Infection Prevention and Control is a regulatory hot button currently, since as we mentioned in our last post, F880 is the most frequently cited deficiency across the country. This is no surprise, since this regulation encompasses a massive set of expectations. Let’s take a deeper dive into some of the some of the information we provided in Part 1 of our Ftag of the Week for F880 Infection Prevention and Control.
The required policies & procedures for Infection Prevention and Control, per the Interpretive Guidance (IG), include the use of precautions and personal protective equipment (PPE). Let’s review the regulatory expectations in these areas, since they are some of the more frequently cited areas on survey under this tag and warrant taking a closer look at.
Standard infection prevention measures that are applicable to all resident care include hand hygiene, use of PPE, respiratory hygiene/cough etiquette, safe injection practices, and safe handling of equipment/items that could be contaminated with infectious bodily fluids. Just looking at all of the practices included in the prior sentence makes you think about how vulnerable your facility is related to the proper use of standard precautions on a daily basis and your potential exposure (no pun intended) for a deficient practice to be identified on survey. Facilities should ensure that staff understand best practices and expectations around:
- Hand hygiene
- Glove use
- Which PPE to use under which circumstances
- Decontamination (as recommended by the CDC Spaulding classification system)
Regarding decontamination, proper cleaning and disinfecting of items such as glucometers is often done improperly. This is a good area to audit staff competency in to ensure they know what type of disinfection is required if single-use/disposable devices are not in use. There were at least ten Immediate Jeopardy-level citations last year related to staff not following manufacturer’s recommendations for cleansing multi-use glucometers, so it’s important that staff know the required procedures and can demonstrate proper cleaning/disinfection of the device.
The IG states that facility policies must identify the type and duration of transmission-based precautions required, ensuring that the precautions are the least restrictive to the resident and used for the least amount of time. It is essential to minimize any potential negative psychosocial effects that could come about due to isolation for residents on these types of precautions and ensure that their needs are met, including for activities.
There is also a list of what staff should do when a resident is placed on transmission-based precautions, including the use of signage, availability of PPE and how to clean and disinfect a room. This is another area to quiz staff on, since there are many SODs under the LTCSP that provide examples of staff not knowing why a resident is on precautions or what PPE they should be wearing – let’s not forget our vulnerability if a Housekeeper is questioned regarding how he/she cleans the room of a resident on precautions. It is that old bathroom first or last scenario. The opportunity to observe unacceptable infection control practices is readily available to a surveyor, especially since the Entrance Conference Matrix asks for residents on transmission based precautions.
Contact, Droplet and Airborne Precautions
- Contact Precautions – When a resident is on contact precautions, staff must use appropriate PPE that includes a gown and gloves which must be put on before entering the room and removed before exiting the room. Proper hand hygiene must also be conducted before leaving the room.
- Droplet Precautions – Regarding droplet precautions – don’t forget, it’s flu season. Staff need to be wearing facemasks, and not just wearing them, but wearing them appropriately. The IG states that the preferred placement of a resident on droplet precautions is the place the resident in a private room, and if one is not available, to have residents cohorted together or be in a room with a roommate who has limited risk factors.
- Airborne Precautions – For residents on airborne precautions, such as residents with tuberculosis, the residents must be transported to an acute care setting unless the facility has an airborne infection isolation room (AIIR) and can put the resident in that room and keep the door shut. Staff must wear a fitted N95 or higher respirator before entering the resident’s room that they are caring for.
While much of this regulation may seem like common sense regarding practices to prevent the spread of an infection, staff need to have correct infection control practices reinforced to prevent corner-cutting and poor practice. Administration needs to ensure staff are appropriately educated in these areas routinely to help improve not only your survey outcomes, but the quality of care being provided in your facilities. Everyone should have a basic understanding of Infection Control Principles, not just your Infection Preventionist.