Since July 20, skilled nursing facilities have the availability of various COVID-19 point-of-care (POC) rapid results tests for both residents and staff in order to fulfill the CMS guidance that recommends a baseline test and weekly testing thereafter. Facilities performing POC testing should have a CLIA waiver. For facilities that do not already have a waiver, information on the application is available here.

Each POC test is intended for use with specific specimen types. Facilities are required to use a test authorized for POC by the FDA with adherence to the manufacturer’s instructions for testing.  Inappropriate specimen collection and handling can lead to inaccurate test results. For further information regarding the proper collection of each of the specimen types, education materials and training resources, please refer to CDC’s Interim Guidelines for Collecting, Handling, and Testing Clinical Specimens for COVID-19. 


A “line list” or spreadsheet should be developed to track resident names, facility location, health status, testing dates & results, hospitalizations, isolation discontinuation, etc. for all residents with signs or symptoms consistent with COVID-19. A line list can aid to determine potential outbreak causes such as linking symptoms, location and test results. It is especially important that all information is filled out so that the data can be accurately analyzed.  Also, the line list should be filled out in real time so that the tool can assist with ongoing management instead of a retrospective look back.

COVID-19 Reporting Requirements

In an effort to increase transparency and support COVID-19 surveillance, CMS added further infection control requirements provisions to launch reporting for suspected or confirmed COVID-19 cases.  These provisions for § 483.80 Infection Control may be found here.

Facilities must submit the data through the NHSN at least once every seven days or can submit multiple times within the week. CMS does not mandate a particular day of the week for data submission but recommends consistency with a certain day of each week using the same collection timeframe.  CMS will pull the information every Monday and share the data publicly. CMS has published FAQs to assist with reporting requirements.

Testing Plan

CDC updated Interim COVID-19 Testing Guidelines for Nursing Home Residents and Healthcare Personnel this month.  These guidelines and any new testing updates can be found on CDC’s website.

A testing plan for COVID-19 should be developed for nursing facilities. This plan should include the following:

      • Alignment with state and federal requirements for testing residents and Healthcare Professionals (HCP)
      • Process for testing all residents and HCP and volume to complete
      • When to complete testing (i.e routine surveillance, with symptoms, exposure)
      • Test accessibility and agreement with lab
      • Omit utilization of antibody test results
      • Procedure for addressing residents or HCP who refuse or are unable to be tested


Additional Resources:

Performing Facility-wide SARS-CoV-2 Testing in Nursing Homes


Contact Proactive for support related to infection prevention and control programming, developing a testing plan, and mock survey assistance.


Blog by Kristen Walden, MSN, RN, RAC-CT, Proactive Medical Review

Learn more about Kristen and the rest of the Proactive team.