Failure to Follow Contact Precautions and Hand Hygiene During Incontinent Care
Penalty
Summary
The deficiency involves the facility’s failure to implement its infection prevention and control program for a resident on contact precautions and Enhanced Barrier Precautions (EBP). The resident was an older adult admitted with chronic systolic heart failure, anemia, and osteoporosis, and had active physician orders for EBP related to a multidrug-resistant organism (MDRO) and an abnormal urinalysis, with contact isolation precautions in place. Her care plan documented contact isolation precautions and the need to follow the facility’s isolation policy. A Significant Change MDS showed she had moderate cognitive impairment and was always incontinent of bowel and bladder, requiring partial to moderate assistance with toileting hygiene. During an observed episode of incontinent care, two CNAs entered the resident’s room, which had a contact precautions sign posted and contained PPE supplies including gowns, N95 masks, face shields, and biohazard bags. Neither CNA performed hand hygiene before starting care, and both donned only gloves without gowns despite the contact precautions order. One CNA pulled down the resident’s pants and brief and performed perineal cleansing of the inner thighs and vaginal area, while the other CNA rolled the resident, cleansed the rectal area, removed the soiled brief, and then placed a clean brief under the resident and applied barrier ointment without changing gloves between handling soiled items and clean items. One CNA washed her hands only after removing gloves at the end of care, and the other CNA removed gloves and discarded them without documented hand hygiene. In subsequent interviews, both CNAs acknowledged they did not pay attention to the contact precautions sign, did not wear gowns, did not perform hand hygiene before care, and did not change gloves when moving from dirty to clean tasks, stating they believed gloves could be worn throughout care if not visibly soiled with feces. They each had prior competency checklists indicating they had been observed performing perineal care and infection control. The ADON, serving as the Infection Preventionist, and the DON described facility policies and expectations that staff wear gowns and gloves for residents on contact precautions or EBP during high-contact care such as changing briefs, perform hand hygiene before, during, and after care, and change gloves between dirty and clean tasks, consistent with the facility’s written policies on Enhanced Barrier Precautions, Isolation/Transmission-Based Precautions, and Handwashing/Hand Hygiene.
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