-1.png?height=120&name=Logo-KrisB%20(1)-1.png){kind=logo}
|
Infection Control: This facility task must be used to investigate compliance at F880, F881, F882, F883, F885, and F886. For the purpose of this task, “staff” includes all facility staff (direct and indirect care functions), contracted staff, consultants, volunteers, others who provide care and services to residents on behalf of the facility, and students in the facility’s nurse aide training programs or from affiliated academic institutions. The infection prevention and control program (IPCP) must be facility-wide and include all departments and contracted services. If a specific care area concern is identified, it should be evaluated under the specific care area, such as for pressure ulcers, respiratory care, catheter care, and medication pass observations which include central lines, peripheral IVs, and oral/IM/respiratory medications.
Entry and screening procedures as well as resident care guidance have varied over the progression of COVID-19 transmission in facilities. Facilities are expected to be in compliance with CMS requirements and surveyors will use guidance that is in effect at the time of the survey. Refer to QSO memos released at: https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Policy-and-Memos-to- States-and-Regions.
If citing for noncompliance related to COVID-19, the surveyor(s) must include the following language at the beginning of the Deficient Practice Statement or other place determined appropriate on the Form CMS-2567: “Based on [observations/interviews/record review], the facility failed to [properly prevent and/or contain – or other appropriate statement] COVID-19.”
Please Note: Surveyors conducting a COVID-19 Focused Infection Control (FIC) Survey for Nursing Homes (not associated with a recertification survey), must evaluate the facility’s compliance at all critical elements (CE) with the exception of CE#8 and CE#9. The surveyor must also examine the facility’s compliance at §483.73(b)(6) or E0024 (at Appendix Z) if the full Emergency Preparedness survey is not being conducted. |
|
Coordination: Each surveyor is responsible for assessing the facility for breaks in infection control throughout the survey and is to answer CEs of concern (e.g., standard and transmission based precautions, source control). One surveyor performs or coordinates (e.g., immunization review) the facility task to review for: · Standard and transmission-based precautions · Resident care for COVID-19 · Infection Prevention and Control Program (IPCP) standards, policies, and procedures · Infection surveillance · Visitor entry · Education, monitoring, and screening of staff · Staff and resident COVID-19 testing · Suspected or confirmed COVID-19 reporting to residents, representatives, and families · Laundry services · Antibiotic stewardship program · Infection Preventionist · Influenza and pneumococcal immunizations Sample residents/staff as follows: · Sample three staff, include at least one staff member who was confirmed COVID-19 positive or had signs or symptoms consistent with COVID-19 (if this has occurred in the facility), for purposes of determining compliance with infection prevention and control national standards such as exclusion from work, as well as screening, testing, and reporting. · Sample three residents for purposes of determining compliance with infection prevention and control national standards such as transmission-based precautions, as well as resident care, screening, testing, and reporting. o Include at least one resident who was confirmed COVID-19 positive or had signs or symptoms consistent with COVID-19 (if any). o Include at least one resident on transmission-based precautions (if any), for any reason other than COVID-19. · Sample five residents for influenza and pneumococcal immunizations.
Standard and Transmission-Based Precautions (TBPs) State and Federal surveyors should not cite facilities for not having certain supplies (e.g., Personal Protective Equipment (PPE) such as gowns, N95 respirators, surgical masks) if they are having difficulty obtaining these supplies for reasons outside of their control (e.g., national or regional shortage). However, we do expect facilities to take actions to mitigate any resource shortages and show they are taking all appropriate steps to obtain the necessary supplies as soon as possible. For example, if there is a shortage of PPE, the facility should contact their healthcare coalition (https://www.phe.gov/Preparedness/planning/hpp/Pages/find-hc-coalition.aspx) or public health authorities for assistance, follow national and/or local guidelines for optimizing their current supply, or identify the next best option to care for residents. Among other practices, optimizing their current supply may mean prioritizing use of gowns based on risk of exposure to infectious organisms, blood or body fluids, splashes or sprays, high contact procedures, or aerosol generating procedures (AGPs), as well as possibly extending use of PPE (follow national and/or local guidelines). Current CDC guidance for healthcare professionals is located at: https://www.cdc.gov/coronavirus/2019-nCoV/hcp/index.html and healthcare facilities is located at: https://www.cdc.gov/coronavirus/2019-ncov/hcp/us-healthcare-facilities.html. Guidance on strategies for optimizing PPE supply is located at: https://www.cdc.gov/coronavirus/2019-ncov/hcp/ppe-strategy/index.html. If a surveyor believes a facility should be cited for not having or providing the necessary supplies, the State Agency should contact the CMS Regional Location.
