                     percent test positivity result below 5 percent in the past 7 days).




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                          have data in CMS’s publicly available data files. This resulted in a total of
                          15,322 nursing homes with 100,780 outbreaks. Third, we excluded 4,632
                          outbreaks due to missing data in CMS’s Minimum Data Set, CMS’s
                          payroll-based journal, or both. All other data files were complete and did
                          not result in any exclusions. After these exclusions, our analytic file
                          included 15,091 nursing homes that had a total of 96,148 COVID-19
                          outbreaks.

Factors Not Included in   We could not control for all factors that may be associated with COVID-19
Analysis                  outbreak duration in nursing homes, often due to inconsistent data,
                          incomplete data, or a lack of data entirely. Some examples include the
                          following.

                          •   Equipment shortages. We have reported on the lack of COVID-19
                              tests and personal protective equipment in nursing homes, particularly
                              during the first year of the pandemic. 12 However, while CDC collected
                              information from nursing homes on these types of shortages in its
                              COVID-19 nursing home data, these variables were inconsistent
                              across our period of review. For example, after the week ending on
                              March 7, 2021, CDC removed questions related to whether nursing
                              homes had any supply or a one week supply of personal protective
                              equipment and added in similar, but slightly different questions,
                              making it difficult to track consistently over time.
                          •   Vaccination rates. The development and subsequent availability of
                              COVID-19 vaccines for nursing home residents and staff at the end of
                              2020 was an important milestone in the pandemic, which
                              corresponded with dramatic decreases in nursing home cases and
                              deaths through the first part of 2021. However, nationwide data on the
                              rate of vaccinations within each nursing home is incomplete—
                              reporting was not required until May 2021—so we could not include
                              these data as a variable in our regression. Instead, we ran two
                              separate models to account for the time period before the introduction
                              of vaccines and the time period after the introduction of vaccines. This
                              is explained further in the following section.
                          •   State and local policies. States and localities varied throughout the
                              pandemic on what, if any, COVID-19 policies, such as masking
                              requirements or the closure of non-essential businesses, they had in
                              place. However, even when policies were in place, we could not
                              quantify how well communities surrounding a nursing home enforced
                              or complied with the policies. Therefore, rather than assess the

                          12See GAO-20-701, 129; GAO-21-191, 67; and GAO-21-265, 63.




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                                    reliability of data on state and local COVID-19 policies, we assumed
                                    that analyzing the effect of transmission of COVID-19 in the county
                                    where each nursing home is located would reflect both the local
                                    policies and the community’s compliance with the policies.
                                •   Adherence to infection prevention and control practices. We
                                    have previously reported on the importance of infection prevention
                                    and control practices and CDC continues to emphasize the
                                    importance of rigorous infection prevention and control to prevent the
                                    spread of COVID-19 in nursing homes. 13 Because CMS collects data
                                    on nursing home deficiencies, we were able to control for a nursing
                                    home’s history of infection prevention and control deficiencies;
                                    however, we could not account for the day-to-day adherence by
                                    nursing home staff and residents to infection prevention and control
                                    practices.


Multivariate Regression Model   We conducted a series of multivariate Cox proportional hazard regression
                                models. The purpose of the model is to evaluate simultaneously the effect
                                of several factors on outbreak duration. A hazard regression model allows
                                us to examine how specified factors may be associated with the rate of a
                                particular event happening (e.g., outbreak ending) at a particular point in
                                time and allows time-varying covariates to capture the effects of changes
                                in independent variables over time. 14 The rate is commonly referred to as
                                the hazard rate. Predictor variables (or independent factors) are usually
                                termed covariates in the survival-analysis literature. The Cox model is
                                expressed by the hazard function denoted by λ(t). Briefly, the hazard
                                function can be interpreted as the probability of the outbreak ending at
                                time t. It can be estimated as follow:

                                                              λk (t; Zki) = λk0 exp{β'kZki(t)}

                                where

                                •   k is the event, which in our case is the outbreak (k = 1, …, K).
                                •   i is the subject, which in our case is the nursing home (i = 1, …, n).

                                13See GAO-22-105133.

                                14We did not use a hierarchical model on top of an already complex model. A hierarchical
                                model would help to account for potential correlation between outbreak durations within
                                the same nursing home. When we checked for this potential correlation in an hierarchical
                                model with no other factors included, we found there was no significant correlation
                                between outbreak durations within the same nursing home.




