Failure to Implement Enhanced Barrier Precautions for Residents Requiring High-Contact Care
Penalty
Summary
The deficiency involves the facility’s failure to implement its infection prevention and control program by not applying Enhanced Barrier Precautions (EBP) for residents who met criteria and were identified by the facility as being on EBP. The facility had identified 26 residents as requiring EBP, yet for at least two of three residents reviewed, there were no physician orders or nursing care plan entries documenting EBP, and no visual cues or supplies at the room entrances to support their use. The facility’s EBP policy, dated August 2022, stated that gowns and gloves were to be used for high-contact resident care activities for residents with wounds or indwelling medical devices when contact precautions did not otherwise apply. One resident had multiple significant medical conditions including dementia, acute respiratory failure, Type II diabetes with neuropathy, dysphagia, a history of aspiration pneumonia, a G-tube, and hypertension, and was in a persistent vegetative state, fully dependent for ADLs, incontinent of bowel and bladder, and at risk for pressure ulcer development with existing moisture-associated skin damage and a sacral wound requiring treatment. Despite this, the medical record lacked any physician order or nursing plan of care for EBP. During observation, the resident was receiving tube feeding, and there was no EBP signage or PPE at the room entry. Two CNAs entered the room and performed incontinence care and repositioning without donning PPE, and one CNA later confirmed they were unaware the resident was on EBP or that PPE was required during direct care. The DON also verified there was no signage or PPE at the room entry. Another resident had diagnoses including HIV, Type II diabetes with neuropathy, COPD, necrotizing fasciitis, peripheral vascular disease, lymphedema, and nutritional anemia, with moderately impaired cognition, dependence for ADLs, incontinence of bowel and bladder, and risk for pressure ulcer development, and was admitted with one stage III and one stage IV pressure ulcer requiring daily wound care. Observation showed the resident’s call light active and, again, no EBP signage or PPE at the room entrance. Two CNAs entered to perform incontinence care and repositioning without donning PPE. A CNA who had assumed care earlier verified they were unaware the resident required EBP and confirmed the absence of signage and readily accessible PPE. The DON stated that the facility’s policy did not include instructions to obtain or require a physician order or plan of care to place or maintain a resident on EBP.
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