Deficiencies in Hand Hygiene and Expired Supplies
Summary
The facility was found to have deficiencies in food service safety and infection control practices during a recertification survey. A Certified Nursing Assistant (CNA) was observed assisting multiple residents with hand hygiene in preparation for dining without performing hand hygiene between residents. The CNA used bare hands and gloves inconsistently, failing to change gloves or sanitize hands between assisting different residents. This was observed for ten residents, indicating a lapse in following the facility's hand hygiene policy, which requires hand hygiene before and after resident contact and between handling food items. Additionally, the facility failed to ensure that disinfecting germicidal wipes and hand sanitizing solutions were discarded by their expiration dates. Expired hand sanitizers and disinfecting wipes were found in various locations, including the medication room, pantry, and central supply room. The Central Supply Representative admitted to not checking expiration dates, and the Infection Preventionist acknowledged that expired supplies would not be as effective. The Director of Plant Operations and Maintenance stated that the central supply person is responsible for checking the expiration of supplies. Interviews with staff, including the CNA, Registered Nurse, and Infection Preventionist, revealed a lack of adherence to infection control practices and oversight in monitoring the expiration of supplies. The CNA admitted to forgetting to change gloves and not performing hand hygiene between residents, while the Infection Preventionist and other staff did not identify concerns related to hand hygiene during their observations. The facility's policies on hand hygiene and inventory control were not effectively implemented, leading to these deficiencies.
Plan Of Correction
Plan of Correction: Approved January 31, 2025 **NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** F 880 483.80 Infection Prevention & Control SS=D I. The following actions were accomplished for the resident(s) identified in the sample: On [DATE], the Certified Nursing Assistant #4 who was assigned on the second-floor dining room was re-educated on the Facilities’ policy entitled “Hand Hygiene.” On [DATE], the hand sanitizer with an expiration date of [DATE] in the medication room on the second floor was immediately removed and replaced. On [DATE], the disinfecting wipe that was found on the 3rd floor panty room was immediately removed and replaced. On [DATE], the three sealed boxes containing expired disinfecting wipes that were found in the central supply with expiration dates of [DATE] were immediately removed and discarded. II. The following corrective actions will be implemented to identify other residents who may be affected by the same practice: All residents have been identified as potentially affected by the same practice. All Certified Nursing Assistants were educated on the facility policy entitled “Hand Hygiene” to ensure proper hand hygiene is practiced in between residents to prevent cross contamination. All hand sanitizer in the entire building were checked by housekeeping staff, including in the central supply, to ensure there were no other expired hand sanitizer. No additional expired hand sanitizer was identified. All disinfecting wipes in the entire building were checked by central supply, including within the central supply department, to ensure there were no other expired disinfecting wipes. No additional expired disinfecting wipes were identified. III. The following system changes will be implemented to ensure continuing compliance with regulations: The Infection Control Preventionist provided an education to all nursing staff on hand hygiene, emphasizing its importance during direct contact with residents in the dining room. This education focused on ensuring the staff members practice proper hand hygiene between residents and when donning or removing gloves, thereby minimizing the risk of cross contamination. The Director of Nursing and the Infection Control Preventionist reviewed the facility’s policy entitled “Hand Hygiene” and all regulatory components were outlined with no revision needed. The Infection Control Preventionist will continue to monitor hand hygiene protocols during meals times in the dining room to ensure all staff members adhere to compliance standards. All Housekeeping staff responsible for monitoring and changing hand sanitizers throughout the facility received education on the critical importance of routinely checking expiration dates. This education ensured that all hand sanitizers remain effective and safe for use, thereby maintaining a high standard of hygiene within the facility. All Central Supply staff/representative responsible for distributing supplies and managing procurement and inventory control within the facility received education on the vital importance of routinely checking expiration dates. This education specifically emphasized hand sanitizer and disinfecting wipes, ensuring that these products remain effective and safe for use, thereby supporting the overall health and safety of the facility. The Executive Director/Administrator and the Director of Plant Operations