Background
On July 10, 2020, DHHS updated the COVID-19 Guidance for Hospital Reporting and FAQs (PDF) to reflect new reporting methods and data metrics. Beginning July 15, 2020, hospitals were required to submit COVID-19 data to DHHS using one of several methods, including the TeleTracking portal, HHS Protect, or through the state. CDPH then issued AFL 20-31.2 to notify hospitals that the NHSN system is no longer used for COVID-19 reporting and CDPH will submit data on behalf of hospitals through TeleTracking, beginning July 22, 2020. Hospitals will continue to report to CDPH via the COVID-19 Tracking Tool no later than 12:00 P.M. Pacific Time daily.
On September 2, 2020, the Federal Register published interim final rule CMS-3401-IFC, requiring hospitals and critical access hospitals to report data in accordance with Title 42 CFR sections 482.42(e) and 485.640(d), respectively. AFL 20-31.3 notified GACHs of the new regulatory requirement and enforcement process for reporting COVID-19 data.
COVID-19 Reporting
In accordance with Title 42 CFR section 482.42(e) and DHHS's COVID-19 Guidance for Hospital Reporting and FAQs (PDF), GACHs must continue to report to CDPH via the COVID-19 Tracking Tool no later than 12:00 P.M. Pacific Time daily. The COVID-19 Tracking Tool ensures GACHs report the necessary patient and resource data to support the local, state, and federal public health response to the COVID-19 pandemic.
CDPH will then submit data on behalf of hospitals through TeleTracking.
To facilitate the data transfer to TeleTracking, the California Hospital Association (CHA) worked with CDPH to update the COVID-19 Tracking Tool. This update incorporates data elements requested by DHHS, including information on COVID-19 confirmed and suspected patients, availability of personal protective equipment, medication shortages, remdesivir data and staffing shortages. To ensure consistent reporting across the state, CDPH is providing a data dictionary (PDF) that incorporates the DHHS definitions. GACHs are encouraged to review the data dictionary (PDF) in its entirety before inputting data into the COVID-19 Tracking Tool.
Use of the COVID-19 Tracking Tool will take the place of daily reporting to CDPH district offices, related to the information specified above. Use of this tool will also replace hospital reporting COVID-19 Patient Impact/Hospital Capacity and Healthcare Supply data to DHSS. All other reporting requirements to CDPH district offices will continue using the standard reporting process. CDPH may revise the types of information collected by issuing subsequent AFLs.
Influenza Reporting
Previously, completion of the influenza hospitalization fields in the COVID-19 Tracking Tool was optional; however, in an effort to prevent overwhelming California's healthcare system due to a combination of influenza and COVID-19 patients, CDPH is requiring GACHs to report daily influenza data, beginning November 30, 2021. These data are needed to monitor and mitigate the impacts of COVID-19 on the health care system in the context of influenza season.
GACHs are required to submit information on influenza confirmed and suspected patients to CDPH via the COVID-19 Tracking Tool. The data dictionary (PDF) has been updated to indicate that completion of these fields is now required.
Failure to Report COVID-19 Requirements
Pursuant to CMS QSO 21-03-Hospitals/CAHs (PDF), hospitals that fail to report the specified COVID-19 data elements on a daily basis will receive notification from their CMS Location of their noncompliance with the reporting requirements and any further noncompliance with reporting requirements may result in future enforcement actions.
The following process will occur for failure to report:
- Those providers that have continually failed to meet the reporting requirements for a period of six weeks after receiving an initial notification from CMS will receive the first in a series of enforcement notification letters. At this point, the enforcement actions are now in process and providers will have one calendar week to demonstrate compliance.
- Providers failing to meet the reporting requirements within one calendar week following the first enforcement notification letter will receive a second enforcement notification letter and third enforcement letter, if non-compliant the following week. The third letter will indicate that the provider will have one calendar week to demonstrate compliance with the reporting requirements otherwise the provider will receive a fourth and final enforcement notification letter, as noted in step
- Providers that have failed to meet the reporting requirements within 1 week following the third enforcement notification letter will receive a fourth and final enforcement notification letter. This notification will include a notice of termination to become effective within 30 days from the date of the notification. Failure to meet the reporting requirements within this 30-day timeframe may result in termination of the Medicare provider agreement.
If a hospital receives a notification of noncompliance, the hospital will have an opportunity to provide evidence of compliance. The hospital may submit evidence to CMS within 72 hours of receiving notification of noncompliance. If the hospital is found to be in compliance with the reporting requirements, enforcement remedies will be rescinded. If the enforcement action for failure to report is rescinded and the provider subsequently demonstrates noncompliance with the requirements in the future, a new enforcement action will begin.
Questions
If you have any questions about the COVID-19 Tracking Tool, please email COVIDTracker@calhospital.org. If you have any other questions about this AFL, please contact the CDPH Duty Officer at CHCQDutyOfficer@cdph.ca.gov.
Sincerely,
Original signed by Cassie Dunham
Cassie Dunham
Acting Deputy Director
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