Failure to Follow Hand Hygiene and Enhanced Barrier Precautions During Incontinence Care
Penalty
Summary
The deficiency involves the facility’s failure to maintain an effective infection prevention and control program, including required hand hygiene and use of personal protective equipment (PPE), during incontinence care for two residents. For one resident with cerebral palsy, severe cognitive impairment, total dependence for care, bowel and bladder incontinence, and a feeding tube, the record showed active orders for Enhanced Barrier Precautions (EBP) every shift. The resident’s care plan documented dependence on staff for all ADLs, including incontinence care and repositioning. An EBP sign posted by the resident’s name plate instructed that everyone must clean their hands before entering and when leaving the room, and that staff must wear gloves and a gown for high-contact resident care activities such as dressing, bathing, transferring, changing linens, and providing hygiene. PPE was available just inside the room door and hand sanitizer was located outside the room. On observation, two CNAs entered this resident’s room without performing hand hygiene and without donning a gown or gloves prior to entry, despite the EBP signage and available PPE. Once inside, they applied clean gloves, closed the door, and pulled the privacy curtain. One CNA prepared supplies on a clean barrier, unlatched the resident’s brief, and cleansed the perineal area, then turned the resident to her side and cleansed the buttocks. The CNA rolled the soiled brief inward and discarded it in the trash. Without changing gloves or performing hand hygiene, the CNA then obtained a clean brief, placed it under the resident, turned her back, and secured the brief. Both CNAs then repositioned the resident, removed their gloves, and exited the room without performing hand hygiene, proceeding down the hallway. This sequence did not follow the facility’s EBP policy, hand hygiene policy, or perineal care policy, which required gown and glove use for high-contact care under EBP, hand hygiene before and after resident contact and after glove removal, and glove removal and hand sanitizing before handling clean linens or briefs. A second observation involved another resident with hemiplegia following cerebral infarction, aphasia, seizure disorder, anxiety, severe cognitive impairment, and total dependence on staff for toileting, showering, dressing, and incontinence care. For this resident, the two CNAs performed hand hygiene upon room entry, shut the door, pulled the privacy curtain, gathered supplies on a clean barrier, and donned clean gloves. One CNA unlatched the brief and cleansed the perineal area using a new wipe with each swipe, while the other CNA assisted with turning the resident to her side so the buttocks could be cleansed. The soiled brief was folded inward and discarded. Without changing gloves or performing hand hygiene, the CNA then obtained and applied a clean brief, and both CNAs repositioned the resident. After care, both CNAs removed their gloves; only one performed hand hygiene, while the other exited the room and went down the hallway without cleaning her hands. This conduct conflicted with the facility’s hand hygiene and perineal care policies, which required hand hygiene before moving from soiled to clean body sites, immediately after glove removal, and before touching clean linens or briefs. In interviews, one CNA reported working at the facility for two months and stated that hand hygiene should be performed anytime she enters or exits a resident’s room, acknowledging she had washed her hands in the utility room when gathering supplies for the first resident but did not perform hand hygiene upon entering or exiting the room and that she “must have forgotten.” She stated she washed her hands before incontinence care on the second resident but forgot to do so afterward, and reported she had not been taught to change gloves during incontinence care, usually using the same gloves throughout and only changing them before putting on new sheets. She also stated she was not aware the first resident was on EBP, missed seeing the sign, and had not been trained to use a gown for that resident’s care, despite recognizing that not wearing PPE and not performing appropriate hand hygiene or glove changes could cause cross contamination and spread infections. The second CNA stated that hand hygiene should be performed before and after any care but admitted she did not perform hand hygiene before or after incontinence care on the first resident, explaining she normally washes her hands but had not been feeling well and forgot. She stated she was familiar with EBP and believed a gown and gloves should be worn before entering the room, was aware of the sign and saw the PPE, but thought it was only needed if the resident was sick and did not know that a feeding tube required gown use. The ADON stated her expectation that staff perform hand hygiene when entering or leaving a resident room and that, with any incontinence care, hand hygiene should be performed between glove changes, specifically between removing a soiled brief and applying a clean brief. She stated that if CNAs were not performing hand hygiene or glove changes appropriately, it could cause a risk of spreading infections or UTIs, and that staff should use PPE for any resident care when a resident is on EBP, as indicated by signage and PPE bins. The DON, who served as the infection preventionist, stated she expected staff to perform hand hygiene when entering or leaving rooms and when going from dirty to clean during incontinence care, and that failure to perform hand hygiene or change gloves appropriately was an infection control issue with a risk of infection. She also stated she expected staff to wear a gown and gloves before entering a resident room on EBP, that staff were trained upon hire and as needed on infection control and incontinence care, and that failure to use PPE was an infection control issue. The Administrator stated he expected staff to wash their hands before and after care, before wearing gloves, and with any glove changes, and that improper hand hygiene could transfer infections. The facility’s written policies and CDC guidelines reviewed by surveyors supported these expectations for hand hygiene, glove changes, and EBP use, which were not followed in the observed care for the two residents.
