Ask Proactive – I’ve assumed a new role that requires me to audit our compliance with reporting to NHSN. The instructions for completion of the LTCF COVID-19 module are not clear in some areas. For example, we are the designated COVID-19 unit amongst two sister facilities. If the patient acquires COVID in my sister facility, then transfers to my facility, and passes away due to the infection, do I have to count this as a resident COVID death in my facility?

I’ve assumed a new role that requires me to audit our compliance with reporting to NHSN. The instructions for completion of the LTCF COVID-19 module are not clear in some areas. For example, we are the designated COVID-19 unit amongst two sister facilities. If the patient acquires COVID in my sister facility, then transfers to my facility, and passes away due to the infection, do I have to count this as a resident COVID death in my facility?

A:

You’re exactly right. The instructions on Page 11 of the Instructions for Completion of the COVID-19 Long-term Care Facility (LTCF) Resident Impact and Facility Capacity Pathway Form are not clear. According to our communication with NHSN, if a resident is transferred to another facility, the originating facility is responsible for reporting the death of that resident. If the resident is officially discharged from the originating facility (not expected to return), then it is NOT the responsibility of the originating facility to report the death. The important difference for when to report the death of a resident is contingent upon if that resident was transferred or discharged. If the resident was transferred, then the originating facility (your sister facility) will need to follow that resident and report the death if that were to occur.

Provider reporting questions can be sent to nhsn@cdc.gov. Their response time is usually a 7-9 day turnaround.