Nursing Homes: CMS Adds New Triggering Factors for Focused Infection Control Surveys

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The Centers for Medicare & Medicaid Services (CMS) has expanded the criteria that will trigger a focused infection control survey at a nursing home, according to a revised CMS memo.

The new criteria are as follows:

  • multiple weeks with new COVID-19 cases;

  • low staffing;

  • selection as a "special focus facility" per the Social Security Act;

  • concerns related to conducting outbreak testing per CMS requirements; or

  • allegations or complaints which pose a risk for harm or immediate jeopardy to the health or safety of residents which are related to certain areas, such as abuse or quality of care (e.g., pressure ulcers, weight loss, depression, decline in functioning).

The revisions come now that there is the increased availability of resources for the testing of residents and staff and factors related to the quality of care, CMS notes.

CMS indicated that it is working with state survey agencies to identify facilities that meet the above criteria. The focused infection control survey, which will be performed by the state agencies, are to start within 3-5 days of identification. CMS noted that facilities which meet the criteria to trigger a survey will not need to be resurveyed if a focused survey was conducted within the previous three weeks.

The updated memo also notes that surveyors performing the focused infection control surveys should keep an eye out for and then investigate concerns related to residents who have experienced a significant decline in their condition during the public health emergency.

As McKnight's Long-Term Care News reports, the memo builds upon requirements issued in the middle of 2020. "Since June, CMS has required states to perform onsite infection control-focused surveys by the end July at nursing homes with previous COVID-19 outbreaks, or within three to five days of any nursing home with three or more new confirmed cases since their last report to the National Health Care Safety Network."

Infection Control Consulting Services (ICCS) is actively assisting many nursing homes working to comply with survey requirements and continuing to implement COVID-19 prevention practices. To learn more ICCS's COVID-19-related services, click here.

Future of Infection Prevention: Q&A With Consultant Phenelle Segal

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Phenelle Segal, RN, CIC, FAPIC, founder of Infection Control Consulting Services (ICCS), answers 10 questions concerning the future of infection prevention in the COVID-19 era.

Q: What trends are you seeing across the non-acute sites that you work with when it comes to infection prevention during COVID-19?

Phenelle Segal: Across the board, non-acute-care sites, including outpatient settings, that were unfamiliar with pandemic preparedness, particularly droplet precautions and the level of personal protective equipment (PPE) required for a virus like COVID-19, have risen to the occasion and shown incredible diligence and expedience in turning their sites into "COVID-safer" sites. The trend for being "COVID-safe" is continuing, and I'm not seeing any pull back to "previous times," which is encouraging. COVID-19 is here to stay for an extended period, and the non-acute sites need to maintain this level of diligence moving forward.

It's worth noting that in August, the governor of New Jersey enacted an executive order encompassing all long-term care settings in response to the severity of outbreaks that occurred in the New York tri-state area (New York, New Jersey, and Connecticut) at the beginning of the pandemic. To fulfill the requirements outlined in this order has required extensive work and communication strategies. These requirements and mandates have resulted in solidifying policies and procedures. However, regardless of state mandates, the pandemic has led to a major emphasis placed on processes, particularly in long-term care, and greater oversight is now in effect.

Overall, I'm seeing a healthcare community outside of acute care that has always had a strong commitment to infection prevention and adhering to a robust program truly rising to the forefront of the COVID-19 health crisis.

Q: How has infection prevention since COVID-19 changed? What do you see happening in the future?

PS: Adherence to the status quo and repeating the same processes over and over, depending on the facility, has definitely changed and is evolving. Existing protocols have tightened up and new protocols have been introduced. Staffing has been challenging and needed to be adjusted for a few reasons. When we were shut down, many non-acute sites had to furlough staff, with some choosing to leave the healthcare arena to find alternate work. As a result, many didn't return to their previous jobs when we started opening up. That resulted in a shortage of skilled workers.

In addition, many staff members have school-age children. For staff with such children doing remote learning, they needed to change their work strategies to accommodate staying home with their children.

Last but not least, COVID-19 fatigue has resulted in many healthcare workers leaving their jobs and finding other, less stressful professional avenues. Going forward, education will remain a huge necessity, especially teaching practices unfamiliar to healthcare workers, such as donning and doffing of PPE that was primarily performed in the acute-care setting. Non-acute-care settings have needed to figure out how to train and educate staff and then establish compliance monitoring and strategies for reporting with feedback as well.

Q: What should facilities be doing now to prepare for what's next?

