ICYMI: CMS Revises Nursing Facility Testing, Visitation Guidance; Guidance Differentiates “Fully Vaccinated” vs. “Up-To-Date With All Recommended COVID-19 Vaccine Doses”

The Centers for Medicare and Medicaid Services (CMS) announced recently that it has revised two QSO memos, affecting COVID guidance for both visitation and testing policies.

The revised CMS guidance within these two memos now aligns with new CDC guidance, distinguishing between individuals who are “up-to-date with all recommended COVID-19 vaccine doses” and individuals who have received the two-dose series but are due for a booster dose based on CDC recommendations. For example, individuals who received their primary series of vaccines in 2021 but have not yet had a booster shot would not be considered “up-to-date”, but they would be considered “fully vaccinated.”


The testing requirements from CMS now outline a routine testing policy dependent on whether staff are “up-to-date” on their vaccination versus the standard of being “fully vaccinated”. Facilities now must routinely test staff who are not up-to-date on their vaccines at a frequency that is based on county positivity rates.

In addition, facilities must test staff and residents, regardless of vaccination status, that present signs or symptoms of COVID-19 or in an outbreak investigation. More information can be found in CMS’ testing memo.


The visitation requirements from CMS have replaced “vaccinated” with “up-to-date with all recommended COVID-19 vaccine doses” and deleted “unvaccinated.” Visitor screening and quarantine requirements are now aligned with CDC recommendations and have been updated to reflect that visitors will now follow the same quarantine guidelines as residents and should not visit until they have met the criteria to discontinue isolation or quarantine.  ​


WHCA/WiCAL asked DQA shortly after CMS issued these new memos what providers can expect right away with enforcement changes. At the time, DQA officials had not yet reviewed the new guidance. WHCA/WiCAL will update members with any new information received from DQA or CMS.

A potential for confusion with these revised QSO memos is that the CMS vaccine mandate (QSO 22-07-ALL) does not currently use the “up-to-date with all recommended COVID-19 vaccine doses” standard, but instead still uses the “fully vaccinated” standard. (See also F888, §483.80(i) COVID-19 Vaccination of facility staff. The facility must develop and implement policies and procedures to ensure that all staff are fully vaccinated for COVID-19. For purposes of this section, staff are considered fully vaccinated if it has been 2 weeks or more since they completed a primary vaccination series for COVID-19. The completion of a primary vaccination series for COVID-19 is defined here as the administration of a single-dose vaccine, or the administration of all required doses of a multi-dose vaccine.)

If the two revised QSO memos issued this week are any indication, a change to the vaccine mandate to adopt the “up-to-date” standard may be coming. For now, CMS is relying on a different standard for determining staff testing in QSO 20-38-NH-Revised vs the standard for the vaccine mandate. WHCA has asked for clarification on this inconsistency.

Please direct any questions on the newly revised QSO memos to Jim Stoa or Jena Jackson.

Posted in COVID-19