Failure to Follow Enhanced Barrier Precautions During High-Contact Care
Penalty
Summary
The deficiency involves the facility’s failure to ensure staff followed its Enhanced Barrier Precautions (EBP) policy during high-contact resident care activities for residents requiring EBP. The facility’s written policy required the use of gowns and gloves for high-contact care activities such as dressing, bathing, transferring, providing hygiene, changing linens, changing briefs or assisting with toileting, device care or use, and wound care for residents with wounds or indwelling medical devices. EBP signs were posted on the doors of residents requiring these precautions, and gowns and gloves were made available near or inside those rooms. The policy also stated that staff were trained on EBP upon hire and annually, and that the Infection Preventionist would periodically monitor adherence. For one resident with functional limitations in both upper and lower extremities, dependent in all ADLs, with a feeding tube and open areas on the right posterior thigh, surveyors observed an EBP sign on the door and PPE supplies inside the room. During a skin assessment, an LPN and the Treatment Nurse both donned gloves but did not wear gowns, despite the presence of a feeding tube stoma with a dressing and open skin areas. This resident’s record showed wound infection, diabetes, stroke, and tube feeding orders, but no specific physician order for EBP, even though the room was posted for EBP. Another resident with cerebral palsy, seizure disorder, total dependence in ADLs, incontinence of bowel and bladder, and a Stage 3 pressure ulcer had a care plan and physician order specifically requiring EBP with gown and gloves for high-contact care due to chronic wounds. Surveyors observed the Treatment Nurse performing a skin assessment and later wound treatment to open areas on the left dorsal foot and heel while wearing gloves but no gown, despite an EBP sign on the door and PPE available. On a separate occasion, two CNAs provided personal care and a bed bath to this resident while each wore gloves but no gowns. One CNA later stated awareness that a gown should have been worn, while the other CNA reported not knowing a gown was required during personal care. A third resident, totally dependent in ADLs with a history of stroke, seizure disorder, respiratory failure, a feeding tube, and a tracheostomy, had a physician order for EBP requiring gown and gloves for high-contact care. An EBP sign and PPE supplies were present at the room. During a skin assessment, an LPN and a CNA donned gloves but not gowns. While in the room, the resident had a large loose bowel movement, and both staff cleaned the resident and changed the incontinent brief without wearing gowns. A fourth resident with quadriplegia, dependence in all ADLs, and a sacral pressure injury had an EBP sign on the door and PPE supplies available. The Treatment Nurse performed a skin assessment of the sacral area while wearing gloves but no gown. In interviews, the Infection Preventionist, Treatment Nurse, DON, and Administrator all stated that staff were expected to follow the EBP signage and policy, and the Treatment Nurse and an LPN acknowledged that gowns should have been worn during these care activities.
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