PS: Continue to enforce and maintain protocols and practices that were developed and be mindful of letting one's guard down, particularly in the areas of the country that have experienced a low or steady downward trend of coronavirus cases. I'd also encourage facilities to consider increasing PPE and disinfectant supply resources as the winter months are upon us and we are seeing an exponential increase in cases before the true winter months get here. This is of great concern. Maintaining diligence, communication, and auditing of processes remains paramount in fighting this pandemic.

Q: Following up on the previous questions, what do you see as the biggest challenges to preparing properly?

PS: Several challenges continue across the continuum of care: Restricted supplies, particularly N95 masks, counterfeit KN95s, shortage of disinfectant wipes; budget constraints as a result of several unforeseen costs; overall staffing issues and COVID-19 healthcare worker burnout (as discussed earlier), particularly caused by high levels of professional and personal stress, along with the wearing of PPE, depending on the facility setting and services provided. Maintaining effective communication can be a challenge but is absolutely essential. Managers need to maintain an open-door approach and share information from external sources, such as state orders and CDC guideline changes, and internal information.

Q: How should facilities approach new regulations resulting from COVID-19, and what do you see as the potential long-term impacts?

PS: The biggest challenge with new regulations, particularly at the individual state level, is the difficulty in interpreting the language as written in the new orders and requirements. Many would argue that regulations are mostly subjective and open to interpretation. This has resulted in much confusion and anxiety thus far, especially for administrators and management teams as they are struggling to comply with the law and put new practices into place. That being said, I expect it to get easier as time moves on and we become more used to the "new normal."

Q: How does all of this compare to past pandemics?

PS: There is no comparison that I can accurately discuss, but what I can do is mention that this is most likely the pandemic of all pandemics, akin to an earthquake when we talk about the big one. Lessons learned from this will certainly carry over to future pandemics, but ones that we can only hope are not as devastating as this one. I don't believe this will be our last major respiratory pandemic, but we certainly will be better prepared for the next crisis.

Q: Ambulatory surgery centers (ASCs) are now required to have an infection preventionist on staff. What should administrators, owners, and human resources leaders consider when they start their search for this new staff member or are they better off certifying someone from within?

PS: Hiring from the outside or training someone from within is very much dependent on several factors, including the type of facility and services offered by the surgery center as well as the infection prevention designee's skills, interest in taking on this role, time allocation, and other factors. It also depends on the current state of the infection prevention program. What is the "right approach" for ASCs will be very much individualized. Many surgery centers appoint an infection prevention designee and hire an external consultant to onboard and assist the designee with developing and implementing a new program or maintaining an already established program.

Q: Can you please clarify the guidance around an infection preventionist on staff for a long-term care/skilled nursing facility?

PS: Between the end of 2016 and 2019, long-term care facilities were mandated to include several infection prevention components for participation. This culminated in designating staff members to the role of infection prevention that included specialized training. With COVID-19 attacking the elderly in facilities since March, individual states have recently enacted executive orders, for example the aforementioned New Jersey order and an order from California in late September. These requirements, depending on the state, can be very stringent.

Q: As home health providers need to treat patients in home, what are recommended practices for home health staff to protect themselves while keeping patients safe?

PS: Follow CDC guidance and the basic principles of prevention of acquisition and/or transmission of COVID-19. In addition, the National Association for Home Care and Hospice has an extensive resources page that I would encourage everyone that is involved in home health to review. The page includes FAQs, information for patients and caregivers, and much more.

Q: Can you share any insights on updated point-of-care (POC) testing protocols for providers?

PS: POC technology is changing frequently. Companies are turning out products that are easier to administer, turnaround faster, and produce fewer false negative results. However, testing is not foolproof. Besides facilities enacting their own rules and policies around testing, what facilities need to do will also be dependent on state regulations. POC testing is mandated in several states for long-term care settings due to the outbreak risks in those settings. I believe that will continue into next year as we expect cases to rise again with winter around the corner. It is important to understand that POC testing has limitations; consider exactly what your goals are for doing POC testing and how you will use these results.

10 of the Scariest Healthcare Infections and Threats (2020 Edition)

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Last year, the team at Infection Control Consulting Services (ICCS) shared 10 of their scariest healthcare infections and threats. Below is our list for 2020. Some were clear-cut choices. Others were debated. All are scary, and all are important.

Agree? Disagree? Let us know what you would have on your list by commenting on LinkedIn.

1. COVID-19

Global. United States. Healthcare professionals. Be vigilant.

2. PPE shortages

Personal protective equipment (PPE) shortages garnered significant attention in the initial weeks and months of the pandemic. Unfortunately, more than six months into the health crisis, shortages of PPE remain a substantial challenge. As the Harvard Business Review noted in September, "Hospitals, nursing homes, and medical practices routinely have to waste time and heighten their disease exposure by decontaminating disposable masks and gloves for reuse. Many organizations must still forage for critically needed equipment through back channels and black markets." 

