Failure to Implement Enhanced Barrier Precautions for Residents With Wounds and Indwelling Devices
Penalty
Summary
The deficiency involves the facility’s failure to implement its own Enhanced Barrier Precautions (EBP) policy for residents with wounds and indwelling medical devices, resulting in staff not using required gowns and gloves during high-contact care activities. The facility’s March 2024 EBP policy required EBP for all residents with wounds or indwelling medical devices, regardless of MDRO status, and specified that gowns and gloves must be used for high-contact care such as dressing, bathing, transferring, toileting, changing linens and briefs, and device and wound care. The policy also required clear EBP signage on or near the resident’s door, availability of PPE near or outside the room, and staff education and competency regarding EBP. For one resident with an indwelling urinary catheter, the comprehensive MDS documented the catheter, and the care plan directed staff to provide EBP and use gowns and gloves during high-contact care. However, observations showed there was no EBP sign on the door and no gowns available inside or outside the room. A CNA entered the room without a gown or gloves, applied a gait belt, transferred the resident from a recliner to a wheelchair, handled the urinary catheter collection bag, and pushed the resident into the bathroom. In the bathroom, the CNA donned gloves but no gown, assisted the resident to stand, pulled down pants, removed an unsoiled incontinence brief, manipulated the catheter tubing, and attached it to the handrail. After the resident complained of a sore on the bottom, the CNA removed gloves and exited the room without handwashing. Subsequently, an LPN and the same CNA entered the bathroom wearing gloves but no gowns; the CNA assisted the resident to stand while the LPN wiped the resident’s bottom, noted blood on the tissue, and left after removing gloves. Another LPN then entered with gloves but no gown, cleansed and dressed an open wound on the buttock, and left after removing gloves and using hand sanitizer. The CNA then completed perineal care, catheter manipulation, clothing adjustment, transfers, and linen changes wearing only gloves and no gown. Interviews showed the LPN believed EBP should be used when applying creams, and the CNA was unsure what EBP was used for and stated he/she only wore gloves when caring for residents. For another resident with end stage renal disease, dependence on dialysis, multiple documented wounds (coccyx, left buttock, right arm, right heel), and a dialysis CVC and AV fistula, the care plan and physician orders specified EBP for wounds and dialysis CVC, with daily wound cleansing and dressing changes. Despite this, repeated observations showed no EBP sign on the door and no PPE cart or PPE door hanger outside the room. Staff, including an LPN and CNA, entered the room and performed high-contact care such as changing linens while the resident was in bed, and other care activities, wearing only gloves and no gowns. A guest and the resident’s spouse both reported that staff only wore gloves when providing care and wound care. In interviews, a CNA stated they relied on door signage to know when to wear a gown, an LPN stated uncertainty about whether the resident was on EBP and confirmed only glove use, and a nurse manager acknowledged that residents with dialysis access and/or wounds should be on EBP, that every such resident should have PPE outside the room, and that the EBP sign likely was never placed on the door. The DON stated that EBP was required for residents with MDRO history, draining wounds, or indwelling devices including catheters, IV lines, dialysis access, and central lines, and that nurse managers were responsible for setting up EBP, while the Administrator and Medical Director both stated they expected staff to know which residents should be on EBP and to use all required PPE.