General Standard Precautions: Staff are performing the following appropriately: · Respiratory hygiene/cough etiquette, · Environmental cleaning and disinfection, and · Reprocessing of reusable resident medical equipment (e.g., cleaning and disinfection of glucometers per device and disinfectant manufacturer’s instructions for use).
Hand Hygiene: Appropriate hand hygiene practices (i.e., alcohol-based hand rub (ABHR) or soap and water) are followed. Staff wash hands with soap and water when their hands are visibly soiled (e.g., blood, body fluids), or after caring for a resident with known or suspected C. difficile infection (CDI) or norovirus during an outbreak, or if endemic rates of CDI are high. ABHR is not appropriate to use under these circumstances. Staff perform hand hygiene (even if gloves are used) in the following situations: · Before and after contact with the resident; · After contact with blood, body fluids, or visibly contaminated surfaces; · After contact with objects and surfaces in the resident’s environment; · After removing personal protective equipment (e.g., gloves, gown, eye protection, facemask); and · Before performing a procedure such as an aseptic task (e.g., insertion of an invasive device such as a urinary catheter, manipulation of a central venous catheter, and/or dressing care). When being assisted by staff, resident hand hygiene is performed after toileting and before meals. How are residents reminded to perform hand hygiene? Interview appropriate staff to determine if hand hygiene supplies (e.g., ABHR, soap, paper towels) are readily available and who they contact for replacement supplies.
Personal Protective Equipment (PPE) Use For Standard Precautions: Determine if staff appropriately use and discard PPE including, but not limited to, the following: · Gloves are worn if potential contact with blood or body fluid, mucous membranes, or non-intact skin; · Gloves are removed after contact with blood or body fluids, mucous membranes, or non-intact skin (and hand hygiene performed); · Gloves are changed and hand hygiene is performed before moving from a contaminated body site to a clean body site during resident care; · An isolation gown is worn for direct resident contact if the resident has uncontained secretions or excretions (e.g., changing a resident and their linens when excretions would contaminate staff clothing); · Appropriate mouth, nose, and eye protection (e.g., facemasks, goggles, face shield) along with isolation gowns are worn for resident care activities or procedures that are likely to contaminate mucous membranes, or generate splashes or sprays of blood, body fluids, secretions or excretions; · All staff are wearing a facemask (e.g., a cloth face covering can be used by staff where PPE is not indicated, such as administrative staff who are not at risk of coming in contact with infectious materials); · When COVID-19 is present in the facility, staff are wearing an N95 or equivalent or higher-level respirator, instead of a facemask for aerosol generating procedures; · PPE is appropriately discarded after resident care, prior to leaving room (except in the case of extended use of PPE per national and/or local recommendations), followed by hand hygiene; · During the COVID-19 public health emergency, PPE use is extended/reused in accordance with national and/or local guidelines. If reused, PPE is cleaned/decontaminated/maintained after and between uses; and · Supplies necessary for adherence to proper PPE use (e.g., gloves, gowns, masks) are readily accessible in resident care areas (e.g., nursing units, therapy rooms). Interview appropriate staff to determine if PPE supplies are readily available, accessible, and used by staff, and who they contact for replacement supplies. · Are there sufficient PPE supplies available to follow infection prevention and control guidelines? In the event of PPE shortages, what procedures is the facility taking to address this issue? · How do you obtain PPE supplies before providing care? · Who do you contact for replacement supplies?
Source Control for COVID-19: Ensure residents (when receiving visitors or while outside of their room), visitors, and others at the facility are donning a cloth face covering or facemask while in the facility or while around others outside.