As the pandemic continues, deaths will continue to add up. PPE shortages are likely to further contribute to the loss of life. U.S. PIRG recently highlighted the growing and serious risk facing nursing homes. 

3. Drug shortages

Drug shortages have long been a problem in the United States. The pandemic has only worsened the situation and it's costing patients their lives and wellness. A recent report from the Center for Infectious Disease Research and Policy noted that more than 70% of the 40 critical drugs for COVID-19 patients are experiencing shortages, citing American Society of Health-System Pharmacists (ASHP) data. The current shortage list maintained by ASHP includes more than 200 drugs. On it are the likes of propofol, morphine, fentanyl, albuterol, midazolam, hydroxychloroquine, and azithromycin.

4. Antibiotic-resistant bacteria

The title of a recent Business Insider article helps to frame the significant threat that we still face from antibiotic-resistant bacteria: "There's another pandemic-level health threat slowly building — this one from bacteria." The CDC notes that antibiotic resistance "is one of the biggest public health challenges of our time," reporting that nearly 3 million Americans contract an antibiotic-resistant bacterial infection annually and, of those, about 35,000 die. 

The good news is that the United States has a national action plan for combating antibiotic-resistant bacteria that was recently updated and we've seen some progress made thanks to prevention efforts that have reduced deaths. The bad news is that the progress is fairly slow, and we continue to learn that this threat may prove even more difficult to combat and control than realized. A recent study showed that antibiotic-resistant bacteria can linger in hospitals even after deep cleaning.

5. Misinformation

This is a topic we wrote about in March, when we debunked potentially dangerous myths concerning the prevention of and treatment for COVID-19 (a list that could be much longer now). Misinformation, disinformation, and rumors, particularly those which "go viral," can complicate efforts to inform the public about health threats and appropriate preventive and responsive actions. This can ultimately lead to dangers, including harm to individuals and the potential prolonging of a threat. As a Scientific American column simply stated, "COVID Misinformation is Killing People."

6. Suboptimal hand hygiene

One of the few silver linings of the pandemic is increased awareness and appreciation of the importance of hand hygiene. Hopefully that translates over to sorely needed improvements in proper hand hygiene practices within healthcare organizations, and there is some evidence that this is occurring.

Such improvements are critical. The CDC references studies showing that, on average, healthcare providers clean their hands less than half of the times they should. A study published in Infection Control & Hospital Epidemiology from early in the year demonstrated that poor hand hygiene continues to contribute to hospital-acquired infections, with the researchers stating that "… current best practice recommendations do not provide a strong guidance regarding patient hand hygiene."

7. Unsafe injection practices

Back in February, Mayo Clinic Proceedings study further highlighted this avoidable threat. Researchers found that nearly 67,000 patients were notified about potential exposure to unsafe injection practices by healthcare personnel between 2012 and 2018, and the total number of U.S. patients notified of potential exposures to blood-contaminated medications or injection equipment since 2001 is close to 200,000.

The same month the study was published marked the 10-year anniversary of the "One & Only Campaign" — a public health effort to eliminate unsafe medical injections. Unfortunately, significant work remains if this campaign is to be declared successful.

8. Sterile processing failures

This is a safety threat that has lingered for years and one we brought attention to in last year's list in the section on "endoscopes testing positive for bacteria after cleaning and disinfection." In ECRI's "Top 10 Patient Safety Concerns for Healthcare Organizations 2020" report, the organization identified "device cleaning, disinfection, and sterilization" as fifth on its list, noting that sterile processing failures can lead to surgical site infections. In addition, ECRI stated that, "Incidents involving improperly reprocessed instruments can potentially result in devastating effects on patients, damage to organizational and provider reputations, citations and fines from regulatory bodies, prompt review by accrediting agencies and lawsuits."

9. Sepsis

Twenty percent. That's the percentage of annual worldwide deaths attributable to sepsis, either as cause or contributing factor, according to a study published in Lancet. The study analyzed death certificates for more than 100 million deaths records in 2017 and found that the number of deaths associated with sepsis was twice as high as previously believed. The researchers also found that nearly 49 million incident cases of sepsis and 11 million sepsis-related deaths were recorded worldwide in 2017. The good news is that the number of global sepsis cases has declined since 1990.

Considering patients who are critically ill with severe COVID-19 and other infectious diseases are at higher risk of developing and dying from sepsis, reports the World Health Organization, it will be interesting to see whether global cases rise in the coming years.

