TB Screening and Water Management Documentation Failures
Summary
Facility staff failed to follow infection prevention and control procedures related to tuberculosis screening for employees and residents. Review of the facility’s TB testing policy showed new employees were to receive a 2-step PPD upon hire and annual TB testing, and residents were to receive a 2-step PPD upon admission or readmission and annual TB testing as ordered. In review of 10 employee files, five employees did not have TB testing completed and documented in accordance with the policy, including a dietary aide, an LPN, a CMT, an RN, and another employee whose records showed incomplete or improperly timed testing documentation. The employee records showed several examples of incomplete or delayed testing. One dietary aide and one LPN had first-step TB tests documented after their hire dates, another employee had first- and second-step TB tests documented months after hire, one CMT had only a first-step TB test documented with no second-step test on file, and one RN had TB test documentation without recorded read dates. During interviews, the DON, Administrator, and BOM each described different responsibilities for ensuring TB testing was completed, and the BOM stated staff were scheduled for TB tests before starting work but that missed tests occurred when employees did not show or nurses did not administer them. Resident TB screening was also incomplete. Review of five sampled resident records showed four residents did not have documentation of the required first-step and/or second-step TB tests in their medical records. The Corporate DON stated residents were expected to have the first-step TB test upon admission and the second-step within 14 days, and believed the issue was that information was not flowing through the EMR to trigger the tests. The Administrator stated the DON was ultimately responsible for ensuring resident TB testing was completed and noted there had been significant turnover in the DON position. The facility also failed to develop and implement complete water management documentation to address Legionella prevention. The facility’s policy required maintaining potable water systems in a clean condition, controlling temperatures, minimizing stagnation, identifying dead legs and low-use conditions, performing routine flushing and monitoring, and documenting all monitoring and corrective actions. However, the Water Management Program did not contain a facility-specific risk assessment, identification of dead legs or low-use conditions, or documentation of routine flushing, cleaning, maintenance, and monitoring. During the Life Safety Code tour, the facility was observed to have a cooling tower, multiple ice machines, and multiple water sources, and staff stated they could not locate the risk assessment or documentation of routine water system monitoring and maintenance.
Penalty
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