QA Investigation Results

Pennsylvania Department of Health
BUTLER COUNTY DIALYSIS CENTER
Health Inspection Results
BUTLER COUNTY DIALYSIS CENTER
Health Inspection Results For:


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Initial Comments:
Based on the findings of an onsite unannounced Medicare recertification survey completed on June 21, 2021, Butler County Dialysis Center was found to be in compliance with the requirements of 42 CFR, Part 494.62, Subpart B, Conditions for Coverage of Suppliers of End-Stage Renal Disease (ESRD) Services - Emergency Preparedness.



Plan of Correction:




Initial Comments:
Based on the findings of an onsite unannounced Medicare recertification survey completed June 21, 2021, Butler County Dialysis Center was found to have the following standard level deficiencies that were determined to be in substantial compliance with the following requirements of 42 CFR, Part 494, Subparts A, B, C, and D, Conditions for Coverage of Suppliers of End-Stage Renal Disease (ESRD) Services.



Plan of Correction:




494.30(a)(1) STANDARD
IC-WEAR GLOVES/HAND HYGIENE

Name - Component - 00
Wear disposable gloves when caring for the patient or touching the patient's equipment at the dialysis station. Staff must remove gloves and wash hands between each patient or station.




Observations:

Based on review of facility policy, observation (OBS), and staff (EMP) interview, the patient care technician failed to remove gloves and perform hand hygiene when going from a dirty task to a clean task for one (1) of two (2) observations of initiation of dialysis with a central venous catheter (OBS2.1).

Findings included:

Review of facility policy on June 21, 2021, at 10:30 a.m. showed, "CVC [central venous catheter] Exit Site Care ... Dons clean gloves ... Remove old dressing and discard without contaminating clean supplies ... Remove gloves, hand hygiene, don clean gloves [cleanse site and apply new dressing]."

Observation (OBS2.1) on June 16, 2021, at 10:13 a.m. at station 8 revealed EMP14 remove patient's used central venous catheter dressing (dirty task) with gloved hands. With same gloved hands, EMP14 opened and prepared disinfectant wipes and new dressing (clean task). EMP14 then cleansed site and applied a new dressing to patient's central venous catheter exit site (clean task) with same gloved hands. Interview with EMP14 after the observation confirmed findings.








Plan of Correction:

Butler County Dialysis Center
Plan of Correction
Survey Date: 6/15/21 to 6/21/21


V 000

The governing body and management staff of this facility takes this deficiency statement very seriously and will ensure that these citations are corrected and that they remain in compliance. The governing body met on 6/28/2021 to review and approve the plan of correction and the tools that will keep approved plan in compliance. The in-services and tools are attached and available for review in the facility.

V 113

An in-service was initiated to all Direct Patient Care (DPC) staff on 6/28/2021, by the Clinic Manager (CM) regarding the importance of removing gloves and performing hand hygiene when going from a dirty task to a clean task to minimize the risk for cross contamination. Per Policy "Gloves must be put on before caring for a patient or touching a patient's equipment. Gloves should be changed frequently during patient care. Examples of when gloves should be changed: When soiled (blood, dialysate or other body fluids), When going from a "dirty area to a "clean" area." It was stressed during the in-service that after removing the dressing from a central venous catheter (CVC) site, gloves must be removed, hand hygiene must be performed immediately, prior to donning new gloves, and prior to continuing cleaning of the catheter site. It is never acceptable to remove the patients dressing and continue performing catheter care, with the same gloves used to remove the dirty dressing. This action had the risk of spread of infection through cross contamination. This item is on the monthly Infection Control Audit which is normally completed monthly and will be increased to weekly for 8 weeks by an assigned Direct Patient Care (DPC) staff member and by the Clinic Manger and monthly thereafter by an assigned DPC staff member. All breaks in Infection Control will be immediately addressed by the Clinic Manager. The Clinic Manager will ensure compliance through direct observation and review of the Infection Control Audits at least monthly prior to the Total Quality Management (TQM) meeting. All findings will be addressed at the monthly TQM meeting where additional action will be taken as deemed appropriate, such as additional training, continuing the weekly audits or if trends are identified, disciplinary action.



494.30(a)(4)(ii) STANDARD
IC-DISINFECT SURFACES/EQUIP/WRITTEN PROTOCOL

Name - Component - 00
[The facility must demonstrate that it follows standard infection control precautions by implementing-
(4) And maintaining procedures, in accordance with applicable State and local laws and accepted public health procedures, for the-]
(ii) Cleaning and disinfection of contaminated surfaces, medical devices, and equipment.