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•   Z represents the set of covariates. Zki represents the specific covariate
    associated with ki.
•   λk0(t) is the baseline hazard function (hazard rate at time t).
•   exp{β'kZki(t)} is the expected hazard ratio of covariates at time (t).

The value of exp(β) is the hazard ratio. A value of β greater than zero, or
equivalently a hazard ratio greater than one, indicates that as the value of
the covariate increases, the hazard increases and thus the duration of the
outbreak decreases.

Multivariate regression modeling is a statistical method that examines
multiple variables simultaneously to estimate whether each of these
variables are more likely or less likely to be associated with a certain
outcome, controlling for the other variables. A multivariate regression
analyzes the statistical influence of each individual factor with the
outcome. This type of modeling allowed us to test the association
between nursing home factors, such as nursing home size or nursing
home ownership, and the probability (hazard rate) of the COVID-19
outbreak ending, while holding other nursing home information constant
(such as staffing levels and resident demographics as independent
variables).

A Cox proportional hazard model provides an estimated hazard ratio for
each independent variable, where a value greater than one indicates a
higher likelihood of the COVID-19 outbreak ending (the dependent, or
outcome, variable) and an estimated hazard ratio less than one indicates
lower probability of the outbreak ending, controlling for all the other
independent variables. For example, an overall staffing level with an
estimated hazard ratio of 2.0 would indicate a higher probability of an
outbreak ending. In contrast, an overall staffing level with an estimated
staffing ratio of 0.5 would indicate a higher probability that the outbreak
continues.

The statistical significance of the results for each variable is determined
by a p-value of less than 0.05. As a result, in our report, we state that
hazard ratios that are statistically significant and greater than 1.00 or
lower than 1.00 indicate that nursing homes with that characteristic (e.g.,
rural location) are more likely or less likely, respectively, to have their
COVID-19 outbreak end at that point in time, relative to their
corresponding reference category. In cases where the p-value was
greater than 0.05, we report that we could not identify any statistically
significant differences, which means that we could not conclude that there



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                                        was an association between that attribute and the likelihood of the
                                        outbreak ending.

                                        We developed multivariate Cox proportional hazard models to test the
                                        extent of association with outcome and statistical significance of all
                                        independent factors presented in table 9. 15 We ran two models—one for
                                        the period of time prior to the introduction of COVID-19 vaccines (June
                                        14, 2020, through January 2, 2021) and one for the period of time after
                                        introduction of COVID-19 vaccines in nursing homes (January 3, 2021,
                                        through January 2, 2022). 16 Hazard ratios from the multivariate model
                                        represent simultaneous relationships of all independent factors specified
                                        in the model with the outcome. Therefore, there is a reference category
                                        for each categorical factor specified in the multivariate model. As an
                                        example, for nursing home size, small and medium nursing homes are
                                        compared against large and very large nursing homes as the reference
                                        category in the model. Based on the results in Table 9, in the pre-vaccine
                                        time period, small nursing homes had a statistically significant hazard
                                        ratio of 1.444, indicating that small homes were distinct from large and
                                        very large homes and that the small homes had shorter outbreaks than
                                        larger homes. Further, the parameter estimate of 0.367 indicates that an
                                        outbreak was likely to end approximately 2.5 days earlier in small homes
                                        than in large and very large homes.

Table 9: Multivariate Regression Results from Cox Proportional Hazard Model, COVID-19 Outbreak Duration by Vaccination
Time Period, June 14, 2020, through January 2, 2022

                                                                          Hazard ratio (parameter estimate)
                                                      Pre-vaccine time period (June 14,       Post-vaccine time period (January
Independent factors                                     2020, through January 2, 2021)         3, 2021, through January 2, 2022)
Categorical variables
Reference category: High community spread
    Low community spread                                                    2.784** (1.024)                       1.999** (0.692)
    Moderate community spread                                               2.382** (0.868)                       1.920** (0.652)
    Substantial community spread                                            2.014** (0.700)                       1.703** (0.533)
Reference category: Metropolitan
    Rural                                                                     1.023 (0.023)                        1.042* (0.041)


                                        15The model results presented are right-censored.

                                        16We initially ran a single model with a dummy variable for the time period that COVID-19
                                        vaccinations were available but found that this dummy variable was overly dominate.
                                        Therefore, by running two separate models we were able to tease out the effects of other
                                        independent variables.




