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Report (2021-03-17)

Issuer
Government Accountability Office
Document type
Report
Date
2021-03-17

Summary

GAO-21-402T is testimony of the U.S. Government Accountability Office before the Committee on Finance, U.S. Senate, for release on March 17, 2021, delivered by John E. Dicken, Director, Health Care. The statement on COVID-19 in nursing homes summarizes findings from GAO's CARES Act reports GAO-21-265, GAO-21-191, GAO-20-701 and GAO-20-625. The testimony reports that CDC data show a winter 2020 surge in nursing home cases and deaths, followed by declines of more than 80 percent since their December 2020 peaks. It describes persistent staffing shortages and newer challenges such as reluctance among some staff to receive a COVID-19 vaccine. It states that HHS has not implemented GAO recommendations to develop an implementation plan for the Nursing Home Commission report and to capture more complete COVID-19 data back to January 1, 2020.

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                            United States Government Accountability Office
                            Testimony
                            Before the Committee on Finance,
                            U.S. Senate


                            COVID-19 IN NURSING
For Release on Delivery
Expected at 10:00 a.m. ET
Wednesday, March 17, 2021

                            HOMES
                            HHS Has Taken Steps in
                            Response to Pandemic,
                            but Several GAO
                            Recommendations Have
                            Not Been Implemented
                            Statement of John E. Dicken, Director, Health Care




GAO-21-402T
                                              March 2021

                                              COVID-19 IN NURSING HOMES
                                              HHS Has Taken Steps in Response to Pandemic, but
                                              Several GAO Recommendations Have Not Been
Highlights of GAO-21-402T, a testimony        Implemented
before the Committee on Finance, U.S.
Senate.




Why GAO Did This Study                        What GAO Found
The COVID-19 pandemic has had a               GAO’s review of data from the Centers for Disease Control and Prevention
disproportionate impact on the 1.4            (CDC) found that winter 2020 was marked by a significant surge in the number of
million elderly or disabled residents in      COVID-19 cases and deaths in nursing homes. However, CDC data as of
the nation’s more than 15,000                 February 2021, show that both cases and deaths have declined by more than 80
Medicare- and Medicaid-certified              percent since their peaks in December 2020. With the introduction of vaccines,
nursing homes, who are often in frail         observers are hopeful that nursing homes may be beginning to see a reprieve.
health and living in close proximity to       Nevertheless, the emergence of more highly transmissible virus variants
one another. HHS, primarily through           warrants the need for continued vigilance, according to public health officials.
CMS and CDC, has led the pandemic
response in nursing homes.                    GAO’s prior work has found that nursing homes have faced many difficult
                                              challenges battling COVID-19. While challenges related to staffing shortages
The CARES Act includes a provision            have persisted through the pandemic, challenges related to obtaining Personal
for GAO to conduct monitoring and             Protective Equipment (PPE) and conducting COVID-19 tests—although still
oversight of the federal government’s         notable—have generally shown signs of improvement since summer 2020.
efforts to prepare for, respond to, and       Further, with the decline in nursing homes cases, the Centers for Medicare and
recover from the COVID-19 pandemic.           Medicaid Services (CMS) updated its guidance in March 2021 to expand resident
GAO has examined the government’s             visitation, an issue that has been an ongoing challenge during the pandemic.
response to COVID-19 in nursing               Some new challenges have also emerged as vaccinations began in nursing
homes through its CARES Act
                                              homes, such as reluctance among some staff to receive a COVID-19 vaccine.
reporting (GAO-21-265, GAO-21-191,
GAO-20-701, and GAO-20-625).
                                              The Department of Health and Human Services (HHS), primarily through CMS
This testimony will summarize the             and the CDC, has taken steps to address COVID-19 in nursing homes. However,
findings from these reports.                  HHS has not implemented several relevant GAO recommendations, including:
Specifically, it describes COVID-19
trends in nursing homes and their             •   HHS has not implemented GAO’s recommendation related to the Nursing
experiences responding to the                     Home Commission report, which assessed the response to COVID-19 in
pandemic, and HHS’s response to the               nursing homes. CMS released the Nursing Home Commission’s report and
pandemic in nursing homes.                        recommendations in September 2020. When the report was released, CMS
                                                  broadly outlined the actions the agency had taken, but the agency did not
To conduct this previously reported               provide a plan that would allow it to track its progress. GAO recommended in
work, GAO reviewed CDC data,                      November 2020 that HHS develop an implementation plan. As of February
agency guidance, and other relevant               2021, this recommendation had not been implemented.
information on HHS’s response to the
COVID-19 pandemic. GAO interviewed            •   HHS has not implemented GAO’s recommendation to fill COVID-19 data
agency officials and other
                                                  voids. CMS required nursing homes to begin reporting the number of cases
knowledgeable stakeholders. In
                                                  and deaths to the agency effective May 8, 2020. However, CMS made the
addition, GAO supplemented this
information with updated data from
                                                  reporting of the data prior to this date optional. GAO recommended in
CDC on COVID-19 cases and deaths                  September 2020 that HHS develop a strategy to capture more complete
reported by nursing homes as of                   COVID-19 data in nursing homes retroactively back to January 1, 2020. As of
February 2021.                                    February 2021, this recommendation had not been implemented.

