Now that routine surveys are beginning to take place in most states, it is important that vigilant infection prevention and control practices do not take a backseat to other survey-ready quality assurance activities. Notably, HHS announced a $2.0 billion payment incentive program (VBP) with $500 million per month for four months Sept-December 2020 paid based on SNF performance in managing the rate of COVID-19 infections each month and the COVID-19 mortality rate for the month as compared to other facilities with similar community infection rates. Details are forthcoming on the specific formula to be used for distribution of funds, but it is anticipated that a facility may be excluded from receiving a portion of these funds if performing significantly worse than peers on these measures.

Focused Infection Control Surveys

In addition to payment incentives, focused infection control surveys will continue for any nursing home with 3 or more new COVID-19 suspected and confirmed cases since the last National Healthcare Safety Network (NHSN) COVID-19 report, or 1 confirmed resident case in a facility that was previously COVID-free. States will also be required to perform annual Focused Infection Control surveys of 20 percent of nursing homes based on State discretion or additional data that identifies facility and community risks. The enhanced enforcement for infection control deficiencies also continues to be in effect, which includes (1) enforcement of directed plan of corrections for any Infection Control deficiency cited and (2) denial of payment for new admissions and (3) civil monetary penalties for repeat infection control citations or citations at harm or Immediate Jeopardy level.

The most common citations seen during the infection focused surveys relate to:

      • Personal protective equipment (PPE)- common deficiency examples include:
        • Staff not wearing mask appropriately to cover mouth and nose
        • Staff entering isolation room without wearing all required PPE
        • Failing to don and/or doff PPE appropriately
        • Not removing PPE before leaving isolation rooms
        • No goggles or face shields on isolation carts
        • Residents in common areas without face coverings
      • Failing to immediately place symptomatic residents or new admissions in isolation
      • Screening procedures – deficiency examples include:
        • Failing to screen surveyors upon entering
        • Staff screening performed on unit versus at entrance to facility
        • Outpatient therapy patients not screened upon entering facility
        • Staff screening logs with omissions
      • Hand hygiene
        • Between tasks, when changing PPE, after touching face or mask
        • For 20 seconds
        • Allow alcohol-based hand rub to dry
      • Inadequate social distancing between staff members
        • Including social distancing in non-patient care areas (break room, conference room, etc.)

Important actions to help prevent future outbreaks and/or Infection Control citations include:

Proactive Medical Review can assist you with preparing for Infection Control Focused surveys and recertification surveys, as well as provide assistance with plans of correction. Please contact us to learn how we can help you. Our Infection Control & Prevention focused services include:

      • Infection Preventionist Consultations
      • Infection Prevention & Control Training & Competency Assessments
      • Directed Plan of Correction Consultation
      • Policy and Procedure Development
      • Infection Control Focused Mock Surveys
      • Survey Support

 

Blog by Shelly Maffia, MSN, MBA, RN, LNHA, QCP, CHC, Proactive Medical Review

Click here to learn more about Shelly and the rest of the Proactive team.