Observations:
Based on review of facility policy, observation (OBS), and staff (EMP) interview, the facility failed to ensure staff emptied and disinfected the prime waste receptacle between patients for one (1) of two (2) observations of cleaning and disinfection of the dialysis station (OBS6.1).

Findings included:

Review of facility policy on June 21, 2021, at 10:30 a.m. showed, "Cleaning and Disinfection of Dialysis Station V122 ... Empty and disinfect prime waste receptacle."

Observation (OBS6.1) on June 15, 2021, at 10:14 a.m. revealed EMP9 clean and disinfect dialysis machine at station 7 after the previous patient had vacated the station. EMP9 installed new equipment onto the dialysis machine for the next patient, and in the process primed new bloodline set for next patient into previously used and uncleaned prime waste receptacle. The prime waste receptacle contained liquid (dialysate) from previous patient's treatment. Interview with EMP9 during the observation confirmed above findings (prime waste receptacle not emptied/disinfected between patients) and he/she said, "Do you want me to empty and clean it?"



Plan of Correction:

V 122
An in-service was initiated to all Direct Patient Care (DPC) staff on 6/28/2021 by the Clinic Manager regarding disinfection of all items in the patient station must be disinfected, including, the prime waste bucket on the side of the machine. Per Policy "Machines, chairs (put in trendelenburg), pillows, saline prime buckets, sharps containers, TVs, TV arms, IV poles, BP tubing, BP basket, stethoscopes, Hanson connectors, O2 concentrators, EMRs (except screen) and surrounding areas are to be cleaned with 1:100 bleach solution between every patient treatment." Also, per policy "The prime bucket is to be dumped into a dirty drain, ensure that liquid only is poured into the drain. Then rinse or wipe with 1:100 bleach solution." During the in-service it was stressed, to prevent the possibility of cross contamination, all items in the patient station must be cleaned with a cloth soaked in 1:100 bleach solution prior to bringing clean supplies into the station, such as bloodlines. This includes ensuring that any fluid in the prime waste bucket is emptied into a dirty sink, and the bucket is disinfected (inside and out), prior to bringing clean items into the station to set up for the next patient. This item has been added to the monthly infection control audit which will be done weekly for 8 weeks by an assigned Direct Patient Care (DPC) staff member and by the Clinic Manger and monthly thereafter by an assigned DPC staff member. All breaks in Infection Control will be immediately addressed by the Clinic Manager. The Clinic Manager will ensure compliance through direct observation and review of the Infection Control Audits at least monthly prior to the Total Quality Management (TQM) meeting. All findings will be addressed at the monthly TQM meeting where additional action will be taken as deemed appropriate, such as additional training, continuing the weekly audits or if trends are identified, disciplinary action.



494.30(a)(1)(i) STANDARD
IC-HBV-ISOLATION-MACHINES/EQUIP/SUPPLIES

Name - Component - 00
Isolation of HBV+ Patients

To isolate HBsAg positive patients, ... dedicate machines, equipment, instruments, supplies, and medications that will not be used by HBV susceptible patients.


Observations:

Based on review of facility policy, observation, and staff (EMP) interview, the registered nurse failed to remove all personal protective equipment after caring for a hepatitis B virus positive (HBV+) patient and before leaving the isolation room for one (1) of one (1) observation (HBV1).

Findings included:

Review of facility policy on June 21, 2021, showed, "INFECTION CONTROL/BLOODBORNE PATHOGENS EXPOSURE CONTROL PLAN ... E. Isolation Precautions ... Gloves, barrier gown, mask and safety glasses or face shield must be worn when working with an isolation patient, removed before leaving area."

Observation (HBV1) of discontinuation of dialysis with HBV+ patient at isolation room on June 21, 2021, at 8:45 a.m. with EMP12 revealed EMP6 discontinue patient's dialysis while wearing gown, mask, and face shield. Once dialysis was terminated, EMP6 removed his/her gown and shield, but left his/her mask on and left the isolation room. EMP6 walked onto the treatment floor wearing same isolation mask he/she had worn in the isolation room. Interview with EMP6 and EMP12 at 8:57 a.m. confirmed above findings. EMP12 noted EMP6 should have removed his/her mask before he/she left the isolation room.