                                              Implementing GAO’s recommendations could help address some of the
                                              challenges nursing homes continue to face and fill important gaps in the federal
                                              government’s understanding of, and transparency around, data on COVID-19 in
                                              nursing homes. In addition to monitoring HHS’s implementation of past
View GAO-21-402T. For more information,
contact John E. Dicken at (202) 512-7114 or   recommendations, GAO has ongoing work related to COVID-19 outbreaks in
dickenj@gao.gov.                              nursing homes and CMS’s oversight of infection control and emergency
                                              preparedness.
                                                                                      United States Government Accountability Office
Letter   Letter




         Chairman Wyden, Ranking Member Crapo, and Members of the
         Committee:

         I am pleased to be here today to discuss our work on Coronavirus
         Disease 2019 (COVID-19) in nursing homes. Just over a year ago, a
         Washington State nursing home was battling one of the first major
         COVID-19 outbreaks in the United States. Today, the COVID-19
         pandemic has reached nearly all of the more than 15,000 Medicare- and
         Medicaid-certified nursing homes in the country, resulting in a
         disproportionately high number of COVID-19 deaths among residents.
         While the nation’s 1.4 million nursing home residents are a small share of
         the total U.S. population (less than 1 percent), they comprise nearly 30
         percent of COVID-19 deaths reported by the Centers for Disease Control
         and Prevention (CDC). Nursing home residents are at a high risk for
         COVID-19 infection and death because the virus has a high mortality rate
         among elderly adults and those with underlying health conditions. In
         addition, the congregate nature of nursing homes, with staff caring for
         multiple residents and shared communal spaces, as well as high
         incidence rates in the surrounding community, can increase the risk that
         COVID-19 will enter the home and easily spread. Further, efforts to
         reduce the spread of COVID-19 in nursing homes have required changes
         in typical nursing home practices—such as restricting visitors and
         isolating residents exposed to COVID-19—raising concerns for vulnerable
         residents, who may have less social interaction and third party oversight
         of their care.

         The Centers for Medicare & Medicaid Services (CMS), an agency within
         the Department of Health and Human Services (HHS), is responsible for
         ensuring that nursing homes meet federal quality standards to participate
         in the Medicare and Medicaid programs. 1 In response to the pandemic,
         HHS, primarily through CMS and CDC, has taken a series of actions with
         nursing homes, such as providing guidance, developing targeted
         inspections to improve infection control practices, and distributing testing




         1To monitor compliance with these standards, CMS enters into agreements with state
         survey agencies in each state government to conduct inspections, including recurring
         comprehensive standard surveys and as-needed investigations. CMS’s Center for Clinical
         Standards and Quality has responsibility for overseeing state survey agencies’ survey and
         certification activities, among others.




         Page 1                                                                      GAO-21-402T
devices to homes. 2 In addition, in May 2020, CDC began collecting
weekly COVID-19 data from nursing homes through its National
Healthcare Safety Network system.

The CARES Act includes a provision for us to conduct monitoring and
oversight of the federal government’s efforts to prepare for, respond to,
and recover from the COVID-19 pandemic. 3 In response to the CARES
Act, we have examined the response to COVID-19 in nursing homes in
four reports since June 2020. To help inform today’s discussion, my
testimony will summarize our findings on nursing home issues from these
reports. 4 In particular, my statement will address:

1. COVID-19 trends in nursing homes and their experiences responding
   to the COVID-19 pandemic, and
2. HHS’s response to the COVID-19 pandemic in nursing homes.
In addition, I will highlight key actions that we recommended HHS take
and the current status of those recommendations. While my comments
today focus on the findings of our CARES Act reports, they are also
informed by our longer-term body of work examining nursing home
oversight and quality prior to the pandemic.

To conduct the work for the previously issued reports on which my
comments are based, we reviewed CDC data, agency guidance, and
other relevant information on HHS’s response to the COVID-19
pandemic. We interviewed agency officials, as well as researchers with
experience in infection control, advocates for individuals residing in
nursing homes and their families, national associations representing
nursing homes, and representatives from associations representing state
and local officials. More detailed information on our methodology can be

2In our May 2020 report, we found that infection control deficiencies were widespread and
persistent in nursing homes in the years prior to the COVID-19 pandemic. 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).
3Pub. L. No. 116-139, § 19010(b), 134 Stat. 281, 579 (2020).

