CMS State Survey Infection Control Regulations and Guidelines

(Last edited: Wednesday, 25 March 2020, 8:57 PM)
A Letter from the President of The NAAP brought to you from
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Infection control
By: Alisa Tagg, NAAP President
On March 4, the Centers for Medicare & Medicaid Services (CMS) announced several actions aimed at limiting the spread of the Novel Coronavirus 2019 (COVID-19). Specifically, CMS is issuing a call to action to health care providers across the country to ensure they are implementing their infection control procedures, which they are required to maintain at all times.
State Survey Agencies and Accrediting Organizations will focus their facility inspections exclusively on issues related to infection control and other serious health and safety threats, like allegations of abuse – beginning with nursing homes and hospitals. The agency is announcing that it has deployed an infection prevention specialist to CDC's Atlanta headquarters to assist with real-time in guidance development.

These actions from CMS are focused on protecting American patients and residents by ensuring health care facilities have up-to-date information to adequately respond to COVID-19 concerns while also making it clear to providers that as always, CMS will hold them accountable for effective infection control standards. The agency is also supplying inspectors with necessary and timely information to safely and accurately inspect facilities.

Our Federal Regulations provide clear guidance on how to be prepared:

F880: The facility must establish and maintain an infection prevention and control program designed to provide a safe, sanitary and comfortable environment and to help prevent the development and transmission of communicable disease and infections.

The intent of this regulation is to ensure that the facility:

  • Develops and implements an ongoing infection prevention and control program (IPCP) to prevent, recognize, and control the onset and spread of infection to the extent possible and reviews and updates the IPCP annually and as necessary. This would include revision of the IPCP as national standards changed.
  • Establishes facility-wide systems for prevention, identification, investigation, and control of infections of residents, staff and visitors. It must include an ongoing system of surveillance designed to identify possible communicable diseases or infections before they can spread to other persons in the facility and procedures for reporting possible incidents of communicable disease or infections.

    NOTE: For purposes of this guidance, "staff" includes employees, consultants, contractors, volunteers, caregivers who provide care and services to residents on behalf of the facility, and students in the facility's nurse aide training programs or from affiliated academic institutions.
  • Develop and implements written policies and procedures for infection control that, at a minimum:
- Explain how standard precautions and when transmission-based precautions should be utilized, including but not limited to the type and duration of precautions for particular infections or organisms involved and that the precautions should be the least restrictive possible for the resident given the circumstances and the resident's ability to the follow the precautions.
- Prohibit staff with a communicable disease or infected skin lesions from direct contact with residents and their food, if direct contact will transmit the disease.
- Require staff follow hand hygiene practices consistent with accepted standards of practice.
- Requires staff handle, store, process, and transport all linens and laundry in accordance with accepted national standards in order to produce hygienically clean laundry and prevent the spread of infection to the extent possible.

What does this mean for Activity Professionals? It is time to regulate infection control procedures in our departments. What are we doing to maintain proper protocols? How are we preventing the spread of infection?

The number one thing to do is WASH YOUR HANDS! How many times have we heard this, right? Washing hands is the number one way to prevent the spread of any disease.

Activity Professionals should also review current policies and procedures on infection control within their department. This needs to include the following:

  • Bingo cards and chips: If you use reusable bingo cards they should be properly disinfected after each use. Reusable bingo/poker chips should be washed properly after each use.
  • Cards and Games: Properly disinfected after each use.
  • Arts and Crafts supplies: Review and determine staff handling and proper infection precautions.
  • Cooking supplies: Use with caution, make sure all residents and you use gloves and wash hands as often as needed.
  • Manicures: Ensure residents hands are washed before starting. Ensure staff wash hands between each resident and wear gloves during the process. Ensure that files are single use.
  • Volunteers and Entertainers: If these individuals show any signs of illness, encourage them to stay home.

If there comes a time when your whole facility is quarantined, disposable activity program options are the way to go. Start now with making copies of trivia and puzzles and be prepared to dispose of paperback books and other items that cannot be properly sanitized.

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