Transmission-Based Precautions (TBP): Determine if appropriate transmission-based precautions are implemented, including but not limited to: · For a resident on contact precautions: staff don gloves and isolation gown before contact with the resident and/or his/her environment; · For a resident on droplet precautions: staff don a facemask and eye protection (goggles or face shield) within six feet of a resident and prior to resident room entry (certain PPE should already be in use because of COVID-19); · For a resident on airborne precautions: staff don a fit-tested N95 or higher level respirator prior to room entry of a resident; · For a resident with an undiagnosed respiratory infection (and tested negative for COVID-19): staff follow standard, contact, and droplet precautions (i.e., facemask, gloves, isolation gown) with eye protection when caring for a resident unless the suspected diagnosis requires airborne precautions (e.g., tuberculosis); · For a resident with known or suspected COVID-19: staff wear gloves, isolation gown, eye protection and an N95 or higher-level respirator if available. A facemask is an acceptable alternative if a respirator is not available. When COVID-19 is identified in the facility, staff wear all recommended PPE (i.e., gloves, gown, eye protection and respirator or facemask) for the care of all residents on the unit (or facility-wide based on the location of affected residents), regardless of symptoms (based on availability). o Some procedures performed on residents with known or suspected COVID-19 could generate infectious aerosols (i.e., aerosol-generating procedures (AGPs)). In particular, procedures that are likely to induce coughing (e.g., sputum induction, open suctioning of airways) should be performed cautiously. If performed, the following should occur: § Staff in the room should wear an N95 or higher-level respirator, eye protection, gloves, and an isolation gown; § The number of staff present during the procedure should be limited to only those essential for resident care and procedure support; § AGPs should ideally take place in an airborne infection isolation room (AIIR). If an AIIR is not available and the procedure is medically necessary, then it should take place in a private room with the door closed; and § Clean and disinfect the room surfaces with an appropriate disinfectant. Use disinfectants on EPA’s List N: Disinfectants for Coronavirus (COVID-19) or other national recommendations. · Dedicated or disposable noncritical resident-care equipment (e.g., blood pressure cuffs, blood glucose monitor equipment) is used, or if not available, then reusable resident medical equipment is cleaned and disinfected according to manufacturers’ instructions using an EPA-registered disinfectant for healthcare settings and effective against the identified organism (if known) prior to use on another resident. · Objects and environmental surfaces that are touched frequently and in close proximity to the resident (e.g., bed rails, over-bed table, bedside commode, lavatory surfaces in resident bathrooms) are cleaned and disinfected with an EPA-registered disinfectant for healthcare settings and effective against the organism identified (if known) at least daily and when visibly soiled. · Signage on the use of specific PPE (for staff) is posted in appropriate locations in the facility (e.g., outside of a resident’s room, wing, or facility-wide). Observe staff to determine if they use appropriate infection control precautions when moving between resident rooms, units and other areas of the facility. Interview appropriate staff to determine if they are aware of processes/protocols for transmission-based precautions and how staff is monitored for compliance. If concerns are identified, expand the sample to include more residents on transmission-based precautions.
1. Did the staff implement appropriate standard (e.g., hand hygiene, appropriate use of PPE, environmental cleaning and disinfection, and reprocessing of reusable resident medical equipment) and transmission-based precautions (if applicable)? Yes No F880
Resident Care for COVID-19 Residents on transmission-based precautions are restricted to their rooms except for medically necessary purposes. If these residents have to leave their room, they are wearing a facemask or cloth face covering, performing hand hygiene, limiting their movement in the facility, and performing social distancing (efforts are made to keep them at least 6 feet away from others). The facility ensures only COVID-19 negative, and those not suspected or under observation for COVID-19, participate in group outings, group activities, and communal dining. The facility is ensuring that residents are maintaining social distancing (e.g., limited number of people in areas and spaced by at least 6 feet), performing hand hygiene, and wearing cloth face coverings. The facility has a plan (including appropriate placement and PPE use) to manage residents that are new/readmissions under observation, those exposed to COVID-19, and those suspected of COVID-19. These actions are based on national (e.g., CDC), state and/or local public health authority recommendations. The facility has a plan to prevent transmission, including a dedicated space in the facility for cohorting and managing care for residents with COVID-19. These actions are based on national (e.g., CDC), state and/or local public health authority recommendations. For residents who develop severe symptoms of illness and require transfer to a hospital for a higher level of care, the facility alerts emergency medical services and the receiving facility of the resident’s diagnosis (suspected, observation, or confirmed COVID-19) and precautions to be taken by transferring and receiving staff as well as place a facemask or cloth face covering on the resident during transfer (as tolerated). For residents who need to leave the facility for care (e.g. dialysis, etc.), the facility notifies the transportation and receiving health care team of the resident’s suspected, observation, or confirmed COVID-19 status.
2. Did staff provide appropriate resident care for COVID-19 related concerns? Yes No F880
IPCP Standards, Policies, Procedures and Education: The facility established a facility-wide IPCP including written IPCP standards, policies, and procedures that are current and based on the facility assessment [according to 483.70(e)] and national standards (e.g., for undiagnosed respiratory illness and COVID-19). The facility’s policies or procedures include which communicable diseases are reportable to local and/or state public health authorities and contain when to notify if there are clusters of respiratory illness or cases of COVID-19 that are identified or suspected. The facility has a current list of reportable communicable diseases. Staff (e.g., nursing and unit managers) can identify and describe the communication protocol with local/state public health officials (e.g., to whom and when communicable diseases, healthcare-associated infections (as appropriate), and potential outbreaks must be reported). There is evidence the facility has provided education to staff on COVID-19 (e.g., symptoms, how it is transmitted, screening criteria, work exclusions). How does the facility convey updates on COVID-19 to all staff? The policies and procedures are reviewed at least annually. Concerns must be corroborated as applicable including the review of pertinent policies/procedures as necessary.
