Failure to Implement Enhanced Barrier Precautions During High-Contact Care and Wound Care
Penalty
Summary
The deficiency involves the facility’s failure to implement its Enhanced Barrier Precautions (EBP) policy for residents with wounds requiring high-contact care. The facility’s policy, revised 7/17/25, requires an EBP order for residents with wounds, including venous stasis ulcers and pressure ulcers, and specifies that gowns and gloves must be used for high-contact resident care activities such as dressing, bathing, transferring, toileting assistance, and wound care. The policy also requires hand hygiene before and after applying or removing PPE and before and after handling clean or soiled dressings or linens. For one resident (R1), who had diagnoses including a right femur fracture with routine healing, osteoporosis with pathological fracture, and chronic venous insufficiency with bilateral lower extremity venous stasis ulcers requiring wound care, the medical record contained an order for EBP related to vascular ulcers to both lower extremities every shift. R1 also had an order for wound care to bilateral leg ulcers twice weekly. During observation, a CNA entered and exited R1’s room without donning any PPE while assisting with toileting and a transfer. The CNA stated PPE was not worn because they believed only wound care required EBP. R1 later reported having wounds with dressings on both legs, that staff performed wound care twice weekly wearing gloves but not gowns or face shields/masks, and that staff assisted with transfers and personal hygiene without wearing gowns. For another resident (R4), who had diagnoses including a stage 2 pressure ulcer of the buttock, opioid dependence, and a non-displaced sacral fracture, the medical record contained an order for EBP related to a pressure area on the left buttock. During observation of wound care, an RN wore gloves but did not don a gown or face shield/mask while removing a dressing with yellow drainage, cleansing the wound with wound cleanser, and completing wound care. The RN confirmed that the resident was on EBP and acknowledged a gown should have been worn during wound care. The Infection Preventionist confirmed that both residents had EBP orders and that a gown and gloves are required for all residents on EBP, with face protection required when there is risk of splash, and verified that high-contact cares include bed changes, transfers, walking, toileting assistance, shaving, bathing, and wound care.
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