CMS Releases LTC Testing Mandate Details

On Wednesday, August 16, CMS released 2 new QSO memoranda related to COVID-19 testing for LTC providers. QSO-20-38-NH provides detailed guidance on the mandatory testing requirements for LTC providers for residents and staff and revises the COVID-19 Focused Infection Control Survey tool. The Interim Final Rule released yesterday provided the authority for CMS to mandate testing parameters for all Medicare and Medicaid certified SNF/NF providers across the country. Additionally, CMS released  QSO-20-37-CLIA, NH which sets the standards for reporting COVID-19 test results, also related to yesterday’s Interim Final Rule.

LTC Staff & Resident Testing Requirements (New Tag F886)

The memorandum outlines Trigger Testing Requirements and Routine Testing Requirements as summarized below. Note that LTC providers should continue screening staff, residents, and all persons entering the building regardless of the frequency of testing. All COVID-19 tests require an order from a medical provider authorized under state law to order laboratory services.

Staff includes “employees, consultants, contractors, volunteers, and caregivers who provide care and services to residents on behalf of the facility, and students in the facility’s nurse aide training programs or from affiliated academic institutions.” Regarding individuals providing services under arrangement or volunteers, the LTC provider should prioritize testing for individuals who are regularly in the building (exp. weekly) and have contact with residents or staff. Individuals that are required to be tested from another source such as their employer do not alleviate the requirement for documentation of testing that complies with the memorandum. All testing shall be document that it was completed with the results of each staff test. The resident record should include documentation that the testing was offered, completed as appropriate, and the results of each test.

Trigger Testing Requirements

Testing Trigger



Symptomatic Individual

Staff with signs and symptoms must be tested

Residents with signs and symptoms must be tested

Outbreak (Any new cases arising in the facility—nursing home onset.)

Test all staff that previously tested negative every 3 to 7 days until testing identifies no new cases for a period of 14 days. 

Test all residents that previously tested negative every 3 to 7 days until testing identifies no new cases for a period of 14 days. 


Routine Testing Requirements

LTC providers should track their 7-day county positivity report every other week and adjust their testing frequency based on the rate for the prior week to comply the following table. If the rate increases to a higher rate, staff should be tested as outlined for the higher rate in the following table.  If the positivity rate decreases to a lower level, staff testing should not adjust to the lower level in the following chart until the positivity rate has held at the lower level for at least 2 weeks. 

Community COVID-19 Activity

County Positivity Rate for Past Week

Minimum Testing Frequency



Once a Month



Once a week



Twice a week


The routine testing requirements assume the availability of Point of Care testing onsite or where off-site testing turnaround is 48 hours or less. If this cannot be met due to community testing supply shortages or processing delays, the LTC provider should document their efforts to obtain quick turnaround testing with the identified lab and contact the public health department.   

Note that routine testing of asymptomatic residents is NOT recommended unless triggered by an outbreak.

Testing Refusals

LTC providers must have procedures in place for staff who refuse testing to ensure that any staff person with signs and symptoms of COVID-19 are prohibited to return to work until criteria are met. If a staff member refuses testing during an outbreak, the staff member should be restricted from the building until the outbreak testing procedures have been completed.

LTC providers must also have procedures in place for residents who refuse testing. Residents who have been exposed or have symptoms and who decline testing should be placed on transmission-based precautions until they meet the symptom-based criteria for discontinuation. Residents who decline testing during an outbreak should be monitored extremely closely, maintain appropriate distance from other residents, wear a face covering, and practice effective hand hygiene until the procedures for outbreak testing have been completed.

Residents and Staff Recovered from COVID-19

Consistent with CDC guidelines, staff and residents who have recovered form COVID-19 and are asymptomatic do not need to be retested within 3 months after symptom onset. After 3 months, testing is encouraged again.

Reporting Testing Results

All COVID-19 test results must be reported to the department of public health the same day the test was performed or be subject to civil monetary penalties. LTC providers receiving antigen machines will be contacted by IDPH to establish an electronic reporting mechanism for both positive and negative test results. See also QSO-20-37-CLIA, NH and IDPH Guidance.


LAI testing resources and templates can be found at