Failure to Follow Enhanced Barrier Precautions and Hand Hygiene Requirements
Penalty
Summary
The deficiency involves the facility’s failure to implement its infection prevention and control program by not ensuring staff consistently performed hand hygiene and donned required PPE, specifically gowns and gloves, when caring for residents on Enhanced Barrier Precautions (EBP). One resident with severe cognitive impairment, an indwelling Foley catheter, and a wound was care planned for EBP due to risk of acquiring or transmitting infection. The care plan required staff to wear gowns and gloves for high-contact care and to provide catheter care per facility protocol. During observation, a CNA provided morning care to this resident without wearing a gown, later acknowledging she was supposed to wear one and that the resident was on EBP because of the Foley catheter. Another resident with a diagnosis including basal cell carcinoma and an order for EBP due to a wound had an EBP sign posted on the room door instructing everyone to clean their hands before entering and leaving and for providers and staff to wear gloves and a gown for high-contact resident care activities. A CNA was observed performing ADL incontinence care for this resident without wearing a gown. When questioned, the CNA stated that EBP required a gown and gloves when providing care, admitted she did not have a gown on, and explained she had been moving too fast and forgot, while also acknowledging that EBP is intended to protect residents and staff from spreading infection. A third resident with diagnoses including anxiety, severe protein-calorie malnutrition, and a healing pubic fracture had physician orders for EBP due to a wound and a care plan identifying risk for acquiring or transmitting infection, directing staff to follow infection prevention protocols including EBP. The resident’s room displayed an EBP sign with instructions for hand hygiene and use of gown and gloves for high-contact care. The resident was observed in bed, awake, being assisted with feeding by a CNA who was not wearing a gown and did not perform hand hygiene upon leaving the room. When the observation was brought to her attention, the CNA stated she did not have to wear a gown while feeding the resident in the room. The facility’s infection preventionist later described that residents are placed on EBP for MDRO risk and that staff performing direct patient care, including incontinence care, wound care, handling indwelling devices, and assisting with feeding in the room, are required to use gowns and gloves and perform hand hygiene, consistent with the facility’s written Standard and Transmission-Based Precautions policy.
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