Failure to Implement Antibiotic Stewardship and Infection Surveillance
Penalty
Summary
The deficiency involves the facility’s failure to implement its antibiotic stewardship and infection surveillance programs as required by its own policies. The Infection Surveillance policy required collection of data to identify infections, including infection site, pathogen, signs and symptoms, resident location, and tracking of all resident infections, as well as use of laboratory reports, antibiotic use, and culture results. The Antibiotic Stewardship Program policy required use of McGeer criteria to define infections, completion of assessment and data collection forms, and measurement of antibiotic use by monthly prevalence, antibiotic starts, and/or days of therapy. Despite these policies, the facility did not consistently complete McGeer forms, did not consistently obtain or document culture results, and did not consistently include infections and culture data on the Monthly Report of Resident Infections. For multiple residents who received antibiotics, there was no documentation that McGeer criteria were applied or that required surveillance forms were completed. One resident received Levaquin for pneumonia, another received antibiotics for sepsis secondary to a UTI with a documented Proteus mirabilis urine culture, and another received Ciprofloxacin for a UTI with a urine culture showing >100,000 cfu/mL Escherichia coli; none of these cases had McGeer forms completed, and several were not entered on the Monthly Report of Resident Infections. Additional residents received antibiotics for a thigh abscess, UTIs treated with Ciprofloxacin, Rocephin, Keflex, Ampicillin, Bactrim DS, and Macrobid, yet their records similarly lacked McGeer forms, and their infections or culture results were either omitted or incompletely documented on the Monthly Report of Resident Infections. In some cases, urine cultures were obtained but the organism and results were not incorporated into the infection logs, and in other cases antibiotics were started without any urine culture being completed prior to treatment. One resident’s progress notes documented that urology advised starting Ampicillin for a positive urinalysis and later confirmed that the current antibiotic was sensitive to the culture, but the Monthly Report of Resident Infections stated no urine culture was completed and did not list an organism. Two other residents received antibiotics for UTIs without any urine culture obtained before treatment, and their infections were not captured on the Monthly Report. During interview, the Chief Nursing Officer acknowledged that infection surveillance was not thoroughly conducted, did not meet the required criteria for antibiotic use, and that culture results were not obtained or reviewed to track and trend infections.
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