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We recommend that the Centers for Medicare & Medicaid Services assess the costs and benefits of implementing the following recommendations and if CMS determines that the benefits outweigh the costs, take action to develop a process to identify nursing homes that do not report required data for all of the data elements related to COVID-19 cases and deaths among residents and staff and PPE and supplies and request that they submit the required data.

We recommend that the Centers for Medicare & Medicaid Services assess the costs and benefits of implementing the following recommendations and if CMS determines that the benefits outweigh the costs, take action to revise its quality assurance checks for ratios 1, 3, 5, and 6, which use the number of all beds in the denominator, to ensure that it does not exclude from its COVID-19 data nursing homes' data that should be included.

We recommend that the Centers for Medicare & Medicaid Services assess the costs and benefits of implementing the following recommendations and if CMS determines that the benefits outweigh the costs, take action to revise its quality assurance checks for ratios 2 and 4, which use the numbers of confirmed cases and admissions among residents and confirmed cases among staff in the denominator, by adding the number of suspected COVID-19 cases to the denominator in both ratios and adjust the ratios' thresholds to reflect the change.

We recommend that the Centers for Medicare & Medicaid Services assess the costs and benefits of implementing the following recommendations and if CMS determines that the benefits outweigh the costs, take action to identify the nursing homes that reported more total COVID-19 deaths than total deaths from any cause and request that they verify or correct the reported data.

We recommend that the Centers for Medicare & Medicaid Services assess the costs and benefits of implementing the following recommendations and if CMS determines that the benefits outweigh the costs, take action to contact nursing homes that failed quality assurance checks to verify the accuracy of reported data or to correct inaccurate data.

We recommend that the Centers for Medicare & Medicaid Services assess the costs and benefits of implementing the following recommendations and if CMS determines that the benefits outweigh the costs, take action to work with CDC and with State health departments to determine the feasibility of using comparable data elements to collect COVID-19 data and the feasibility of monitoring substantial differences in the data and, if determined feasible, take actions to provide the public with more complete and accurate COVID-19 data for nursing homes.