The official start of summer is here, and that usually mean that we put the “Ftag of the Week” on pause, however, based on demand, we will keep this series on compliance with the Requirements of Participation going throughout the summer. We are going to review the Ftags that are part of the Physical Environment, some of which have very little Interpretive Guidance, but we will provide examples of actual citations to provide some reminders about “dos and don’ts” related to these regulations. We’ll begin this week by looking at F925 Maintains Effective Pest Control Programs.
Regulatory Requirement: F915 requires that a nursing facility maintains an effective pest control program (measures to “eradicate and contain common household pests” so the facility remains free of pests and rodents).
In lieu of Interpretive Guidance, surveyors are instructed to look for signs of vermin when they conduct observations of the facility as well as question staff and residents/representatives regarding whether they have seen any pests in the facility. The guidance section is short but includes the pests that we do not want to reside in our facility – bed bugs, lice, roaches, ants, mosquitos, flies, mice and rats.
So, what can go wrong when a surveyor is looking for signs of vermin or infestation in a certain area? A lot! This Ftag has been cited at an Immediate Jeopardy level multiple times under the LTCSP, ranging all the way from Scope/Severity J (Isolated) through L (Widespread) in facilities throughout the country. The following are examples of actual citations that you can use to reflect on systems in your own building that may need to be tweaked:
- More than a dozen live cockroaches observed in dish area as well as two leaking pipes that were creating wet areas under and on top of equipment – cleaning schedule was reviewed with the Dietary Manager and multiple employee signatures were noted as missing. (S/S: L)
- Infestation of roaches identified in the emergency food storage area and kitchen and then upon further observation, cracked tiles and gaps in door frames were seen, which allowed the pests to enter the areas. The Statement of Deficiencies also noted that the wet kitchen floor allowed the pests to continue thriving by providing necessary moisture. (S/S: L)
- A resident received over 100 ant bites/stings after the facility discovered the resident’s bed had fire ants in it but did not act. Surveyors found live ants in the room even though store-bought bug killer had been sprayed in the room. Multiple unresolved recommendations from the pest company had not been implemented to address such issues as missing window screens, issues with space around door frames and windows propped open to allow extension cords to fit through them. (S/S: K)
- Two residents had live maggots develop in their wounds, with one requiring transfer to the hospital. Flies were noted around multiple residents, and residents were provided with fly swatters to kill the pests, including a resident who did not have the ability to use the swatter. Seals around the windows were noted to be insufficient for keeping pests out. (S/S: J)
- Other identified issues cited at a widespread S/S of F include: presence of drain flies in a kitchen, fruit flies around boxes of bananas in a satellite kitchen, mice observed running along the baseboards in a resident room and a damaged packet of gelatin with holes in it that were likely to have been made by a rodent. Surveyors also observed a homemade gnat trap in one resident’s room, and another where a licensed staff member was trying to kill a spider who “was playing with” her.
As you can see from reading these actual citations, it is easy for surveyors to identify either through observation or interviews that there is a pest issue in a building. It is important that preventative pest control systems are in place to proactively identify any potential issues before they become widespread problems that could impact the quality of care and services being provided in the facility. In most of these cases, staff were aware of the presence of pests but either did not report them to have them addressed or responsible physical plant/maintenance staff did not act on the reported issues. Whatever your protocol is to address pest problems, it needs to include proactive preventative measures in addition to alerting appropriate personnel through a maintenance log, email system or whatever other mechanism your facility uses to ensure that there is a swift response to pest “sightings.”