and Maintenance reviewed the facility’s policy entitled Purchasing, Stocking Inventory Control and Order Points Procedure was revised to incorporate comprehensive inventory control measures and monitoring protocols, ensuring that all supplies are routinely checked for expiration dates. IV. The facility’s compliance will be monitored utilizing the following quality assurance system: The Director of Nursing and Infection Control Preventionist will develop an audit tool to assess compliance with hand hygiene practices during mealtimes in the dining room. This audit tool will specifically focus on ensuring the staff members perform hand hygiene both during direct contact with residents and between residents. Quality Assurance Monitoring will be conducted by the Director of Nursing/Designee using a standardized audit tool titled “Hand Hygiene Compliance in Dining Room.” The audits will be conducted weekly for six months and/or until two quarters are at 100% compliance. A quantitative summary of findings and corrective actions will be reported monthly to the Quality Assurance Performance Committee by the Director of Nursing. The Executive Director/Administrator and the Director of Plant Operations and Maintenance will develop an audit tool to monitor compliance with inventory control measures and monitoring protocol ensuring that all supplies are routinely checked for expiration dates. Quality Assurance Monitoring will be conducted by the Director of Plant Operations and Maintenance/Designee using a standardized audit tool titled “Supply Inventory and Monitoring of Expiration Dates.” The audits will be conducted weekly for six months and/or until two quarters are at 100% compliance. A quantitative summary of findings and corrective actions will be reported monthly to the Quality Assurance Performance Committee by the Director of Plant Operations and Maintenance. Responsible: Executive Director/Administrator, Director of Nursing, Infection Preventionist and Director of Plant Operations are responsible for ensuring all above is in compliance.
Penalty
Resources
Below are regulatory guidelines relevant to this citation:
A resident being evaluated for C. difficile was not consistently managed under the correct contact-enteric precautions. Staff gave care with incomplete understanding of the precautions, the room signage did not clearly identify the needed disinfectant or contact time, bleach wipes were not always available, and staff were observed missing hand hygiene and handling items under PPE during care.
Failure to Use EBP PPE During Wound Care: A resident with a wound and severely impaired cognition was receiving ordered wound care when the DON and ADON entered the room, washed hands, and donned gloves but did not wear gowns before starting care. EBP signage and PPE were present at the bedside, and both leaders later stated they forgot to put on gowns even though the resident was on EBP for an open wound and the facility policy required gown and glove use for wound care.
Staff failed to consistently follow EBP and hand hygiene for two residents who required high-contact care. One resident with an indwelling catheter and cognitive impairment did not have EBP followed during transfers, clothing removal, and pericare, and another resident with a suprapubic catheter and multiple pressure ulcers had staff wear PPE incorrectly, remove PPE in the room without hand hygiene, and continue care after emptying the catheter bag without changing gloves or cleaning hands. Interviews confirmed staff were expected to use gowns, gloves, and hand hygiene for these tasks.
A resident on Contact Precautions for active C. difficile infection was not consistently protected by required PPE. Although signage outside the room directed all entrants to wear a gown and gloves, an RN entered the room with medications without either item and touched the bedside table and door surface. The resident stated staff did not always wear gowns, and the DON confirmed staff were expected to wear a gown and gloves when entering the room while precautions were in place.
A facility failed to maintain infection control during care for two residents. During incontinence care, a CNA removed gloves and applied clean gloves without hand hygiene before placing a clean brief on a resident who was dependent for toileting hygiene and always incontinent. During ostomy care, an LVN handled a resident’s colostomy, wiped stool from the stoma, and continued care without removing soiled gloves, sanitizing hands, or putting on clean gloves. The DON stated staff were expected to perform hand hygiene between glove changes.
Infection Control Failures During Incontinent Care: Two residents were observed receiving incontinent care with multiple infection control lapses. A CNA did not perform hand hygiene between glove changes or after glove removal while caring for one resident, and another CNA did not wash hands before care, changed nothing between dirty and clean tasks, touched clean items with dirty gloves, placed soiled linens on the floor, and handled dirty linens with bare hands after glove removal. The DON stated hand hygiene, glove changes, and proper handling of soiled linens were required, and facility policies reflected those practices.