4See GAO, 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); COVID-19: Urgent Actions Needed to Better Ensure an Effective Federal
Response, GAO-21-191, (Washington, D.C.: Nov. 30, 2020);COVID-19: Federal Efforts
Could Be Strengthened by Timely and Concerted Actions, GAO-20-701, (Washington,
D.C.: Sept. 21, 2020); and COVID-19: Opportunities to Improve Federal Response and
Recovery Efforts, GAO-20-625, (Washington, D.C.: June 25, 2020).




Page 2                                                                       GAO-21-402T
found in the issued reports. 5 In addition, we supplemented this
information with updated data from CDC on COVID-19 reported by
nursing homes for the week ending February 7, 2021. 6 We analyzed the
CDC data as they were reported by nursing homes to CDC and publicly
posted by CMS. We did not otherwise independently verify the accuracy
of the information with these nursing homes. We assessed the reliability
of the data sets used in our analyses by checking for missing values and
obvious errors and reviewing relevant CMS and CDC documents. We
determined the data were sufficiently reliable for the purposes of our
reporting objective.

We conducted the work on which this statement is based 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 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.




5For example, see GAO-21-265.

6We analyzed the most recent data available on February 18, 2021. The CDC data on
COVID-19 in nursing homes were accessed on February 18, 2021, for the week ending
February 7, 2021, from https://data.cms.gov/Covid19-nursing-home-data. For the data on
COVID-19 in nursing homes, we analyzed and reported data that had been determined by
CDC and CMS to pass quality assurance checks for data entry errors. According to CDC,
data used in this analysis are part of a live data set, meaning that facilities can make
corrections to the data at any time.




Page 3                                                                      GAO-21-402T
Nursing Home
COVID-19 Cases and
Deaths Are Declining
after Winter Surge;
Persistent Challenges
Remain in Pandemic
Response
After a Winter Surge, CDC   Our analysis of CDC data shows that winter 2020 was marked by a
Data Show a Decline in      significant surge in the number of COVID-19 cases and deaths for
                            nursing home residents and staff. Specifically, during mid-December
COVID-19 Cases and
                            2020, there were more than 33,600 new resident cases and 28,600 new
Deaths among Nursing        staff cases, which was more than twice as high as the prior case number
Home Residents and Staff    peaks in summer 2020. CDC data show that cases and deaths in nursing
to Levels Closer to Those   homes are on the decline. Specifically, as of the week ending February 7,
of Fall 2020                2021, resident and staff cases have both declined by more than 80
                            percent since their peaks in December 2020. The changing weekly
                            COVID-19 death counts in nursing homes generally moved in the same
                            direction as changes in the country as a whole. With the introduction of
                            vaccines, observers are hopeful that nursing homes may be beginning to
                            see a reprieve; however, the emergence of more highly transmissible
                            virus variants warrants the need for continued vigilance, according to
                            public health officials. 7 (See fig. 1).




                            7These numbers are likely underreported because they do not include data for the 998
                            nursing homes (6.5 percent) that did not report COVID-19 data to CDC for the week
                            ending February 7, 2021, or that submitted data that failed data quality assurance checks.
                            The week ending May 31, 2020, is the first single week of data reported to CDC. The
                            week ending May 24 is the only earlier week of data, and could potentially include cases
                            and deaths for multiple weeks dating back to January 1, 2020, for those homes which
                            voluntarily reported such data. It is therefore not comparable with data for other weeks,
                            and we excluded it. According to CDC, data used in this analysis are part of a live data
                            set, meaning that facilities can make corrections to the data at any time.




                            Page 4                                                                       GAO-21-402T
Figure 1: New Weekly Confirmed COVID-19 Cases and Deaths among U.S. Nursing Home Residents and Staff, as Reported by
Medicare- and Medicaid-Certified Nursing Homes, May 31, 2020, through Feb 7, 2021




                                      Notes: Dates refer to the end of a week (e.g., May 31 refers to the entire week from May 25 through
                                      May 31).




                                      Page 5                                                                                 GAO-21-402T
                                         According to CDC, data used in this analysis are part of a live data set, meaning that facilities can
                                         make corrections to the data at any time. Data presented reflect the data downloaded as of February
                                         18, 2021, which includes data through the week ending February 7, 2021. We excluded data for the
                                         week ending May 24, 2020, because it is the first week for which data are available from the CDC
                                         and could include cases and deaths from multiple weeks dating back to January 1, 2020.
                                         Weekly and cumulative 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, as we previously
                                         reported, the Centers for Medicare & Medicaid Services (CMS) does not require nursing homes to
                                         report data prior to May 2020, although nursing homes may do so voluntarily. We recommended that
                                         the Secretary of Health and Human Services—in consultation with CMS and CDC—develop a
                                         strategy to capture more complete data on confirmed COVID-19 cases and deaths in nursing homes
                                         retroactively to January 1, 2020. See GAO, COVID-19: Federal Efforts Could Be Strengthened by
                                         Timely and Concerted Actions, GAO-20-701, (Washington, D.C.: Sept. 21, 2020).
                                         Weekly staff deaths reported for the weeks ending May 31 through February 7 ranged from 13 (week
                                         ending September 20, 2020) to 61 (week ending May 31, 2020).


