From the Desk of Linda Elizaitis, President, CMS Compliance Group, Inc.
Life in our nursing homes with COVID-19 at or in our door is no fun! The onslaught of COVID-19 will slow and eventually end, and we are all going to have improved infection control practices due to these tough times. We, as an industry, will need to be vigilant about these practices because even after the COVID-19 Focused Surveys end and nursing homes return to a standard survey process we all can expect that the focus on overall compliance with F-880 will remain a prominent fixture of the survey process.
Moving forward, infection prevention and control must remain a “high risk” area for monitoring in the everyday management of each facility. We have been given an excellent guidance tool in CMS’s COVID-19 Focused Survey for Nursing Homes and we will be negligent if we do not use it to monitor our own practices related to outbreak control. Not only do we have that tool we have a vast amount of “free” information from the CDC to use to help us craft an effect Infection Prevention and Control Program that meets an individual facility’s needs. You can then couple that with additional guidance, checklists, etc. that are being provided by your state’s department of health. This playbook is yours to use.
The playbook right now is focused on COVID-19, but an outbreak of another virus can occur so we need to be armed with a comprehensive Infection Prevention and Control Program that we adhere to on a routine basis, which we have not consistently been doing. Infection Control has been the #1 deficiency across the country for a number of years and this is reflective of inconsistency in our practices in such areas as surveillance and associated tracking and trending of infections within our facility, lack of or inappropriate use of personal protective equipment (PPE) or something simpler like a nurse not correctly disinfecting a glucometer used for multiple residents. In many ways we will be in control of our own destiny.
We need to expect and be prepared for a higher level of scrutiny of our Infection Prevention and Control practices during any type of future survey. If you ask any of CMSCG’s clients who utilize our services to conduct a quality review/mock survey, they would tell you that we have been leaning on them for years to pay more attention to infection control practices, including doing staff competencies and provide additional education related to identified unacceptable practices. The current COVID-19 outbreak is a wake-up call to reassess our individual practices and improve them. For example, why did we not really address, when observed, staff not using PPE when entering a room with a resident on contact precautions. We all know better. F-880 just might be your new bedside companion!
I wish success to our industry in winning the COVID-19 battle and good health to each of you.
Linda Elizaitis, RN, BS, RAC-CT, CDS
President, CMS Compliance Group, Inc.