Infection Control Practices Not Consistently Implemented for Resident Evaluated for C. difficile
Penalty
Summary
The facility failed to establish and maintain an effective infection prevention and control program for a resident who was being evaluated for C. difficile. Resident #43 was admitted with diagnoses including anoxic brain damage, neuromuscular dysfunction of the bladder, and disorder of the autonomic nervous system. A laboratory test for C. difficile had been ordered, but the specimen had not yet been collected because the resident had not produced stool. During observation, a dental hygienist provided care to the resident while wearing a gown and gloves, and a Contact Precautions sign was posted outside the room. The hygienist stated no one had informed him/her that the resident was suspected of having C. difficile, and no one had instructed him/her about using bleach for disinfection or washing hands with soap and water. The infection preventionist stated the sign should have identified the precautions as contact enteric and that the resident should have been placed on the appropriate precautions when the order to obtain the specimen was initiated. Later observation showed a Contact Precautions Special Enteric sign, bleach wipes, gowns, and gloves outside the room, but the sign did not identify the disinfectant required for equipment or environmental disinfection. Bleach wipes were not available outside the room at one point, and staff interviews showed inconsistent knowledge of the precautions. One CNA stated he/she had never heard of contact enteric, another believed enteric precautions required a gown, goggles, and gloves, and another entered the room without performing hand hygiene before donning PPE. During care, one CNA removed gloves and handled a hand-held radio under the gown without hand hygiene, and another used alcohol-based hand sanitizer during glove changes while caring for the resident being evaluated for C. difficile. A licensed nurse stated soap and water and bleach wipes should be used, but did not know the required contact time, and the precaution sign did not identify that contact time.
Failure to Use EBP PPE During Wound Care
Penalty
Summary
The facility failed to maintain an infection control program designed to provide a safe, comfortable, and sanitary environment to help prevent the development and transmission of disease for one resident with a wound. Resident #6 was a female admitted with diagnoses including Parkinsonism, muscle weakness, dementia, and hypertension. Her MDS assessment showed a BIMS score of 06, indicating severely impaired cognition, and her care plan identified a stage 2 pressure ulcer to the right lower calf with ordered wound treatments. During wound care observation, the DON and ADON entered the resident’s room, washed hands, and donned gloves, but did not put on gowns before starting the wound care. EBP signage and PPE were observed hanging at the head of the bed. In interviews, the DON and ADON stated they forgot to put on gowns and acknowledged that the resident was on EBP for an open wound. The facility policy stated that EBP requires targeted gown and glove use during high-contact resident care activities, including wound care, and that gowns and gloves are to be applied prior to performing the activity.
Failure to Follow Enhanced Barrier Precautions and Hand Hygiene During Resident Care
Penalty
Summary
The facility failed to implement Enhanced Barrier Precautions (EBP) for a resident with an indwelling catheter and for a resident with an indwelling suprapubic catheter and multiple pressure ulcers. One resident had moderate cognitive impairment, Type 2 diabetes, obstructive reflux uropathy, and required an indwelling catheter with staff assistance for toileting. His care plan directed staff to use EBP, including gowns and gloves for high-contact care such as toileting, hygiene, and wound care. During observation, a nurse donned a gown and gloves, but a nursing assistant did not don a gown or gloves while assisting the resident with transfers, clothing removal, pericare, and cleaning feces from the resident’s skin. The second resident was cognitively intact and had multiple sclerosis, obesity, diabetes mellitus, a right below-the-knee amputation, neurogenic bladder, obstructive uropathy, an indwelling suprapubic catheter, bowel incontinence, and dependence on staff for toileting, showering, dressing, hygiene, repositioning, and transfers. He also had a stage 4 pressure ulcer on the left buttock with a wound vacuum, a stage 3 sacral pressure ulcer, and a chronic diabetic left foot ulcer. His care plan required EBP for catheter care, dressing, bathing, transferring, changing linens, changing briefs, toileting, and wound care. During observations of care for this resident, staff did not consistently follow EBP or hand hygiene practices. One nursing assistant wore a gown open to the front while providing care, removed gown and gloves in the room without hand hygiene, and handled linens, trash, and the wastebasket before returning to the room. Another nursing assistant emptied the catheter bag and cleaned the catheter tip without changing gloves or performing hand hygiene, then continued with pericare and repositioning using the same gloves. Additional observations showed staff removing PPE in the room, leaving without hand hygiene, and handling the Hoyer lift and other items while wearing or after removing contaminated PPE. Staff interviews and the DON’s statements confirmed that staff were expected to follow EBP and change gloves and perform hand hygiene after high-contact tasks such as emptying a catheter bag, but the observed practices did not match those expectations.