Some Challenges Nursing                  In our prior CARES Act reports, we found that nursing homes have faced
Homes Faced Persisted                    many difficult challenges battling COVID-19. 8 While challenges related to
While Other New                          staffing shortages have persisted through the pandemic, challenges
                                         related to obtaining Personal Protective Equipment (PPE) and conducting
Challenges Have                          COVID-19 tests—although still notable—have generally shown signs of
Emerged                                  improvement since summer 2020. Further, with the decline in nursing
                                         home cases, CMS updated its guidance in March 2021 to expand
                                         resident visitation, an issue that has been an ongoing and persistent
                                         challenge during the pandemic. Some new challenges have also
                                         emerged as vaccinations started for nursing home residents and staff.
                                         (See table 1). Some of these challenges, such as staffing shortages,
                                         obtaining PPE, and conducting testing, are critically important for infection
                                         control.

Table 1: Key Pandemic Challenges Experienced by Nursing Homes

Challenge               Description                                                                             Status
Visitation              Through interviews with researchers, advocacy organizations, and national            Challenge has persisted
                        association officials from July 2020 to February 2021, we consistently heard         throughout pandemic
                        that nursing homes have faced an ongoing tension between providing
                        residents with important visitation and minimizing the potential for a COVID-19
                        outbreak:
                        •    The restriction of visitors has negatively affected residents’ mental and
                             physical health. Researchers and advocacy organizations have noted
                             that the isolation resulting from decreased visitation can cause loneliness,
                             anxiety, and depression among residents.
                        •    The restriction of visitors has created limited oversight of facilities through
                             the exclusion of resident advocates, such as family members and
                             ombudsmen.


                                         8See GAO-20-701; GAO-21-265; GAO-21-191; and GAO-20-625.




                                         Page 6                                                                                 GAO-21-402T
Challenge             Description                                                                        Status
Staffing              In our reviews of data from the Centers for Disease Control and Prevention         Challenge has persisted
                      (CDC) and interviews with advocacy organization and national association           throughout pandemic
                      officials from July 2020 through January 2021, we consistently found that
                      nursing home staffing challenges were difficult and ongoing throughout the
                      pandemic:
                      •     CDC data from July through December 2020 consistently show that
                            about one in five nursing homes were reporting to CDC that they had a
                            shortage of nurse aides or other support staff.a
                      •     From nursing home associations we interviewed, we heard that many
                            alternative staffing sources have been used to fill critical gaps, such as
                            seeking help from staffing agencies, sharing staff between other local
                            providers, and using emergency waivers to hire nurse aides who had yet
                            to complete their certification. As of January 2021, we continued to hear
                            that staff are exhausted, face burn-out from emotional trauma, need to
                            quarantine due to exposure to or illness from the virus, or stay home to
                            take care of family members—all of which further strains staffing
                            resources.
Personal Protective   According to our reviews of data from the CDC and interviews with advocacy         Challenge has generally
Equipment (PPE)       organization and national association officials from July 2020 to January          shown improvement
                      2021, shortages of PPE in nursing homes have improved since the beginning
                      of the COVID-19 pandemic but remain an issue:
                      •    CDC data show that, as recently as December 2020, about 10 percent of
                           nursing homes did not have a one-week supply of at least one of the
                           following: N95 respirators, surgical masks, gloves, eye protection, or
                           gowns (a decrease from about 22 percent of nursing homes in July
                           2020).
                      •    In interviews with advocacy organizations and national association
                           officials from July 2020 to January 2021, we heard that, while challenges
                           maintaining PPE supplies in reserve is an ongoing concern, supply
                           shortages have become less severe over time.
Testing               According to our reviews of CDC data and interviews with a researcher and           Challenge has generally
                      with nursing home association officials in November 2020 and January 2021, shown improvement
                      nursing homes’ ability to use testing to identify infected residents and staff
                      through testing protocols has improved over the course of the pandemic, but
                      at a high cost to nursing homes:
                      •    Nursing homes have reported to CDC improved testing capacity.
                           Specifically, the number of nursing homes testing for COVID-19 in both
                           staff and residents has increased by 48 percentage points—from 35 to 83
                           percent—between August 16, 2020, and November 22, 2020, the last
                           week complete data for overall testing were available.
                      •    Although data reported in December 2020 by nursing homes found that
                           less than 2 percent of nursing homes would be unable to test all staff or
                           residents within the week if needed, nursing home association officials
                           note that the high cost of continuous testing is not sustainable indefinitely.




