Regulatory Affairs: Update on COVID-19 Vaccine Reporting

Confused about what CMS requires now? We’ve got you covered.

May 11 was declared the end of the Federal COVID-19 Public Health Emergency Declaration, but facilities that report through the Healthcare Personnel Safety (HPS) component of the National Healthcare Safety Network (NHSN) — such as hospitals and ASCs — are still required to continue reporting employees’ vaccination status to the database.

The healthcare personnel COVID-19 vaccination data reporting requirement remains at the rate of at least one week per month for each reporting quarter. The facility can select any week within the month to report data, until updates to the reporting requirements are made. NHSN recently posted an update with the changes to the reporting requirements that went into effect June 26, 2023.

There has been much anticipation over the update to the COVID-19 healthcare personnel vaccine reporting requirements by ASC and healthcare leaders, as well as a good deal of confusion.

Clarity lacking

Leaders have been waiting for the update, some in hopes vaccine reporting requirements would be decreased or possibly eliminated altogether. If we’re being honest, who hasn’t been getting anxious? I, too, was waiting not so patiently for the update to communicate any major changes. I also thought I could find the information easily and communicate it to assist healthcare leaders in maintaining compliance.

Keep in mind that I have access to several outstanding resources, and I still was surprised at how difficult it was to find the most current information. Finding the current requirements was a scavenger hunt of websites, blog posts, FAQs and other sources that aren’t even worth mentioning. Many of the resources haven’t been updated since the end of the public health emergency or include information specifically designed for height-of-the-pandemic conditions — and are no longer applicable.

Was I looking for something that didn’t exist? There was supposed to be a major update in the reporting requirements. I was able to find a few minor updates, but I couldn’t help but thinking, “Am I missing something?” Well let me save you some time, the changes are minor.

Updated definitions, questions removed

Unfortunately, leaders may not get the relief they were hoping for from CMS this time around, but there are a few changes worth noting. To start, some definitions have been updated and two questions were removed from the form. Effective June 26, 2023, according to the CDC:

• A Complete Primary Series is defined as receiving a two-dose series of a monovalent COVID-19 vaccine OR a single-dose of Janssen OR a single-dose of a bivalent vaccine.

• Healthcare personnel are considered up to date with their COVID-19 vaccinations if they have received an updated bivalent vaccine. This definition is the same for all individuals, regardless of age and immunocompromised status.

Many of the resources haven’t been updated since the end of the public health emergency or include information specifically designed for height-of-the-pandemic conditions.

The Quality Reporting Requirements will continue to include the primary COVID-19 vaccine series for healthcare personnel at this time. The changes to the weekly COVID-19 vaccination for healthcare professionals form includes the removal of the following questions:

• 2.1 “Only one dose of a two-dose primary COVID-19 vaccine series 2.2,” and

• 4 “Individuals with a complete primary series vaccine who have received any booster(s) or additional dose(s) of COVID-19 vaccine since August 2021.”

The reporting requirements aren’t expected to see major changes any time soon. Rest assured, though, I’ll be watching for them and will provide updates as soon as they become available. OSM