                                        Page 57                                   GAO-23-104291 Nursing Home COVID-19 Outbreaks
                                                               Appendix II: Detailed Description of
                                                               Methodology for Multivariate Statistical Models




                                                                                                              Hazard ratio (parameter estimate)
                                                                                    Pre-vaccine time period (June 14,                     Post-vaccine time period (January
 Independent factors                                                                  2020, through January 2, 2021)                       3, 2021, through January 2, 2022)
       Micropolitan                                                                                               0.978 (-0.022)                                          0.990 (-0.010)
 Reference category: Large (100 – 199 beds) or very
 large (200 or more beds)
       Medium (50 to <100 beds)                                                                                  1.177** (0.163)                                         1.167** (0.155)
       Small (<50 beds)                                                                                          1.444** (0.367)                                         1.414** (0.346)
 Reference category: For-profit
       Non-profit                                                                                               0.882** (-0.125)                                        0.884** (-0.124)
       Government-owned                                                                                         0.903** (-0.102)                                        0.799** (-0.225)
 Reference category: No reported staff shortages
       Reported staff shortages                                                                                 0.843** (-0.170)                                        0.944** (-0.058)
 Reference category: Lower overall star rating (one- to
 three-stars)
       Higher overall star rating (four- and five-stars)                                                        0.933** (-0.070)                                        0.956** (-0.045)
 Reference category: Lower health inspection star
 rating (one- to three-stars)
       Higher health inspection star rating (four- and five-                                                       1.004 (0.004)                                           1.006 (0.006)
       stars)
 Continuous variables
 Number of prior outbreaks                                                                                      0.959** (-0.042)                                         1.074** (0.072)
 Percentage of new employeesa                                                                                   0.987** (-0.013)                                         1.003** (0.003)
 Average hours per employee per week                                                                              0.996 (-0.004)                                           1.000 (0.000)
 Number of employees per resident                                                                                 0.984 (-0.016)                                        0.969** (-0.031)
 Nursing home case-mix                                                                                          0.995** (-0.005)                                        0.995** (-0.005)
 Percentage of occupied beds                                                                                       1.001 (0.001)                                        0.999** (-0.001)
 Number of infection prevention and control deficiencies                                                        0.955** (-0.046)                                           1.006 (0.006)
 cited in the last year
 Percentage of residents over 75                                                                                   1.001 (0.001)                                           1.001 (0.001)
 Percentage of residents less than 65                                                                             1.005* (0.005)                                         1.006** (0.006)
 Percentage of female residents                                                                                    1.001 (0.001)                                         1.002** (0.002)
 Percentage of minority residents                                                                                1.001** (0.001)                                          1.001* (0.001)

Legend:
“*” indicates that this variable is statistically significant at p-value <0.05.
“**” indicates that this variable is statistically significant at p-value <0.001.
Source: GAO analysis of Centers for Disease Control and Prevention, Centers for Medicare & Medicaid Services (CMS), and Health Resources and Services Administration data. │GAO-23-104291

                                                               Notes: Multivariate Cox Proportional Hazard models are used to test the extent of association with
                                                               outcome and statistical significance of all independent factors.
                                                               The hazard ratio is the probability of an outbreak ending for the given factor relative to its reference
                                                               category. In our report, we state that hazard ratios that are statistically significant and greater than




                                                               Page 58                                                   GAO-23-104291 Nursing Home COVID-19 Outbreaks
                             Appendix II: Detailed Description of
                             Methodology for Multivariate Statistical Models




                             1.00 or lower than 1.00 indicate that nursing homes with that characteristic are more likely or less
                             likely, respectively, to have their COVID-19 outbreak end at that point in time.
                             The parameter estimate is the measure of the direction and size of the effect that a single unit change
                             in the independent variable has on the dependent variable. The parameter estimate is based on
                             weekly data (parameter estimate of 1.00 equals 1 week); therefore, a parameter estimate of
                             approximately +/- 0.143 is equivalent to one day.
                             a
                              New employees were defined as any employee at a specific nursing home without a record in CMS’s
                             payroll-based journal in the prior 6 weeks.




