CMS Mandates Use of Enhanced Barrier Precautions (EBP)

If you’ve been delaying the use of Enhanced Barrier Precautions (EBP) in your nursing home since the CDC introduced this PPE strategy in 2019, it’s time to take another look. In a March 20, 2024 QSO Memo, the Centers for Medicare & Medicaid Services (CMS) announced that it will require nursing homes to implement use of Enhanced Barrier Precautions (EBP) effective April 1, 2024 – and this is when surveyors will begin to review this area.

CMS has incorporated the new regulatory guidance under F880 Infection Prevention and Control. Updated survey documents will be available for these requirements, and CMSCG will post a link once they are available. On your next survey, expect surveyors to evaluate your facility’s use of EBP when residents have been identified for the use of EBP related to CDC-targeted MDROs. Facilities have discretion in using EBP for residents who do not have a chronic wound or indwelling medical device and are infected or colonized with an MDRO that isn’t currently being targeted by the CDC.

Why EBP?

Multidrug resistant organism (MDRO) transmission is high in nursing homes, and this increases the risk of more residents becoming colonized and being infected with MDROs. In 2019, the Centers for Disease Control (CDC) issued information on Enhanced Barrier Precautions, which help to reduce the transmission of MDROs where contact precautions do not apply. The CDC has been targeting a set of MDROs with this approach ever since. In 2021, per the QSO Memo, a white paper found that more than 50% of nursing home residents may be colonized with MDROs, but use of contact precautions, especially restricting residents to their rooms, could negatively impact quality of life.

The CDC updated its EBP recommendations in July 2022 guidance. CMS is updating its infection control guidance to align with these recommendations. Key recommendations to be aware of include:

• EBP should be used for high-contact care activities for residents who have chronic wounds or indwelling medical devices, regardless of their MDRO status.
• EBP should be used for residents who have an infection or colonization with a CDC-targeted/ other epidemiologically important MDRO when contact precautions do not apply.

View QSO-24-08-NH, “Enhanced Barrier Precautions in Nursing Homes,” here. Also – check out our next Ftag of the Week post, where we’ll review the new guidance for Enhanced Barrier Precautions under F880.