Failure to Use Required PPE for Resident on Contact Precautions
Penalty
Summary
The facility failed to ensure required PPE was used for a resident on Contact Precautions for C. difficile infection. The resident’s MDS identified multiple diagnoses, including congestive heart failure, heart disease, kidney problems, and recurrent C. difficile, and the care plan required Contact Precautions and a private room due to the infection. Nursing documentation identified the resident had active C. difficile infection, and later notes indicated Contact Precautions were discontinued after the last full day of isolation. During observation, Contact Precautions signage outside the resident’s room directed all people entering to wear a gown and gloves, and PPE supplies were located across the hall. The resident stated staff did not always wear a gown when entering the room but usually wore gloves. An RN entered the room with medications without wearing a gown or gloves and touched the bedside table and the interior surface of the room door. The RN stated staff used the signage to determine PPE requirements and confirmed she did not wear a gown or gloves because she was only delivering medications. The interim DON confirmed staff were expected to wear a gown and gloves when entering the room while Contact Precautions were in place, and the facility policy required staff to put on a gown and gloves before contact with the resident or the resident’s environment.
Infection Control Lapses During Incontinence and Ostomy Care
Penalty
Summary
The facility failed to maintain an infection prevention and control program when CNA C did not perform hand hygiene before applying clean gloves during incontinence care for a resident with hemiplegia and hemiparesis following cerebral infarction, unspecified urinary incontinence, and bowel incontinence. The resident’s record showed she was dependent for toileting hygiene and always incontinent of urine and bowel. During observation, CNA C cleaned the resident’s buttocks, rolled the soiled draw sheet under the resident’s hip, removed gloves, did not perform hand hygiene, applied new gloves, and then applied a clean brief. When interviewed, CNA C stated she should have performed hand hygiene when changing gloves and said she was nervous. The DON stated staff were expected to perform hand hygiene between glove changes and that staff had received training on infection control and incontinent care. The facility also failed to ensure proper glove use during ostomy care for a resident with dementia and colostomy status. The resident’s orders included checking the skin around the stoma for redness and irritation, colostomy care every shift and as needed, and emptying the pouch every shift and as needed. During observation, LVN E removed the soiled dressing and emptied the pouch, observed brown substance on the stoma, wiped it off, and placed it in a garbage bag. LVN E then affixed the pouch and cleaned the dressing without removing the soiled gloves, sanitizing his hands, or applying new clean gloves. The DON stated the nurse policy and procedures followed from the named source had no mention of changing gloves between dirty and clean, and LVN E stated he was busy talking and did not remove the old gloves, though he said best practice was to change gloves between dirty and clean.
Infection Control Failures During Incontinent Care
Penalty
Summary
The facility failed to establish and maintain an infection prevention and control program for two residents during incontinent care observations. For one resident with Alzheimer’s disease, morbid obesity, muscle weakness, and dependence for toileting hygiene, CNA B provided most of the incontinent care while another CNA assisted with turning. During the care, CNA B changed gloves but did not wash or sanitize her hands before putting on new gloves, did not wash or sanitize her hands after removing gloves, and did not wash or sanitize her hands before transferring the resident with a mechanical lift. CNA B later stated she forgot to switch gloves at the end and did not sanitize her hands because she forgot to bring sanitizer with her. CNA A observed that CNA B did not wash or sanitize her hands between glove changes. For another resident with cerebral palsy, BPH, hypertension, severe cognitive impairment, and total incontinence of urine and bowel, CNA C performed incontinent care without washing or sanitizing her hands before starting and without changing gloves or washing her hands during and after care. While wearing the same gloves, she removed the resident’s shoes and pants, handled clean clothing from the closet, touched items in the room, handed the resident objects from the dresser, opened the resident’s refrigerator, and later handled dirty linens with bare hands after removing her gloves. She also placed dirty linens on the floor during the care. CNA C stated she had not been taught that she had to change gloves during incontinent care and was not sure when glove changes or hand hygiene should occur. The DON stated hand hygiene should be performed before care, before gloves were applied, after care was completed, and between residents, and that gloves should be changed when moving from dirty items to clean items. The DON also stated soiled linens should be placed in a plastic bag and not on the floor, and staff should never touch clean items with dirty gloves. Facility policies reviewed for perineal care, hand hygiene, and laundry and bedding soiled reflected these same practices.
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