Data and Model Limitations   Although the data quality is sufficiently reliable for the purposes of our
                             objective, there are some limitations to note. The CDC COVID-19 nursing
                             home data, which forms the backbone of the COVID-19 outbreak variable
                             and other variables, is self-reported weekly by nursing homes. The
                             number of COVID-19 cases is based on the testing technology and
                             infrastructure available to homes at the time the data were reported; the
                             availability and accuracy of the tests may have changed over time, but
                             there is no reason to believe that any bias in testing occurred between
                             homes at the time. In addition, according to CDC officials, the agency’s
                             definition of a COVID-19 outbreak is an epidemiologic one and has been
                             used during the pandemic to trigger the implementation of additional
                             infection prevention and control practices, such as screening testing for
                             residents and staff to determine if unrecognized cases were in the nursing
                             home. Therefore, an individual outbreak in our analysis does not
                             necessarily imply that all of the COVID-19 cases reported during that
                             outbreak were related to a single introduction of COVID-19 into the
                             facility.

                             CDC officials also noted that the inclusion of staff COVID-19 cases in our
                             analysis of outbreaks may inflate the total number and duration of
                             outbreaks because routine screening testing of asymptomatic nursing
                             home staff could have identified infected staff who may have never
                             entered the facility. This situation would reflect COVID-19 transmission in
                             the community rather than transmission in the nursing home.

                             Other variables in the COVID-19 nursing home data weekly reports, such
                             as the availability of staffing and personal protective equipment, are also
                             self-reported. While noting the staffing shortages are self-reported, we
                             also included CMS payroll-based journal data that provide an objective
                             measure of staffing. In the case of personal protective equipment and
                             infection containment supplies (such as hand sanitizer), CDC altered the
                             questions at different periods during the pandemic. This resulted in data
                             that could not be tracked over time and thus we did not include variables
                             on personal protective equipment shortages in the final models. The



                             Page 59                                       GAO-23-104291 Nursing Home COVID-19 Outbreaks
Appendix II: Detailed Description of
Methodology for Multivariate Statistical Models




vaccination of staff and residents posed a slightly different problem, in
that CMS did not require nursing homes to report data to CDC on the
number and percent of staff and residents vaccinated until about 5
months into the vaccination program. To account for the possible role that
the presence of the vaccine played in COVID-19 outbreaks, we first
created a dummy variable to acknowledge the availability of the vaccine.
When this proved to be an overwhelmingly significant variable, we split
the model into two time periods, as described above.

Other datasets also had limitations. In its payroll-based journal CMS
allows nursing homes to submit staffing information for 40 different types
of staff, including both nurse and non-nurse staff. While CMS has
instituted checks and audits to ensure that nurse staffing data reported in
the payroll-based journal are accurate, CMS does not have a process to
ensure the accuracy and completeness of staffing information for non-
nurse staff. 17 Based on interviews with CMS officials, we determined that,
despite this limitation, we could still use most of the non-nurse payroll-
based journal data for the purposes of our analysis. However, CMS only
requires reporting for 32 of the 40 types of staff. Data for the remaining
eight types of non-nurse staff—which include housekeepers and others
who may not care for residents in a therapeutic manner but still may
come into close contact with residents—are neither required to be
reported nor audited for accuracy. 18 As a result, we decided to exclude
these eight types of staff from our analysis. Therefore, we do not know if
these types of staff were associated with the duration of outbreaks.

When using staffing variables created based on data in the payroll-based
journal, we were generally not able to separate out the influence of
certain staff roles (e.g., registered nurses and nurse aides) to our
satisfaction. While many of the homes we interviewed pointed to staffing

17The Department of Health and Human Services’ Office of Inspector General has
recommended that CMS take steps to ensure the accuracy of payroll-based journal data
for non-nurse staff that it chooses to include on its Care Compare website. For example,
CMS may consider adding physical therapists—the only type of non-nurse staff with data
currently found on Care Compare—to its audits of payroll-based journal data. See
Department of Health and Human Services Office of Inspector General, CMS Use of Data
on Nursing Home Staffing: Progress and Opportunities To Do More, OEI-04-18-00451
(Washington, D.C.: March 2021).
18According to CMS, these eight types of staff (dentist, podiatrist, vocational service
worker, clinical laboratory service worker, diagnostic x-ray service worker, blood service
worker, housekeeping service worker, other service worker) are voluntary for nursing
homes to report because they either do not meet the definition of direct-care or are not
paid by nursing homes, so their data would not be able to be audited by CMS.