3. Does the facility have a facility-wide IPCP including standards, policies, procedures and education that are current, based on national standards, and reviewed at least annually? Yes No F880
Infection Surveillance: The facility has a screening process that all staff must complete prior to or at the beginning of their shift that reviews for signs/symptoms of illness and must include whether fever is present. The facility is documenting staff with signs/symptoms (e.g., fever) of COVID-19 according to their surveillance plan. Interview staff to determine what the screening process is, if they have had signs/symptoms of COVID-19 during the screening process, who they discussed their positive screening with at the facility and what actions were taken (e.g., work exclusion, COVID-19 testing). If staff develop symptoms at work (as stated above), the facility: · Informs the facility’s infection preventionist and includes information on individuals, equipment, and locations the person came in contact with; and · Follows current guidance about returning to work (e.g., local health department, CDC: https://www.cdc.gov/coronavirus/2019- ncov/healthcare-facilities/hcp-return-work.html). The facility identifies the number of residents and staff in the facility, if any, that have fever, respiratory signs/symptoms, or other signs/symptoms related to COVID-19. The facility identifies the number of residents and staff, if any, that have been diagnosed with COVID-19 and when the first case was confirmed. The facility prohibits employees with a communicable disease or infected skin lesions from direct contact with residents or their food, if direct contact will transmit disease. Staff are excluded from work according to national standards. The facility has established/implemented a surveillance plan, based on a facility assessment, for identifying, tracking, monitoring and/or reporting of infections. For COVID-19 that includes resident surveillance of fever, respiratory illness, or other signs/symptoms of COVID-19 at least daily, and immediately isolate anyone who is symptomatic. The plan includes early detection, management of a potentially infectious, symptomatic resident that requires laboratory testing and/or the implementation of appropriate transmission-based precautions/PPE (the plan may include tracking this information in an infectious disease log). The plan uses evidence-based surveillance criteria (e.g., CDC NHSN Long-Term Care or revised McGeer Criteria) to define infections and the use of a data collection tool. The plan includes ongoing analysis of surveillance data and review of data and documentation of follow-up activity in response. The facility has a process for communicating at time of transfer to an acute care hospital or other healthcare provider the diagnosis to include infection or multidrug-resistant organism colonization status, special instructions or precautions for ongoing care such as transmission-based precautions, medications [e.g., antibiotic(s)], laboratory and/or radiology test results, treatment, and discharge summary (if discharged). The facility has a process for obtaining pertinent notes such as discharge summary, lab results, current diagnoses, treatment, and infection or multidrug-resistant organism colonization status when residents are transferred back from acute care hospitals. Interview appropriate staff to determine if infection control concerns are identified, reported, and acted upon.
4. Did the facility provide appropriate infection surveillance? Yes No F880
Visitor Entry Review for compliance of: · Screening processes and criteria (i.e., screening questions and assessment of illness); · Visitation is conducted according to residents’ rights for visitation and in a manner that does not lead to transmission of COVID-19; and · Signage posted at facility entrances for screening and restrictions as well as a communication plan to alert visitors of new procedures/restrictions. The facility instructs those permitted entry to frequently perform hand hygiene; limit their interactions with others in the facility and surfaces touched; restrict their visit to the resident’s room or other location designated by the facility; maintain at least six feet from others in the facility; and are required to wear a cloth face covering or facemask during the duration of their visit. What is the facility’s process for communicating this information? The facility advises those permitted entry to monitor for signs and symptoms of COVID-19 and appropriate actions to take if signs and/or symptoms occur.
5. Did the facility perform appropriate screening, restriction, and education of visitors? Yes No F880
Suspected or Confirmed COVID-19 Reporting to Residents, Representatives, and Families This CE is relevant to facilities that have had confirmed cases or clusters of suspected COVID-19 infection.