                                       Page 7                                                                         GAO-21-402T
Challenge                              Description                                                                                    Status
Vaccinations                           According to our reviews of a CDC analysis of vaccination data and interviews Emerging challenge
                                       with nursing home and state and local government officials, nursing homes
                                       face some emerging challenges related to vaccinations:
                                       •    A February 2021 CDC study estimated low rates of vaccine uptake
                                            among nursing home staff (38 percent) compared to nursing home
                                            residents (78 percent) participating in the Pharmacy Partnership for Long-
                                            Term Care Program.b
                                       •    In interviews with nursing home and state and local government
                                            association officials since the vaccines were first administered in
                                            December 2020, we heard about reluctance among some nursing home
                                            staff to receive the COVID-19 vaccine, in addition to hearing about
                                            uncertainty around certain aspects of vaccination distribution and
                                            requirements earlier in the year.
Source: GAO review of CDC data and interviews. | GAO-21-402T
                                                               a
                                                                According to CDC’s data documentation, other support staff may include certified nursing assistants,
                                                               medication aides, and medication technicians as reported to CDC by the provider.
                                                               b
                                                                R. Gharpure, et al., “Early COVID-19 First-Dose Vaccination Coverage Among Residents and Staff
                                                               Members of Skilled Nursing Facilities Participating in the Pharmacy Partnership for Long-Term Care
                                                               Program—United States, December 2020-January 2021,” Centers for Disease Control and
                                                               Prevention Morbidity and Mortality Weekly Report, vol. 70, no. 5 (2021): 178-182.


                                                               Our prior CARES Act reports have described how HHS, primarily through
HHS Has Taken                                                  CMS and CDC, has taken a series of actions to address COVID-19 in
Steps in Response to                                           nursing homes, such as providing guidance to nursing homes on infection
                                                               control practices and issuing waivers and regulatory flexibilities. 9
COVID-19, but                                                  Examples of other actions include:
Several Relevant
                                                                    Temporarily suspending state survey agencies’ standard surveys and
GAO                                                            •
                                                                    many complaint investigations, instead shifting to targeted infection
Recommendations
Have Not Been
Implemented




                                                               9For example, in March 2020 CMS waived the requirement that a nursing home not
                                                               employ nurse aides for more than 4 months unless they meet certain training and
                                                               certification requirements. This was done to address potential staffing shortages in nursing
                                                               homes due to the COVID-19 pandemic.




                                                               Page 8                                                                                 GAO-21-402T
    prevention and control surveys and high-priority complaint
    investigations. 10
•   Creating a new reporting requirement for nursing homes to report
    weekly COVID-19 cases and deaths for residents and staff as of May
    8, 2020.
•   Distributing antigen diagnostic tests and associated point-of-care
    testing instruments to nursing homes.
•   Distributing billions of dollars in payments from the Provider Relief
    Fund, established with funds provided under the CARES Act and
    other COVID-19 relief laws, as direct payments to assist nursing
    homes with responding to COVID-19. 11
•   Convening the Coronavirus Commission on Safety and Quality in
    Nursing Homes (the Nursing Home Commission) in June 2020, which
    was tasked with assessing the response to the COVID-19 pandemic
    in nursing homes and made recommendations for additional actions
    CMS could take.
•   Establishing the Pharmacy Partnership for Long-Term Care Program
    in October 2020, an agreement with CVS, Walgreens, and Managed
    Health Care Associates Inc. to provide and administer COVID-19
    vaccines to residents of long-term care facilities, including nursing
    homes.
•   Directing nursing homes to expand resident visitation beginning in
    March 2021, after previously restricting visitors and non-essential
    health care personnel in nursing homes, except in certain


10On June 1, CMS issued survey re-prioritization guidance as part of its nursing home
reopening strategy. Specifically, once a state enters phase 3—a threshold based on
factors including case status in the community and the nursing home, as well as access to
testing, PPE, and adequate staffing—state survey agencies were authorized to expand
beyond conducting targeted infection control surveys and high-priority complaint
investigations to include lower-priority complaint investigations. See Centers for Medicare
& Medicaid Services, “COVID-19 Survey Activities, CARES Act Funding, Enhanced
Enforcement for Infection Control Deficiencies, and Quality Improvement Activities in
Nursing Homes,” QSO-20-31-ALL, (Baltimore, Md.: June 1, 2020). On August 17, CMS
revised this guidance to authorize traditional, comprehensive, standard surveys and lower-
priority complaint investigations as soon as state survey agencies have the resources,
such as staff and PPE. See Centers for Medicare & Medicaid Services, “Enforcement
Cases Held During the Prioritization Period and Revised Survey Prioritization,” QSO-20-
35-ALL, (Baltimore, Md.: Aug. 17, 2020).
11As of January 15, 2021, $5 billion in Provider Relief Funds had been allocated for
nursing homes and $4.764 billion had been disbursed.




