Failure to Follow EBP PPE Requirements and Hand Hygiene During High-Contact Care
Summary
The deficiency involves the facility’s failure to implement its infection prevention and control program by not ensuring appropriate use of personal protective equipment (PPE) and proper hand hygiene during high-contact resident care activities. One resident with encephalopathy, acute respiratory failure with hypoxia, quadriplegia, anoxic brain damage, hepatitis B, hepatitis C, and bipolar disorder was under Enhanced Barrier Precautions (EBP) and had a PEG tube for tube feeding. During observation, a CNA provided incontinence care to this resident while wearing only gloves and no gown, despite a posted EBP sign specifying that staff must wear both gown and gloves for high-contact care activities such as changing briefs, providing hygiene, and device care, including feeding tubes. The CNA acknowledged that a gown should have been worn due to the resident being under EBP. A second resident had type 2 diabetes mellitus, active C. difficile enterocolitis, a stage II pressure ulcer on the coccyx, and an indwelling urinary catheter with orders for catheter care every shift and as needed. This resident was on contact isolation precautions for C. difficile. During observed incontinence and catheter care, a CNA and a Unit Manager performed hand hygiene and donned PPE appropriately before entering the room. The CNA then removed the resident’s soiled brief and cleaned the resident’s front perineal area, after which she removed only one pair of double gloves but did not perform hand hygiene. The CNA and Unit Manager then repositioned the resident to clean the back side, where dried feces were present. The CNA completed washing and drying the resident’s back side and continued care activities, including placing a clean brief, adjusting the gown, repositioning the resident, and arranging linens, all while wearing the same contaminated gloves and without performing hand hygiene. The CNA confirmed she did not perform hand hygiene during this sequence and that she still had dirty gloves on when finishing the resident’s care. The ADON stated that staff were expected to follow the facility’s hand hygiene and infection control policies when providing incontinence care, personal hygiene, and care for residents on contact precautions for C. difficile. Facility policies and CDC guidance reviewed in the report emphasized that gloves are not a substitute for hand hygiene and that hand hygiene is required before donning and after removing gloves, and when moving from a soiled to a clean body site on the same patient.
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