Failure to Follow Hand Hygiene and Enhanced Barrier Precautions During Incontinence Care
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.
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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