CMS Memorandum Clarifies Hepatitis C (HCV) Screening Exception for End Stage Renal Disease

PUBLISHED: Jul 14, 2017
Relevant to: Dialysis Facilities

The US Centers for Medicare and Medicaid Services Conditions for Coverage (CfCs) for End Stage Renal Disease (ESRD) facilities require infection control procedures which demonstrate that a facility follows standard infection control precautions including routine serological testing and immunization, surveillance, training and education.

The CfCs incorporate, within its provisions, recommendations found in “Recommendations for Preventing Transmission of Infections among Chronic Hemodialysis Patients,” developed by the Centers for Disease Control and Prevention (CDC). Specifically, the CfCs at §494.30(a) require dialysis facilities to follow the above CDC recommendations for routine serologic testing and immunization, surveillance, and training and education, with the exception of screening for Hepatitis C (HCV).

In a recent memorandum, CMS clarifies that, pursuant to the above regulatory exclusion, surveyors should not cite ESRD facilities for a failure to conduct routine, or periodic screening for HCV. Most hemodialysis patients with a newly acquired HCV infection have elevated liver enzyme results, specifically serum Alanine Aminotransferase (ALT) results. ALT testing is performed monthly for all patients in renal dialysis facilities. Consequently, if a patient has an elevated ALT, the provider may order a diagnostic hepatitis panel, which includes a HCV antibody test as part of the panel.

Any indication that there may have been a transmission of HCV among facility patients or staff would indicate the need for the ESRD facility to evaluate the adequacy of its infection control practices.

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