Failure to Maintain Effective Infection Prevention, Surveillance, and PPE Practices
Penalty
Summary
The deficiency involves the facility’s failure to maintain an ongoing infection prevention and control surveillance system and to consistently implement its own infection control policies and procedures. Surveyors observed multiple lapses in the use and availability of personal protective equipment (PPE) for residents on Contact Precautions and Enhanced Barrier Precautions (EBP). For one resident on contact precautions, signage required staff to don gown and gloves before entering, but the PPE cart outside the room contained no gloves; another PPE cart across the hall was also missing gloves, which was confirmed by the unit manager. A resident readmitted from the hospital over a weekend was placed on EBP only after the surveyor had already entered the room, and the unit manager could not explain why the required signage had not been posted earlier, later stating that nurses were responsible for ensuring orders were entered correctly upon readmission. The infection surveillance program did not ensure that symptomatic residents were tested for COVID-19 in accordance with facility policy and CDC guidance. Infection report forms and clinical notes documented that several residents had symptoms consistent with respiratory infection and possible COVID-19, including cough, congestion, wheezing, productive cough, stuffy nose, headache, fever of 101.5°F, leukocytosis, shortness of breath, nausea, vomiting, loose stools, lethargy, and difficulty with arousal. Despite these documented symptoms for multiple residents, their medical records contained no documentation that they had been tested for COVID-19 as required by the facility’s COVID-19 policy and CDC testing guidance. When interviewed, the Infection Control Preventionist stated that symptomatic residents should be tested and that the facility followed CDC guidance and its own policy, but was unable to explain why these particular symptomatic residents were not tested. Additional infection control failures were observed in the implementation of contact precautions, hand hygiene, medication handling, and environmental cleanliness. A resident on contact precautions for CRE in the urine had a sign on the door, but the isolation cart outside the room had no gloves. Another resident on contact precautions reported that staff were not wearing gowns and gloves when entering the room, and there was no garbage can in the room or bathroom for disposal of PPE. During medication administration, one LPN moved between units, used a computer, retrieved backup medications, and administered them without performing hand hygiene. Another LPN picked up a pill that had fallen onto a resident’s lap with a bare hand and returned it to the medication cup, and also poured a pill from a stock bottle into the palm of an ungloved hand before administration. During wound care, the wound treatment nurse flicked unrestrained long hair away from the face and continued wound treatment with the same gloves, and for a resident on contact precautions, entered the room and placed wound care supplies on a dresser without PPE, then later removed gown and gloves to obtain more supplies without performing hand hygiene. Surveyors also identified failures related to EBP signage and PPE bin sanitation. One resident’s door initially had no indication of any precautions, and CNAs entered with a mechanical lift and provided care without PPE; upon exiting, an EBP sign had been placed on the door requiring gown, gloves, and mask for all staff providing care. An agency CNA stated it was their first day back and that the sign had not been on the door before entering. On the same unit, a PPE bin contained a heavily soiled mask with dried brown and orange stains stored among clean masks, and another bin had a dried brown substance on the outside that had to be touched to open the drawers. Multiple CNAs opened the contaminated bin drawers and closed them without removing the soiled mask or discarding the clean masks stored with it, until an LPN removed the soiled mask and threw it away. Central supply staff later stated that all clean masks in the bin had to be disposed of and the bins sanitized, noting that one bin had an odor. When interviewed, the DON acknowledged that nurses should not touch pills with bare hands, that hand hygiene should be performed using soap and water when visibly soiled or alcohol-based hand rub otherwise, and that gloves should be kept in the isolation cart, while also stating understanding of the concerns raised by these observations.