Page 60                                   GAO-23-104291 Nursing Home COVID-19 Outbreaks
Appendix II: Detailed Description of
Methodology for Multivariate Statistical Models




as an issue, the actual employment data, despite several different
iterations using different breakouts of staffing roles, did not indicate a
significant role by particular kinds of staff.

CDC data on community spread is based on test results. While there is
no imputation that accounts for cases that exist but for which no test was
done or tests were done at home and not reported, we used CDC’s
categorization of community spread, which is based, in part, on the
percentage of positive diagnostic and screening nucleic acid amplification
tests, which are required to be reported. CDC data is assumed to be
reliable for our purposes because we can assume that there was no
systematic bias with respect to the duration of outbreaks in nursing
homes.

In general, CMS data on nursing home surveys and investigations and
their resulting deficiencies is considered reliable. We should note that for
a number of months during the first year of the pandemic, regular
standard surveys of nursing homes and low priority investigations were
temporarily suspended, replaced by focused infection control surveys,
which evaluated compliance with CMS infection prevention and control
policies. Based on this and findings in prior reports we focused on a
home’s history of infection prevention and control deficiencies rather than
on their overall number and severity of deficiencies.

The CMS Minimum Data Set was used to determine the case-mix of the
residents in a home as well as the demographics of each home’s
population. Many variables within the Minimum Data Set are self-reported
by the resident, the family, or a staff member on behalf of a resident, and
we acknowledge this can raise some questions of data reliability, some of
which have been reported in the literature. 19 We determined that the
demographic data are sufficiently reliable. Further, we determined that
case-mix data are sufficiently reliable given that any bias in case-mix is
likely to exist in all nursing homes, so comparison of homes is not
particularly problematic.




19Some studies have found that the Minimum Data Set data reported by nursing homes
underreports anti-psychotic use and falls. For examples, see HHS Office of Inspector
General, CMS Could Improve the Data It Uses to Monitor Antipsychotic Drugs in Nursing
Homes, OEI-07-19-00490 (Washington, D.C.: May 3, 2021), and J. Mintz et al., “Validation
of the Minimum Data Set Items on Falls and Injury in Two Long-Stay Facilities,” Journal of
the American Geriatrics Society, vol. 69, no. 4 (April 2021).




Page 61                                   GAO-23-104291 Nursing Home COVID-19 Outbreaks
Appendix III: Nursing Home Officials’    Appendix III: Nursing Home Officials’
                                         Descriptions of COVID-19 Outbreaks, including


Descriptions of COVID-19 Outbreaks,
                                         Challenges and Successes




including Challenges and Successes
Table 10: Nursing Home Officials’ Descriptions of COVID-19 Outbreaks, including Challenges and Successes

Nursing home                 Description of COVID-19 outbreaks, including challenges and successes
Nursing home A               This nursing home kept COVID-19 out of the facility until July 2020, which was likely due to the
Non-profit                   proactive steps it took to restrict residents to their rooms and adopt face mask requirements. Their
                             first case was a staff member, and it was caught early. The required biweekly COVID-19 testing
Large (100-199 beds)         caught additional staff cases throughout the pandemic. The challenges posed by the reduction in
                             staff due to quarantine or symptoms was “manageable although not optimal.” However, the home
                             reached a staffing “crisis” as the pandemic continued, noting that they were down 25 full-time
                             employees. The nursing home’s first resident outbreak was in October 2020 and started with five
                             residents and then spread to an additional 16 residents. The nursing home officials believed that
                             COVID-19 entered the home from a dialysis patient. The COVID-positive residents were able to be
                             isolated in one ward of the nursing home and staff who already had tested positive and had returned
                             from their quarantine were willing to work in the COVID-19 unit. A year later, in October 2021, the
                             home had a second “major” resident outbreak.
Nursing home B               This nursing home experienced its largest outbreak in December 2021 with the Omicron surge.
For-profit                   During this time, 20 percent of its residents and staff tested positive. Officials attributed this outbreak
                             in part to the re-opening of visitation that occurred in November 2021. Prior to the outbreak, the home
Large (100-199 beds)         had only seen a few cases at a time, and its COVID-19-positive residents had avoided severe illness.
                             A lot of the home’s prior success in keeping COVID-19 out of the facility was due to community
                             decisions that resulted in low levels of COVID-19. Located in an isolated area, the county was able to
                             close a road into the community during the worst of the pandemic in 2020 to keep travelers out.
                             However, these community policies were discontinued by winter of 2021, and the nursing home could
                             no longer restrict visitation. Officials also discussed staffing shortages and staff fatigue as challenges
                             experienced during outbreaks. For example, at one point the home was down five working staff
                             members as COVID-19-positive staff had to quarantine. In addition, the home had to staff a separate
                             COVID-19 unit for just a few COVID-19-positive residents during a smaller outbreak, requiring more
                             staff. It was also difficult to find staff willing to work the COVID-19 unit due to the risk of exposure.
Nursing home C               This nursing home kept COVID-19 out of the facility until May 2020, which the home attributed to
For-profit                   having enough personal protective equipment, suspending new admissions, and adopting face mask
                             requirements. But mitigation measures only worked for a while. The first of two resident outbreaks
Very large (200+ beds)       started with a few staff contracting COVID-19 from the community. Soon after, two residents tested
                             positive, then two more, and so on. During the first outbreak, the virus spread slowly, but the second
                             outbreak in late 2020 spread more rapidly—from two residents to 10 or 12 residents almost
                             immediately. During the first outbreak, the boundaries of the COVID-19 unit never changed, but
                             during the second outbreak the home had to keep expanding the boundaries. Throughout the
                             outbreaks, the nursing home was able to maintain its staffing levels—even when staff were out sick
                             with COVID-19. However, the psychosocial toll had significant negative effects on residents. The
                             suspension not only of visitation but also dining facility activities resulted in declines in resident
                             physical and mental health. The staff began to see residents with weight loss and an increased need
                             for anti-depressant drugs. Many of the residents just “gave up.”