Plan of Correction:

V 130

An in-service was initiated to all Direct Patient Care (DPC) staff on 6/28/2021 by the Clinic Manager regarding the requirement for removing all personal protective equipment (PPE), including mask, when leaving isolation room. Per policy "Gloves, barrier gown, mask and safety glasses or face shield must be worn when working with an isolation patient, removed before leaving the area, and followed by thorough hand washing at a designated sink." It was stressed during the in-service that in order to reduce the risk of cross contamination, staff caring for patient's in the isolation room, must remove all PPE, including the face mask, prior to leaving the isolation room. It is unacceptable to leave the isolation room with any PPE on, such as the face mask, that was used while caring for a patient in the isolation room. This item is on the monthly infection control audit which will be done weekly for 8 weeks by an assigned Direct Patient Care (DPC) staff member and by the Clinic Manger and monthly thereafter by an assigned DPC staff member. All breaks in Infection Control will be immediately addressed by the Clinic Manager. The Clinic Manager will ensure compliance through direct observation and review of the Infection Control Audits at least monthly prior to the Total Quality Management (TQM) meeting. All findings will be addressed at the monthly TQM meeting where additional action will be taken as deemed appropriate, such as additional training, continuing the weekly audits or if trends are identified, disciplinary action.



494.110(a)(2)(ix) STANDARD
QAPI-INDICATOR-INF CONT-TREND/PLAN/ACT

Name - Component - 00
The program must include, but not be limited to, the following:
(ix) Infection control; with respect to this component the facility must-
(A) Analyze and document the incidence of infection to identify trends and establish baseline information on infection incidence;
(B) Develop recommendations and action plans to minimize infection transmission, promote immunization; and
(C) Take actions to reduce future incidents.



Observations:

Based on review of clinical records (CR), infection logs, and staff (EMP) interview, the facility failed to record and review all infections with action taken for two (2) of two (2) clinical records reviewed with infections (CR5, & CR7).

Findings included:

Review of CR5 on June 17, 2021, at 11:45 a.m. showed patient was ordered an antibiotic on 7/15/2020 per "Home Meds" document, "Doxycycline [100 milligrams two times per day]." A nursing note from 7/10/2020 showed, "Rt [right] foot infection per pt. ... Pt to go to wound center tom. [tomorrow] per pt. Pt mentioned they may want dialysis to do IV [intravenous] antibiotics which dialysis said they could with an order from MD." Signed by EMP1

Review of facility's July 2020 infection tracking logs on June 17, 2021, at 11:50 a.m. did not show that CR5's foot infection had been recorded or reviewed with action taken.

Review of CR7 on June 17, 2021, at 1 p.m. showed patient was admitted to hospital for pneumonia (lung infection) on 3/22/2020 and dialysis facility was aware. Per hospital documentation (H&P) contained in CR7 from March 2020 admission, "Chief Complaint ... Febrile event and shortness of breath with cough ... Assessment/Plan - Pneumonia-multifocal RLL [right lower lobe], RUL and LUL with small pleural effusion ... Initially started on IV rocephin and Azithromycin [both antibiotics] will continue at this time."

Review of CR7's "POST HOSPITAL DISCHARGE INFORMATION SHEET AND CHECKLIST," dated 4/10/2020 showed that EMP1 documented patient's hospital episode with a discharge diagnosis of pneumonia.

Review of facility's March and April 2020 infection tracking logs on June 17, 2021, at 1:15 p.m. did not show that CR7's pneumonia had been recorded or reviewed with action taken.

Interview with EMP1 on June 21, 2021, at 10:52 a.m. confirmed above findings, "Failed to put it [infections] into the log." EMP1 confirmed that above logs are used to track infections as part of facility's infection control program within QAPI.








Plan of Correction:

V 637

The Corporate Clinical and Regulatory Manager (CRM) met with the Clinic Manager (CM) and the Total Quality Management (TQM) Team on 6/28/2021 regarding the requirements and process for the facility TQM Program in tracking and monitoring infection control practices of the facility. Per policy, "Incidents of infection must be documented addressed and reviewed on an ongoing basis as they occur. Data is analyzed, with trends identified and action plans developed and implemented to minimize infection transmissions and reduce future incidents." It was stressed during the in-service that the TQM meeting agenda must include the tracking and trending of facility infection control, ensuring that all incidents of infection are documented on the facilities infection tracking logs. This includes ensuring there is documentation on the infection control log of all patients, including patient CR5, that are prescribed antibiotics for foot infections, and all patients, including patient CR7, that are admitted to the hospital for infections, such as pneumonia.
The Clinic Manager is responsible for ensuring that the monthly infection tracking tool is complete and accurate, and is presented and reviewed monthly by the TQM committee. The TQM committee is responsible for reviewing all incidents of infection, including foot infections and pneumonia, to identify trends and develop action plans to minimize the incidents of infection transmission within the facility and reduce further incidents. The Clinic Manager will ensure compliance, with the above, as an active member of the TQM committee. The TQM minutes are also sent to the Corporate Clinical and Regulatory Manager monthly for review. The CRM will monitor this activity to ensure it is being done monthly.