Page 9                                                                        GAO-21-402T
    compassionate care situations, to reduce the transmission of COVID-
    19. 12
However, HHS has not implemented several of our recommendations that
could help the agency address some of the challenges nursing homes
have faced and fill important voids in the federal government’s
understanding of, and transparency around, data on COVID-19 in nursing
homes. (See app. I for a description of related GAO reports and the
status of their recommendations.)

•   HHS has not implemented our recommendation related to the
    Nursing Home Commission report. CMS released the Nursing
    Home Commission’s final report in September 2020, which includes
    27 recommendations organized under 10 themes—such as Testing
    and Screening, Equipment and PPE, Workforce (staffing), and
    Visitation—that are paired with over 100 specific action steps for
    CMS. 13 CMS released a response to the report broadly outlining the
    actions the agency has taken to date as part of its response to the
    COVID-19 pandemic, but the agency did not provide an
    implementation plan that would allow it to track and report progress
    toward the Commission’s recommendations.
    We recommended in November 2020 that the Administrator of CMS
    quickly develop a plan that further details how the agency intends to
    respond to and implement, as appropriate, the 27 recommendations
    in the final report of the Coronavirus Commission on Safety and
    Quality in Nursing Homes. HHS neither agreed nor disagreed with our
    recommendation; instead, it highlighted actions CMS has taken
    related to Commission recommendations and indicated that it would
    refer to and act upon the Nursing Home Commission’s
    recommendations as appropriate. CMS reiterated this position in
    February 2021.
•   HHS has not implemented our recommendation to fill COVID-19
    data voids. HHS, through CMS, implemented a COVID-19 reporting
    requirement for nursing homes effective May 8, 2020 (noted briefly



12CMS restricted visitors and non-essential health care personnel in nursing homes from
March through September 2020. In September 2020, CMS issued guidance that allowed
for nursing homes to resume visitations depending on certain factors.
13MITRE, Coronavirus Commission on Safety and Quality in Nursing Homes: Commission
Final Report, PRS Release Number 20-2382, September 2020.




Page 10                                                                     GAO-21-402T
    above). 14 CMS made the reporting of the data prior to May 8, 2020,
    optional. As a result, CMS’s data do not capture the early months of
    the pandemic. 15
    We recommended in September 2020 that the Secretary of HHS, in
    consultation with CMS and CDC, develop a strategy to capture more
    complete data on confirmed COVID-19 cases and deaths in nursing
    homes retroactively back to January 1, 2020, and clarify the extent to
    which nursing homes had reported data before May 8, 2020. 16
    Although HHS partially agreed with this recommendation and
    indicated that it continues to consider how to implement this
    recommendation, the agency had taken no specific actions, as of
    February 2021.
We maintain the importance of our recommendations. Specifically, we
maintain that developing a plan for whether CMS will proceed with the
Nursing Home Commission’s recommendations and, if so, how it will do
so would improve the agency’s ability to systematically consider the
Nursing Home Commission’s recommendations going forward. We also
maintain that collecting data on COVID-19 cases and deaths from nursing
homes retroactively would better inform the government’s continued
response to, and recovery from, the COVID-19 pandemic, and we
maintain that HHS could ease the burden by incorporating data previously
reported to CDC or to state or local public health offices.

We also have recommendations from work completed prior to the
pandemic that have yet to be fully implemented by CMS. Implementation
of these recommendations could improve HHS’s oversight of nursing
homes both generally and during a pandemic. For example, in our 2019
report on abuse in nursing homes, we made six recommendations,
including recommending that CMS require state survey agencies to

1485 Fed. Reg. 27,550, 27,627 (May 8, 2020) (to be codified at 42 C.F.R. § 483.80(g)).
CMS is responsible for ensuring that nursing homes meet federal quality standards to
participate in the Medicare and Medicaid programs.
15Nursing homes are required to self-report data regarding COVID-19 cases and deaths
among residents and staff, PPE supplies, and staffing shortages, among other things, at
least weekly through CDC’s National Healthcare Safety Network.
16Also in September 2020, GAO identified gaps in COVID-19 data for racial and ethnic
minority groups, and, among other things, recommended that CDC take steps to help
ensure its ability to comprehensively assess the long-term health outcomes of persons
with COVID-19, including by race and ethnicity. HHS agreed with the recommendation
and as of February 2021, CDC is reviewing the quality of the demographic data and
assessing potential opportunities to enhance the collection of race and ethnicity data.




