Failure to Perform Hand Hygiene After Providing ADLs and Incontinent Care
Penalty
Summary
Surveyors identified a deficiency in the facility’s infection prevention and control program related to hand hygiene practices by CNAs following provision of ADLs. Resident 4, who had diagnoses including generalized muscle weakness, difficulty walking, and dementia, had documented self-care deficits and required assistance with ADLs, including incontinent care. The resident’s MDS indicated dependence for showering, substantial assistance with toileting, partial assistance with oral hygiene and dressing, and supervision with eating. During an observation, CNA 2 was seen at the doorway of the resident’s room wearing gloves after providing care, then removing and discarding the gloves in a trash receptacle near the doorway without performing hand hygiene with soap and water or alcohol-based hand rub (ABHR). Shortly afterward, CNA 1 was observed removing and discarding gloves in the same manner and then proceeding to a table to document, again without performing hand hygiene. In subsequent interviews, CNA 1 stated she had provided incontinent care and assisted the resident to activities, acknowledged she removed her gloves upon exiting the room, and confirmed she did not perform hand hygiene using ABHR, despite stating that hand hygiene should be performed after resident care due to the risk of contamination. CNA 2 reported she had provided perineal care with warm water and mild soap, assisted with dressing, and prepared the resident for activities, and confirmed she did not perform hand hygiene after providing care, while acknowledging that hand hygiene should be performed before and after resident contact. The Infection Preventionist stated staff are required to perform hand hygiene before entering and after exiting resident rooms and after providing direct care, and that CNA 1 and CNA 2 should have performed hand hygiene after removing gloves. The Administrator stated hand hygiene is required before and after resident care and after resident contact. Review of the facility’s Handwashing/Hand Hygiene policy showed that all personnel are required to perform hand hygiene before and after direct resident contact, after contact with bodily fluids, after removing gloves, and as the final step after removal of PPE, and that glove use does not replace the requirement for hand hygiene.
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