§483.80 Infection Control The facility must establish and maintain an infection prevention and control program designed to provide a safe, sanitary and comfortable environment and to help prevent the development and transmission of communicable diseases and infections.
§483.80(a) Infection prevention and control program. The facility must establish an infection prevention and control program (IPCP) that must include, at a minimum, the following elements:
§483.80(a)(1) A system for preventing, identifying, reporting, investigating, and controlling infections and communicable diseases for all residents, staff, volunteers, visitors, and other individuals providing services under a contractual arrangement based upon the facility assessment conducted according to §483.70(e) and following accepted national standards;
§483.80(a)(2) Written standards, policies, and procedures for the program, which must include, but are not limited to: (i) A system of surveillance designed to identify possible communicable diseases or infections before they can spread to other persons in the facility; (ii) When and to whom possible incidents of communicable disease or infections should be reported; (iii) Standard and transmission-based precautions to be followed to prevent spread of infections; (iv)When and how isolation should be used for a resident; including but not limited to: (A) The type and duration of the isolation, depending upon the infectious agent or organism involved, and (B) A requirement that the isolation should be the least restrictive possible for the resident under the circumstances. (v) The circumstances under which the facility must prohibit employees with a communicable disease or infected skin lesions from direct contact with residents or their food, if direct contact will transmit the disease; and (vi)The hand hygiene procedures to be followed by staff involved in direct resident contact.
§483.80(a)(4) A system for recording incidents identified under the facility's IPCP and the corrective actions taken by the facility.
§483.80(e) Linens. Personnel must handle, store, process, and transport linens so as to prevent the spread of infection.
§483.80(f) Annual review. The facility will conduct an annual review of its IPCP and update their program, as necessary.
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Observations:
Based on staff interviews, facility policy review, and review of facility legionella guidelines, it was determined the facility failed to implement a Water Management Program for the prevention, detection, and control of water-borne contaminants, such as Legionella (a bacteria that may cause Legionnaires' Disease (a serious type of pneumonia)); and failed to maintain accurate infection control data.
Findings include:
A review of the facility policy, titled "Anticipated Increase in Legionellosis Cases Due to Seasonality", dated June 12, 2023, failed to address any baseline or annual testing in the facility for water-borne contaminants, such as Legionella.
A review of the facility policy, titled "Surveillance for Health-Care Associated Infections (HAI)", last reviewed February 22, 2024, stated, "The purpose of the surveillance of infections is to identify both individual cases and trends in the transmission of epidemiologically significant organisms and Healthcare-Associated Infections, to permit interventions to try to slow or stop the transmission of such infections."
A review of the facility guidelines (toolkit developed by CDC-Centers for Disease Control), titled "Developing a Water Management Program to Reduce Legionella Growth and Spread in Buildings", determined the need for a water management program based on risk analysis. The facility risks, based on analysis, included being a healthcare facility where residents stay overnight and have acute or chronic problems and weakened immune systems; Residents are primarily older than 65 years; and the building has multiple rooms (housing units) with a centralized hot water system.
During an interview with the Nursing Home Administrator (NHA) on March 6, 2024, at 11:00 AM, the NHA was unable to show evidence of routine environmental sample results of Legionella testing. The NHA added that the facility was having difficulty finding a local service provider to perform Legionella testing.
A review of the facility infection control (IC) monthly log (data that should minimally include a resident identifier, room location, confirmed type and area of infection, treatment), dated January 2024, revealed 26 residents were listed as suspected for an infection and 8 are listed as confirmed, but the IC logs were not updated for the 26 residents to show confirmation of an infection with microbiology (laboratory/x-ray reports that confirm infection, type of bacteria, and recommended antibiotic), or that the infection was ruled out.
A look back at previous months of IC data revealed the same as above.
Further review of the January 2024 infection control (IC) data log revealed Resident 56 was documented as being admitted January 31, 2024. Resident 56 was actually admitted May 11, 2022. Resident 56's infection was listed as suspected, but was actually confirmed with microbiology reports for both infections in the blood and urinary tract. The organism (type of bacteria or treatment) was never documented on the IC log.
During an interview with the Infection Control Preventionist (ICP) on March 7, 2024, the ICP stated that the system marks all residents as suspected and only those residents who are reported to the state reporting system are marked as confirmed; therefore, the logs do not reveal all of the confirmed infections and accuracy for tracking infections.
During an interview with the Nursing Home Administrator (NHA) on March 7, 2024, at approximately 11:30 AM, the NHA agreed that IC data should be accurate.
28 Pa. Code 201.18(b)(1)(3) Management
| | Plan of Correction - To be completed: 04/02/2024
Resident 56 had correction to infection log to reflect correct type of infection. No ill effects from not testing for Legionella. Current residents with infection have been audited to ensure that an accurate infection tracking UDA is present and completed to include any organism/x-ray results. Current licensed staff will be educated on requirements of F 0880 with attention to Defining Infections in the Elderly. Current team involved with Water testing will be educated. Baseline Legionella testing completed. The DON/designee will complete an audit of 3 random residents with infection /antibiotic ordered weekly for 4 weeks, then 3 random residents monthly for 2 months to ensure accurate infection documentation. Results of audits and trends from these audits will be submitted and reviewed in the quarterly QAPI committee.
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