Infection Control and COVID-19 Work Exclusion Deficiencies
Penalty
Summary
The facility failed to ensure a safe environment free from the potential spread of infection related to the processing of resident personal laundry. Observations revealed that staff collected soiled personal laundry in mesh bags, which were not leak-resistant, potentially exposing staff to contamination during transport. The mesh bags were placed in a large, open bin in the nursing unit's soiled utility room, which lacked a lid, increasing the risk of contamination. Staff were instructed to rinse heavily soiled garments in the soiled utility hopper without the availability of isolation gowns, potentially contaminating the air, surfaces, and staff in the room. Additionally, the facility did not adhere to CDC guidelines for COVID-19 work exclusions. Employee 3, a nurse aide, returned to work five days after testing positive for COVID-19 on two separate occasions without undergoing subsequent testing to confirm a negative result. The facility's policy required adherence to CDC guidance, which stipulates a return to work after at least seven days with a negative test or ten days without testing. The facility did not provide evidence of any additional COVID-19 cases or staffing shortages that would justify early return to work under contingency or crisis staffing criteria. Interviews with the Nursing Home Administrator and the Director of Nursing confirmed the lack of evidence for additional COVID-19 cases or measures to mitigate staffing shortages. The facility did not progress through measures from conventional to contingent nurse staffing, nor did it communicate with local healthcare coalitions to identify additional healthcare personnel. This resulted in Employee 3 returning to work outside of CDC's conventional strategy parameters, potentially increasing the risk of COVID-19 transmission within the facility.
Plan Of Correction
The Facility submits this Plan of Correction under procedures established by the Department of Health in order to comply with the Department's directive to change conditions which the Department alleges is deficient under State and/or Federal Long Term Care Regulations. This Plan of Correction should not be construed as either a waiver of the facility's right to appeal or challenge the accuracy or severity of the alleged deficiencies or an admission of past or ongoing violation of State or Federal regulatory requirements. 1. No individual residents were identified as impacted. At the time of the finding, environmental staff was verbally reminded about the importance of keeping laundry in sealed bags and the use of PPE during laundry processing. 2. The Director of Nursing and/or designee will educate all environmental service staff and nursing assistants on the need to place resident personal laundry that is in a mesh bag in a plastic bag before removing it from the residents' room and the importance of using PPE when working in the soiled laundry area to prevent the potential spread of infection related to resident personal laundry processing. 3. The Administrator and/or designee will educate the Director of Nursing and Human Resources on the updates to the facility policy COVID-19 Testing and Exposure Management. Specifically, but not limited to the need to consider the continuum of options for addressing staffing shortages, and that contingency strategies followed by crisis strategies are provided to augment conventional strategies and are meant to be considered and implemented sequentially. As per the CDC, "when staffing shortages are anticipated, healthcare facilities and employers, in collaboration with human resources and occupational health services, should use capacity strategies to plan and prepare for mitigating this problem." The Director of Nursing will also be educated on the need to consider the PA DOH staffing Ratios and Hours Per Patient Day (HPPD) requirements while balancing strategies to mitigate staffing shortages, safe staffing to meet resident needs, and providing evidence of measures considered. 4. The Director of Nursing and/or designee will conduct 5 visual audits per week for 2 months to ensure the environmental service staff and/or nursing assistants place resident personal laundry that is in a mesh bag in a plastic bag for transport and storage and the importance of using PPE when working in the soiled laundry area to prevent the potential spread of infection related to resident personal laundry processing. The NHA and/or designee will conduct an audit on the return to work for any employee who is off due to COVID-19 and what was considered to support a return to work outside of the conventional strategies to mitigate staffing shortages. The audit will be completed for 2 months or until substantial compliance is achieved. Audit findings will be reviewed at the QAPI meeting.