Page 11                                                                       GAO-21-402T
immediately notify law enforcement of any reasonable suspicion of a
crime against a resident, and that CMS provide more guidance to state
survey agencies on the information nursing homes should include on
facility-reported incidents. CMS agreed with our recommendations. 17
These recommendations have relevance prior to, during, and after the
COVID-19 pandemic, because with reduced visitors or ombudsmen
presence in nursing homes, and with the decrease or elimination of
surveyor presence, there may be a higher risk of residents being abused
and of that abuse going unreported. 18 This risk is higher than it needs to
be because CMS has not yet implemented our relevant
recommendations.

In addition to monitoring HHS’s implementation of past recommendations,
we have ongoing work examining COVID-19 outbreaks in nursing homes,
as well as CMS’s oversight of infection prevention and control protocols
and the adequacy of emergency preparedness standards for emerging
infectious diseases in nursing homes.

In summary, the COVID-19 pandemic has underscored the importance of
issues we have previously raised about nursing home quality and
oversight while pointing to new vulnerabilities unique to the pandemic.
Effective federal oversight and support for nursing homes are especially
critical during times of widespread disease outbreak, as the pandemic
has demonstrated. As nursing homes are prioritized for vaccination, there
is hope that COVID-19 cases and deaths in these homes will continue to
decline. Going forward, our work on COVID-19 in nursing homes remains
important for informing future pandemic responses, as well as for
addressing longer-standing challenges that have put residents’ health and
safety at risk, as indicated by our prior recommendations.

Chairman Wyden, Ranking Member Crapo, and Members of the
Committee, this concludes my prepared statement. I would be pleased to
respond to any questions that you may have at this time.




17See GAO, Nursing Homes: Improved Oversight Needed to Better Protect Residents
from Abuse. GAO-19-433. (Washington, D.C.: June 13, 2019).
18State surveyors evaluate nursing homes’ compliance with federal quality standards.




Page 12                                                                     GAO-21-402T
                  If you or your staff have any questions about this testimony, please
GAO Contact and   contact John E. Dicken, Director, Health Care at (202) 512-7114 or
Staff             dickenj@gao.gov. Contact points for our Offices of Congressional
                  Relations and Public Affairs may be found on the last page of this
Acknowledgments   statement. GAO staff who made key contributions to this testimony were
                  Karin Wallestad (Assistant Director), Sarah-Lynn McGrath (Analyst-in-
                  Charge), Isabella Guyott, Erin Henderson, Julianne Flowers, Elise
                  Pressma, and Kathryn Richter. Also contributing were Laurie Pachter,
                  Vikki Porter, and Jennifer Whitworth.




                  Page 13                                                      GAO-21-402T
Appendix I: Description of Selected GAO  Appendix I: Description of Selected GAO
                                         Reports on Nursing Homes with


Reports on Nursing Homes with
                                         Recommendations




Recommendations
                                         The following table summarizes the status of relevant recommendations
                                         from GAO’s prior reports on nursing home oversight with the status as of
                                         the most recent detailed update. According to the Centers for Medicare &
                                         Medicaid Services (CMS), as of March 2021, there are no additional
                                         updates on the status of these recommendations, as the agency’s focus
                                         has been on responding to the pandemic.

Table 1: Description of Selected GAO Reports on Nursing Homes with Recommendations, April 2011 through November 2020

