Failure to Implement Effective Infection Control and Water Management Program
Summary
The facility failed to develop, implement, and follow a comprehensive and effective infection prevention and control program, specifically regarding its water management plan to prevent the growth and spread of legionella bacteria. The deficiency was identified after a resident, who was bedbound, ventilator-dependent, and had not left the facility for over two weeks, became unresponsive and was hospitalized with septic shock and pneumonia. The resident subsequently tested positive for legionella pneumophila antigen and died in the hospital. Review of the facility's water management documentation revealed significant gaps, including the absence of updated control measures for areas affected by flooding and closure, lack of detailed plumbing schematics, and insufficient documentation of water system maintenance, flushing, and monitoring. There was no evidence that the water management plan had been revised to address changes in the physical plant, such as the closure of the Somerset unit after flooding, nor was there a written description of how water was supplied, heated, stored, or circulated throughout the building. Observations and interviews further revealed that water stagnation and potential sources of contamination were not adequately addressed. For example, the Somerset unit, which had been closed after flooding, still had water running to certain areas, and there were no logs or documentation to confirm that water lines were being flushed to prevent stagnation. In addition, the attic area above the affected resident's room showed signs of mold, water damage, a decomposed animal carcass, and leaking pipes, all of which were verified by maintenance staff. These environmental conditions, combined with the lack of clear signage and communication to staff regarding water restrictions and infection control measures, contributed to the risk of legionella exposure. The facility's infection control practices were also found lacking in other areas. For instance, a respiratory therapist was observed providing suctioning and tracheostomy care to a resident in contact isolation for Clostridium difficile infection without wearing appropriate personal protective equipment. This failure to adhere to standard infection control protocols had the potential to affect multiple residents on the same unit. Overall, the facility's inaction and insufficient oversight in both water management and general infection control practices led to the identified deficiencies.
Removal Plan
- Registered Nurse (RN) #431 notified the Medical Director, Administrator, Director of Nursing (DON) and Infection Control Physician of the Legionella case.
- Administrator, DON, Assistant Director of Nursing (ADON) and Human Resources instructed staff to avoid unflushed/restricted water and to use alternative (bottled or approved) water and ice.
- Administrator, Maintenance Director #368 and Dietary Director #317 implemented bottled water for all drinking and cooking.
- Use of ice machines, showers, whirlpool tub, hoppers were restricted on the Aspen unit and on the Birch, Dogwood, Crabapple units only bed baths with provided wipes were permitted as use of showers was restricted.
- Administrator, DON, ADON and Human Resources provided staff education to RNs, Licensed Practical Nurses (LPN), certified nursing assistants (CNA), Housekeepers, Activity staff, Respiratory Therapists (RT), and agency staff. The education included the Centers for Disease Control Legionella signs and symptoms, transmission, surveillance/detection, and the facility's water management program. For any staff not on the schedule due to leave or other reasons, education would be provided prior to start of next shift.
- DON and Registered Nurse (RN) #350 assessed all current residents for signs/symptoms of legionella infection (cough with phlegm, chest pain, fever, chills, and shortness of breath).
- Water was delivered to the facility by commercial provider.
- Bags of ice were delivered by commercial provider.
- Use of ice machine, sinks, showers, whirlpool tub, and hoppers were restricted on the remaining units of Birch, Crabapple, Dogwood and Somerset.
- A phone call was held with the local health department and Ohio Department of Health Bureau of Environmental and Radiation Protection for guidance on legionella mitigation and testing.
- Portable handwashing sinks were delivered and stationed on Aspen unit.
- Signage was posted by VPCS #806, RDCS #803, the DON, ADON and Respiratory Therapy Director instructing staff to avoid unflushed/restricted water and to use alternative (bottled/approved) water.
- ServPro performed professional attic cleaning on the Aspen unit including debris removal, HEPA vacuuming, antimicrobial treatment, stain/odor blocking sealant application, air/surface testing, removal of wet insulation, ceiling repair below the attic and vent pipe repair within the Aspen unit Hallway/Attic area between rooms 503, 508, 502, 509, 510 and 501.
- A phone call meeting was held with a legionella consultant to review the facility water management plan.
- Portable handwashing stations were delivered and stationed throughout the facility.
- Maintenance Supervisor (MS) #368 installed legionella prevention filters on the Aspen unit (in the shower room, medication room and rooms 501, 502, 503, 504, 505, 506, 507, 509, 510, 515, 516, 517, 518 and 519).
- Regional Director of Operation completed Somerset unit water flush which included full flushing of all pipes, bathrooms, sinks, hoppers and dialysis den. Documentation was submitted to the Administrator.
- An Ad Hoc Quality Assessment and Performance Improvement (QAPI) meeting was held with the Medical Director, VPCS, RDO, RDCS, Administrator, DON, MDS, Housekeeping, MS #368, Human Resources, RN #431 and the ADON for QAPI tracking including weekly flushing compliance, audit outcomes, symptom surveillance, environmental concerns, legionella water management program review and risk assessment analysis review.
- MS #368 installed additional legionella prevention filters to two hand sinks in dialysis, one hand sink in the therapy gym, one hand sink in the first floor public rest room, one hand sink in laundry and six sinks in the kitchen, one sink in the Birch, Dogwood, Crabapple medication rooms, one sink in the first floor dining room, one sink in the Dogwood shower room and the Crabapple room sinks in rooms 710, 716 and 718.
- RDO re-educated MS #368 on weekly flushing, documentation rules, proper procedures (15 minutes run time, full toilet flush/hopper flush) and reporting/escalation steps.
- RDO contacted an additional Legionella Consultant #901 for mitigation support.
- Legionella Consultant #901 performed water testing of samples collected across Aspen, Birch, Crabapple, Dogwood and Somerset units.
- The facility implemented a plan for clinical monitoring by the DON/ADON or designee to review resident documentation weekly for four weeks for symptoms such as temperature, pulse, respirations, blood pressure, oxygen level, lung sounds, cough and phlegm, chest pain, fever/chills, shortness of breath.
- The facility implemented a plan for environmental monitoring by the Administrator or designee to review flushing logs weekly for four weeks and monthly thereafter.
- The facility implemented a plan for enhanced surveillance by the DON/ADON to include enhanced respiratory illness monitoring and immediate reporting of suspected cases.
- The facility implemented a plan for the water management program to be on-going and include daily monitoring of temperature, disinfectant levels, flushing logs, legionella filters for placement and function twice a day and monthly Water Management Plan meetings until investigation closed.
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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