10. Home-laundered scrubs

We conclude with this threat because the question of whether organizations should permit their staff members to take scrubs home and wash them is one that our team is asked regularly. The Association of periOperative Registered Nurses (AORN) provides recommendations and guidance concerning what organizations should do if they go the route of

  • laundering at a healthcare-accredited laundry facility,

  • laundering scrubs themselves (following state regulatory requirements or following CDC guidelines if no state requirements exist), or

  • allowing staff members to launder scrubs at home.

While organizations must ultimately choose whether to permit home-laundered scrubs and develop a policy that reflects their decision, ICCS strongly advises against home-laundered scrubs. Among our reasons: How will the organization control the laundering? Who will review and monitor the process in individual homes? Ultimately, we believe that the potential safety risks associated with home-laundered scrubs are not worth taking.

What are your scariest healthcare infections and threats of the year?

We hope you found our list informative. It wasn't easy to settle on just these 10, and we could easily have made a much longer list. But we tried to cover a range of threats and hopefully help you gain a better understanding and appreciation of some that may not be receiving the level of attention they deserve as we are largely focus on battling this pandemic.

Did we omit your scariest infection or threat? Let us know on LinkedIn!

Phenelle Segal Presents Webinar on the Future of Infection Prevention

ICCS Founder Phenelle Segal, RN, CIC, FAPIC, recently presented a webinar for McKesson as part of its ongoing educational webinars series.

The program was titled "The future of infection prevention: Expert insights on the lasting impact of COVID-19" and focused on infection prevention in the era of COVID-19 and beyond.

Phenelle tackled top COVID-19 questions, shed light on critical lessons learned from this and previous pandemics, and detailed what organizations should be doing now to strengthen their facility's infection prevention program to better prepare for the future.

The webinar’s recording can be viewed below.

OSHA Outlines New Enforcement Discretion Policy for Respiratory Protection

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The Occupational Safety & Health Administration (OSHA) has issued a new memorandum that provides temporary enforcement guidance concerning tight-fitting powered air-purifying respirators (PAPRs) used during the COVID-19 pandemic.

The memorandum outlines the new enforcement discretion policy that permits the use of National Institute for Occupational Safety and Health (NIOSH)-approved tight-fitting PAPRs for protection against the novel coronavirus.

There are a few caveats:

  • Usage is only acceptable when initial and/or annual fit-testing is infeasible due to respirator and fit-testing supply shortages. 

  • The guidance only applies to fit-testing of NIOSH-approved tight-fitting PAPRs used as a contingency capacity strategy when performing job tasks with high or very high occupational exposure risk to the novel coronavirus. An example of a tight-fitting PAPR is the elastomeric half-facepiece respirator, which can be cleaned, decontaminated and reused.

OSHA stated that will exercise enforcement discretion, on a case-by-case basis, when considering issuing citations in cases where the employer has:

  • provided NIOSH-approved tight-fitting PAPRs to protect personnel against SARS-CoV-2 (the virus that causes COVID-19) using a high efficiency particulate cartridge or filter, when initial and/or annual fit-testing is infeasible due to shortages of N95, N99, N100, R95, R99, R100, P95, P99, and P100 respirators and/or fit-testing supplies;

  • monitored fit-testing supplies and made good faith efforts to obtain fit-testing supplies;

  • implemented, to the extent feasible, engineering controls, work practices, and/or administrative controls that reduce the need for respiratory protection, such as using partitions, restricting access, and cohorting patients; and

  • maintained a fully-compliant respiratory protection program, other than fit-testing requirements, including ensuring personnel are informed of new policies and trained on new procedures, ensuring employees receive required medical evaluations, ensuring batteries and filters for PAPRs are well maintained to provide positive pressure throughout the entire shift or procedure, and ensuring employees wearing tight-fitting PAPRs maintain neatly trimmed facial hair that does not compromise the seal of the respirator or come between the sealing surface of the facepiece and the face, and that does not interfere with valve function.

The guidance does not apply to PAPRs that have not been approved by NIOSH; PAPRs used by any workers with low or medium exposure risk to SARS-CoV-2; PAPRs used by any workers for protection against airborne hazards other than SARS-CoV-2; and loose-fitting hooded PAPRs that do not require fit-testing.

The interim guidance takes effect immediately and remains in effect until further notice. It is intended to be time-limited to the current public health crisis.

While this temporary enforcement guidance does provide organizations with some flexibility concerning the usage of respirators and fit-testing supplies, organizations should only consider usage of NIOSH-approved tight-fitting PAPRs if absolutely necessary. As OSHA notes, where the above efforts are absent and respiratory protection use is required, or voluntary use is permitted, and an employer fails to comply with applicable medical evaluation, fit-testing, maintenance, care, and training requirements, an organization may face serious violations.