                                         Page 62                                    GAO-23-104291 Nursing Home COVID-19 Outbreaks
                                                                 Appendix III: Nursing Home Officials’
                                                                 Descriptions of COVID-19 Outbreaks, including
                                                                 Challenges and Successes




 Nursing home                                   Description of COVID-19 outbreaks, including challenges and successes
 Nursing home D                                 This nursing home was hit “like a brick” in the fall of 2020. Earlier in 2020, a COVID-19 outbreak
 Non-profit                                     affected about a dozen residents, but cases in its outbreak in the fall of 2020 “wreaked havoc” on
                                                residents and staff, with 40 residents dying. The loss of so many residents took a heavy emotional
 Very large (200+ beds)                         toll on staff and fellow residents. Officials believed the virus entered the facility through staff as, at the
                                                time, the home’s staff and the surrounding community had low vaccination rates. In addition to the
                                                emotional toll on residents and staff, the number of resident deaths plus staff attrition resulted in the
                                                nursing home losing about 50 percent of its capacity and closing a sister nursing home. The home
                                                learned a lot about the importance of communication during the second outbreak. For example, to
                                                facilitate communication within the home, task force teams met twice a week, and to facilitate
                                                communication to families, a hotline was created and a weekly newsletter was developed to provide
                                                relevant COVID-19 information. However, the psychosocial toll during that time took the joy away
                                                from caregiving and left many staff with trauma. Further, the fact that the home is located in a rural
                                                area with limited available staff, made maintaining staffing levels very difficult, with officials noting
                                                “scary” staffing shortages.
 Nursing home E                                 This nursing home kept COVID-19 out of the facility until July 2020 and used its outbreak-free time
 For-profit                                     learning to adapt to infection control procedures that very few staff were doing correctly before the
                                                pandemic. The July 2020 outbreak lasted about 5 weeks and culminated with 32 of about 70
 Medium (50-99 beds)                            residents and 12 staff infected. Eight of those residents died. After that outbreak, the nursing home
                                                did not experience any additional large outbreaks, only a few isolated cases. Officials could not trace
                                                the origin of the outbreak, but believed that COVID-19 was brought into the facility by a staff member.
                                                Further exacerbating the outbreak was a limited supply of N95 masks, so many residents and some
                                                staff were using regular procedure masks instead, as well as physical space constraints. Officials
                                                said that to isolate COVID-19-positive residents, the home had to “shuffle” healthy residents from one
                                                room to another, which may have accidentally spread the virus. In addition, the nursing home’s
                                                resident population and nurse staff decreased significantly. Specifically, the nursing home lost 23
                                                residents and about half of its staff left. This resulted in closing a section of the home in December
                                                2020 and having to rely on traveling nurses and aides for the home’s staffing needs.
 Nursing home F                                 Early in the pandemic, this nursing home had some staff members test positive, but COVID-19 was
 For-profit                                     not transferred to the residents. The first resident did not test positive until November 2020. Officials
                                                believed that the virus was brought into the facility by staff. The home had another outbreak in
 Large (100-199 beds)                           January 2021 and was able to contain COVID to just one floor of their three-floor facility for a time,
                                                but eventually the virus spread. Staff were out sick with COVID-19 during these outbreaks. With
                                                limited staff and the building’s physical space constraints, officials had to make difficult choices. For
                                                example, there were times where nursing home officials felt they had no choice but to move staff
                                                between COVID-19 and non-COVID-19 units. As the pandemic wore on, staff had a hard time
                                                adjusting to the re-opening of visitation in November 2021. Officials said that they believed their staff
                                                were exposed to trauma as a result of their early experiences with COVID-19.
Source: GAO interviews with officials from selected nursing homes in four states. │GAO-23-104291




