In this edition of The State of IJs, we’re spotlighting Immediate Jeopardy (IJ) citations issued to nursing homes across North Dakota. These citations represent the most serious level of noncompliance, where resident safety is at immediate risk. Understanding the patterns behind these citations can help providers proactively address vulnerabilities and improve care outcomes.
Areas of Non-compliance
F880 Infection Prevention and Control
North Dakota, as so many other states do during recertification surveys, considers compliance with Infection Control protocols an important compliance concern that is carefully reviewed. There was an IJ citation at F880 Infection Prevention and Control scope/severity of “J” (isolated) related to a staff nurse’s lack of compliance with standard practices that should have ben followed during a dressing change for a resident requiring enhanced barrier precautions (EBP) related MRSA in their wound.
The IJ was a simple, straightforward deficiency identified by the surveyor during a dressing change. What happened? Simply this – the staff nurse performed a dressing change in the medication room and failed to wear PPE. There obviously was no need to conduct a lengthy investigation as the poor practices of the nurse were apparent. You could not argue with this citation related to the failure to follow infection control practices related to location of a dressing change and EBP having the potential to spread infection throughout the facility.
FYI – a directive was issued after this observation and IJ being cited to indicate that the medication room must not be used to complete wound treatments along with other reminders, including use of appropriate PPE.
My thoughts? Someone should have prepped this nurse if she/he was going to be observed for treatment administration. This common scenario is a great reminder of the importance of monitoring staff performance of their routine responsibilities on a routine basis and implementing corrective actions as needed. A facility should couple this with having nurses complete a treatment administration competency every six (6) months so that they maintain proper infection control practices.
F689 Free of Accident Hazards/ Supervision/ Devices
An area with more than one (1) IJ citation is the infamous F689 Free of Accident Hazards/ Supervision / Devices. One situation was related to two (2) residents with orders for electric heating pad use. I must share that I do not believe that this is an order that is widely used because use of these devices is such high risk. In this facility, one (1) resident use of a heating pad resulted in a burn and placed another specific resident at risk for burns as well as mentioning the risk to all other residents who used a heating pad.
The resident identified in this recertification survey citation sustained a first degree burn to their right hip. The heating pad was reported as set at medium and was left in place for three (3) hours versus up to twenty (20) minutes. A Nursing Notes stated that the heating pad was left on the patient for about five (5) hours. The resident is attributed with commenting that the heating pad was turned up too high yesterday and “fried her.” The resident required a treatment to be ordered to the site for healing.
Per facility practices, the CNAs apply/remove the ordered heating pads and sign for their use on the TAR. Unfortunately, the resident’s TAR did not include time parameters for application/removal even though the order included time parameters. The other resident mentioned in the SOD had a heating pad, but no order for use – staff also shared that residents have their own electric heating pads that they use at their own discretion. I was personally surprised at the number of residents identified with orders for use of heating pads, but I was not surprised at the corrective actions implemented to remove the IJ situation, including discarding all facility-owned heating pads, revising the facility policy and updated the admission handbook.
There was another portion of the deficiency related to use of assistive devices for transfer and another section that addressed the environment not being kept free of accident hazards regarding the storage of chemical products used by Housekeeping staff. These issues were not noted as being at an IJ level.
Rounding out this review is another F689 citation at another facility. This deficiency is related a facility’s failure to utilize devices necessary to prevent accident and/or injury. This “J” scope/severity citation is associated with a complaint investigation that occurred related to the facility’s self-reporting of the occurrence. One resident sustained a fall with an injury related to staff not utilizing the spa chair safety belt. The resident’s fall resulted in the resident sustaining a nasal fracture. The lack of using a shower chair or spa chair or safety belts or other safety devices during provision of showers or baths is not an uncommon practice. Staff are trained but for whatever reason do not consistently apply the safety devices as per policy. Another not-so-rare scenario is the belt/security device breaks, and it goes unreported until a resident slips from the chair – some of these falls result in serious fracture and/or lacerations.
Compliance Insights
Here’s what providers need to consider to avoid citations in these area.
- Never take compliance with staff adherence to proper Infection Control practices and full compliance with your facility’s Infection Control policies off your radar. The never-ending reminders of correct practices are a must and should be coupled with reeducation and competencies in certain tasks.
- Accident and Fall Prevention need to be more than an annual review. It takes ongoing monitoring to ensure that your staff is following protocols and understands the importance of adhering to all accident and fall prevention strategies that your clinical team has outlined in a resident’s care plan. Do you ever ask a CNA if they know what the preventative plan is for a specific resident?
The Best Way to Handle an IJ? Prevent It.
Our consultants help nursing homes strengthen their compliance infrastructure with targeted mock surveys, staff education, and system reviews.
Reach out today at (631) 692-4422 or info@cmscg.net.