Identify the mechanism(s) the facility is using to inform residents, their representatives, and families (e.g., newsletter, email, website, recorded voice message): The facility informed all residents, their representatives, and families by 5 PM the next calendar day following the occurrence of a single confirmed COVID-19 infection or of three or more residents or staff with new onset of respiratory symptoms that occurred within 72 hours of each other. The information included mitigating actions taken by the facility to prevent or reduce the risk of transmission, including if normal operations in the nursing home will be altered (e.g., visitation or group activities). The information did not include personally identifiable information. The facility provides cumulative updates to residents, their representatives, and families at least weekly or by 5 PM the next calendar day following the subsequent occurrence of either: each time a confirmed COVID-19 infection is identified, or whenever three or more residents or staff with new onset of respiratory symptoms occurs within 72 hours of each other. Interview a resident and a resident representative or family member to determine whether they are receiving timely notifications.
6. Did the facility inform residents, their representatives, and families of suspected or confirmed COVID-19 cases in the facility along with mitigating actions in a timely manner? Yes No F885 N/A
Staff and Resident COVID-19 Testing Review the facility’s testing documentation (e.g., logs of county level positivity rate, testing schedules, staff and resident records, other documentation). If possible, observe how the facility conducts testing, including the use of PPE and specimen collection. If such observation is not possible, interview an individual responsible for testing and inquire how testing is conducted (e.g., “what are the steps taken to conduct each test?”). The facility conducts testing of staff based on the county level positivity rate according to the recommended frequency. Based on observation or interview, the facility conducts testing and specimen collection in a manner that is consistent with current standards of practice for conducting COVID-19 tests. The facility’s documentation demonstrates the facility conducts testing of residents or staff with signs or symptoms of COVID-19 in a manner that is consistent with current standards of practice for conducting COVID-19 tests. The facility’s documentation demonstrates the facility conducts testing of residents and staff based on the identification of an individual diagnosed with COVID-19 in the facility in a manner that is consistent with current standards of practice for conducting COVID-19 tests. The facility takes actions to prevent the transmission of COVID-19 upon the identification of an individual with symptoms consistent with or who tests positive for COVID-19. The facility has procedures for addressing residents and staff that refuse testing or are unable to be tested. If there was an issue related to testing supplies or processing tests, ensure the facility made adequate attempts to obtain supplies by contacting the state and/or local health departments, local laboratories for assistance. If the facility conducts their own tests, they should also contact the supplier.
7. Is the facility in compliance with requirements for staff and resident COVID-19 testing? Yes No F886
Laundry Services: Determine whether staff handle, store, and transport linens appropriately including, but not limited to:
Laundry Rooms – Determine whether staff:
8. Did the facility store, handle, transport, and process linens properly? Yes No F880 N/A, not a recertification survey
Antibiotic Stewardship Program: Determine whether the facility has an antibiotic stewardship program that includes:
9. Did the facility conduct ongoing review for antibiotic stewardship? Yes No F881 N/A, not a recertification survey
Infection Preventionist (IP): During interview with facility administration and Infection Preventionist(s), determine the following: The facility designated one or more individual(s) as the infection preventionist(s) who are responsible for the facility’s IPCP. The Infection Preventionist(s) works at least part-time at the facility. The Infection Preventionist(s) completed specialized training in infection prevention and control.
10. Did the facility designate at least one qualified IP, who is responsible for the facility's IPCP? Yes No F882
Influenza and Pneumococcal Immunizations: Select five residents in the sample to review for the provision of influenza/pneumococcal immunizations. Document the names of residents selected for review. Review the records of the five residents for documentation of: · Screening and eligibility to receive the vaccine; · The provision of education related to the influenza or pneumococcal immunizations (such as the benefits and potential side effects); · The administration of pneumococcal and influenza vaccine, in accordance with national recommendations. Facilities must follow the CDC and Advisory Committee on Immunization Practices (ACIP) recommendations for vaccines; and · Allowing a resident or representative to refuse either the influenza and/or pneumococcal vaccine. If not provided, documentation as to why the vaccine was not provided. For surveys occurring during influenza season, unavailability of the influenza vaccine can be a valid reason why a facility has not implemented the influenza vaccine program, especially during the early weeks of the influenza season. Ask the facility to demonstrate that: · The vaccine has been ordered and the facility received a confirmation of the order indicating that the vaccine has been shipped or that the product is not available but will be shipped when the supply is available; and · Plans are developed on how and when the vaccines are to be administered. As necessary, determine if the facility developed influenza and pneumococcal vaccine policies and procedures, including the identification and tracking/monitoring of all facility residents’ vaccination status.
11. Did the facility provide influenza and/or pneumococcal immunizations as required or appropriate? Yes No F883 |
