Failure to Follow Transmission-Based Precautions, Enhanced Barrier Precautions, and Hand Hygiene Requirements
Penalty
Summary
The deficiency involves multiple failures in implementing transmission-based precautions, enhanced barrier precautions, and proper hand hygiene. In one instance, a CNA entered the room of a cognitively intact resident who was on contact and droplet isolation for a newly identified positive COVID-19 test without wearing required PPE, with their mask pulled down to the chin. The resident’s door displayed signs for droplet and contact isolation, and a PPE cart was properly stocked outside the room. The CNA stated they did not think the resident was on isolation precautions, and the resident reported not knowing if she was on contact isolation. A nurse later confirmed the resident was on contact and droplet isolation and that staff should be wearing PPE when entering the room. Another set of deficiencies involved improper use of enhanced barrier precautions and PPE by non-nursing staff. A housekeeping and laundry manager entered the room of a resident on enhanced barrier precautions wearing only a gown and no gloves to deliver a meal tray. While in the room, she touched the bedside table to move items and then exited the room, walked across the hallway still wearing the gown, and discarded it in a regular trash can at the nurse’s station before using hand sanitizer. She acknowledged seeing the enhanced barrier precautions sign and admitted she donned a gown but not gloves because she was unsure of the rules. In a separate incident, a laboratory technician entered the room of another resident on enhanced barrier precautions, who had a PICC line and a JP drain, and drew blood without wearing a gown as required by the posted signage and facility policy. The technician stated she did not see the signage or the PPE available on the back of the door, but indicated she would normally wear a gown and gloves for a blood draw under enhanced barrier precautions. Additional deficiencies were identified in hand hygiene and glove use during medication administration and wound care. During medication administration to a resident with COVID-19 and weeping edema of the lower extremities, an LPN performed hand hygiene and donned PPE before entering the room, then touched the resident’s weeping lower extremities and soiled bed linens with gloved hands, and subsequently handled a blood pressure cuff and administered medications without changing gloves or performing hand hygiene. The LPN later verified that soiled gloves were not removed and hand hygiene was not performed before touching the blood pressure cuff and medications, contrary to the facility’s hand hygiene policy. In another observation, the same LPN performed wound care on a cognitively intact resident with multiple lower extremity wounds. During the procedure, the LPN intermittently performed hand hygiene and changed gloves but also touched her cell phone and the back pocket of her scrubs with gloved hands, then continued wound care, handled dressings, wiped the floor, and moved the resident’s wheelchair before finally removing PPE and performing hand hygiene. The LPN acknowledged that hand hygiene was not consistently performed after handling soiled dressings and linens and before moving from contaminated to clean body sites, and the unit manager confirmed that facility policy required hand hygiene in these situations. Facility policies reviewed by surveyors specified that contact precautions require hand hygiene, gloves, and gown; droplet precautions require gloves, gown, mask, and eye protection; and enhanced barrier precautions require gown and glove use during high-contact resident care activities for residents colonized with MDROs or at increased risk due to indwelling devices. The hand hygiene policy required hand hygiene before moving from a contaminated body site to a clean body site, after handling contaminated objects or equipment, and before and after handling clean or soiled dressings or linens, as well as before handling medications. The observed practices by the CNA, housekeeping and laundry manager, laboratory technician, and LPN did not conform to these written policies, resulting in the cited infection prevention and control deficiency affecting multiple residents. This deficiency represents noncompliance investigated under Complaint Number #2713145.
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