                                                                 Page 63                                 GAO-23-104291 Nursing Home COVID-19 Outbreaks
Appendix IV: GAO Contact and Staff
                  Appendix IV: GAO Contact and Staff
                  Acknowledgments


Acknowledgments

                  John E. Dicken at (202) 512-7114 or dickenj@gao.gov
GAO Contact
                  In addition to the contact named above, key contributors to this report
Staff             were Karin Wallestad (Assistant Director), Kathryn Richter (Analyst-in-
Acknowledgments   Charge), Julianne Flowers, Isabella Guyott, Sarah-Lynn McGrath, Elise
                  Pressma, and Elaina Stephenson. Also contributing to the report were
                  Laurie Pachter, Vikki Porter, Patricia Powell, Bryan Ricciardi, Ravi
                  Sharma, Anna Beth Smith, Roxanna Sun, Jeff Tamburello, Jennifer
                  Whitworth, and Sirin Yaemsiri.




                  Page 64                              GAO-23-104291 Nursing Home COVID-19 Outbreaks
Related GAO Products
             Related GAO Products




             COVID-19 in Nursing Homes: CMS Needs to Continue to Strengthen
             Oversight of Infection Prevention and Control. GAO-22-105133.
             Washington, D.C.: September 14, 2022.

             Health Care Capsule: Improving Nursing Home Quality and Information.
             GAO-22-105422. Washington, D.C.: January 14, 2022.

             COVID-19: Continued Attention Needed to Enhance Federal
             Preparedness, Response, Service Delivery, and Program Integrity.
             (Nursing Homes Enclosure). GAO-21-551. Washington, D.C.: July 19,
             2021.

             COVID-19 in Nursing Homes: Most Homes Had Multiple Outbreaks and
             Weeks of Sustained Transmission from May 2020 through January 2021.
             GAO-21-367. Washington, D.C.: May 19, 2021.

             COVID-19: Sustained Federal Action Is Crucial as Pandemic Enters its
             Second Year. (Nursing Homes Enclosure). GAO-21-387. Washington,
             D.C.: March 31, 2021.

             COVID-19 in Nursing Homes: HHS Has Taken Steps in Response to
             Pandemic, but Several GAO Recommendations Have Not Been
             Implemented. GAO-21-402T. Washington, D.C.: March 17, 2021.

             COVID-19: Critical Vaccine Distribution, Supply Chain, Program Integrity,
             and Other Challenges Require Focused Federal Attention. (Nursing
             Homes Enclosure). GAO-21-265. Washington, D.C.: January 28, 2021.

             COVID-19: Urgent Actions Needed to Better Ensure an Effective Federal
             Response. (Nursing Homes Enclosure). GAO-21-191. Washington, D.C.:
             November 30, 2020.

             COVID-19: Federal Efforts Could Be Strengthened by Timely and
             Concerted Actions. (Nursing Homes Enclosure). GAO-20-701.
             Washington, D.C.: September 21, 2020.

             COVID-19: Opportunities to Improve Federal Response and Recovery
             Efforts. (Nursing Homes Enclosure). GAO-20-625. Washington, D.C.:
             June 25, 2020.

             Infection Control Deficiencies Were Widespread and Persistent in Nursing
             Homes Prior to COVID-19 Pandemic. GAO-20-576R. Washington, D.C.:
             May 20, 2020.


(104291)
             Page 65                         GAO-23-104291 Nursing Home COVID-19 Outbreaks
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