Date                Title                                           Summary of recommendations
November 2020       COVID-19: Urgent Actions Needed to Better       GAO made one recommendation related to nursing homes
                    Ensure an Effective Federal Response            that the Centers for Medicare & Medicaid Services (CMS)
                    (GAO-21-191)                                    should quickly develop a plan that further details how the
                                                                    agency intends to respond to and implement, as appropriate,
                                                                    the 27 recommendations in the final report of the Coronavirus
                                                                    Commission on Safety and Quality in Nursing Homes, which
                                                                    CMS released on September 16, 2020. The Department of
                                                                    Health and Human Services (HHS) neither agreed nor
                                                                    disagreed with our recommendation and, as of February
                                                                    2021, HHS/CMS had not implemented this recommendation.
September 2020      COVID-19: Federal Efforts Could Be              GAO made one recommendation related to nursing homes
                    Strengthened by Timely and Concerted Actions    that HHS, in consultation with CMS and the Centers for
                    (GAO-20-701)                                    Disease Control and Prevention (CDC), develop a strategy to
                                                                    capture more complete data on confirmed COVID-19 cases
                                                                    and deaths in nursing homes retroactively to January 1, 2020,
                                                                    in order to address gaps in the new reporting requirements on
                                                                    COVID-19 cases and deaths in nursing homes. HHS partially
                                                                    agreed with this recommendation and, as of February 2021,
                                                                    HHS had not implemented this recommendation.
June 2019           Nursing Homes: Improved Oversight Needed to GAO made six recommendations, including that CMS require
                    Better Protect Residents from Abuse         state survey agencies to immediately notify law enforcement
                    (GAO-19-433)                                of any reasonable suspicion of a crime against a resident,
                                                                and that CMS provide more guidance to state survey
                                                                agencies on the information nursing homes should include on
                                                                facility-reported incidents. HHS agreed with the
                                                                recommendations and, as of February 2020, HHS had not
                                                                implemented these recommendations.
April 2019          Management Report: CMS Needs to Address         GAO made three recommendations, including that CMS
                    Gaps in Federal Oversight of Nursing Home       ensure all state survey agencies are meeting federal
                    Abuse Investigations That Persisted in Oregon   requirements for investigating alleged abuse, and that the
                    for at Least 15 Years                           results are shared with CMS. HHS agreed with the
                    (GAO-19-313R)                                   recommendations and, as of November 2019, HHS had
                                                                    implemented one of the three recommendations.
November 2016       Nursing Homes: Consumers Could Benefit from     GAO made four recommendations, including that CMS
                    Improvements to the Nursing Home Compare        should add information to the Five-Star System that allows
                    Website and Five-Star Quality Rating System     consumers to compare nursing homes nationally. HHS
                    (GAO-17-61)                                     agreed with three of the four recommendations and, as of
                                                                    July 2019, HHS had implemented three of the four
                                                                    recommendations.




                                         Page 14                                                                      GAO-21-402T
                                                  Appendix I: Description of Selected GAO
                                                  Reports on Nursing Homes with
                                                  Recommendations




Date                         Title                                               Summary of recommendations
October 2015                 Nursing Home Quality: CMS Should Continue to GAO made three recommendations, including that CMS
                             Improve Data and Oversight                   implement a clear plan for ongoing auditing of self-reported
                             (GAO-16-33)                                  data and establish a process for monitoring oversight
                                                                          modifications to better assess their effects. HHS agreed with
                                                                          GAO’s recommendations. As of 2020, HHS had implemented
                                                                          these three recommendations.
April 2011                   Nursing Homes: More Reliable Data and               GAO made seven recommendations aimed at ensuring
                             Consistent Guidance Would Improve CMS               CMS’s complaints database is reliable, strengthening CMS’s
                             Oversight of State Complaint Investigations         assessment of state survey agencies’ performance in
                             (GAO-11-280)                                        managing complaints, and increasing accountability for
                                                                                 managing the complaints process. HHS generally agreed with
                                                                                 our recommendations. As of October 2019, HHS had
                                                                                 implemented two of these seven recommendations and
                                                                                 indicated it would not be taking action on a third (GAO closed
                                                                                 this as not implemented).
Source: GAO. | GAO-21-402T

                                                  Note: The hyperlinks to these reports provide additional details about the recommendations and their
                                                  statuses.




                                                  Page 15                                                                               GAO-21-402T
Appendix II: Related GAO Reports
                    Appendix II: Related GAO Reports




CARES Act Reports   COVID-19: Critical Vaccine Distribution, Supply Chain, Program Integrity,
                    and Other Challenges Require Focused Federal Attention. GAO-21-265.
                    Washington, D.C.: January 28, 2021.

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

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

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

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

                    Elder Abuse: Federal Requirements for Oversight in Nursing Homes and
                    Assisted Living Facilities Differ. GAO-19-599. Washington, D.C.: August
                    19, 2019.

                    Nursing Homes: Improved Oversight Needed to Better Protect Residents
                    from Abuse. GAO-19-433. Washington, D.C.: June 13, 2019.

                    Management Report: CMS Needs to Address Gaps in Federal Oversight
                    of Nursing Home Abuse Investigations That Persisted in Oregon for at
                    Least 15 Years. GAO-19-313R. Washington, D.C.: April 15, 2019.

                    Nursing Homes: Consumers Could Benefit from Improvements to the
                    Nursing Home Compare Website and Five-Star Quality Rating System.
                    GAO-17-61. Washington, D.C.: November 18, 2016.

                    Nursing Home Quality: CMS Should Continue to Improve Data and
                    Oversight. GAO-16-33. Washington, D.C.: October 30, 2015.

                    Antipsychotic Drug Use: HHS Has Initiatives to Reduce Use among Older
                    Adults in Nursing Homes, but Should Expand Efforts to Other Settings.
                    GAO-15-211. Washington, D.C.: January 30, 2015.

                    Nursing Homes: More Reliable Data and Consistent Guidance Would
                    Improve CMS Oversight of State Complaint Investigations. GAO-11-280.
                    Washington, D.C.: April 7, 2011.



(105027)
                    Page 16                                                        GAO-21-402T
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