Navigating The New Rule: Infection Prevention and Control Program

Dr. Andy Kramer
Provider Magazine – April 2017

The addition of the word “prevention” into the previous regulation for a nursing center’s infection control program signals an important evolution in the regulations aimed at the new challenges nursing centers face in reducing morbidity and mortality from infection.

These new requirements, recently outlined by the Centers for Medicare & Medicaid Services in the revised appendix PP of the SOM for regulation 483.80, are the topic of this second installment in the series.

This emphasis on prevention has come about in all health care settings because of the challenges we face in effectively treating many acute infections, and controlling transmission of communicable diseases. Two challenges make this harder to achieve today in nursing centers.

First, infections in today’s health care institutions are increasingly caused by organisms that are resistant to standard antibiotic therapy (MRSA, for example). Second, in today’s nursing centers, we care for frailer elders who are at greater risk for infection in many cases, and when they have a severe infectious disease, they are less able to overcome the sustained physiological consequences.

Thus, it is not surprising that recently published work has shown that sepsis is the major cause of hospital admissions for elderly nursing center residents and hospital discharges, and is associated with high mortality rates.

The Centers for Disease Control and Prevention (CDC) has been focused on this challenge in recent years, with numerous publications, tools, and pathways related to prevention and antibiotic stewardship in all health care settings.

‘The current updates represent a more aggressive approach to infection.’

While regulations for nursing centers have always addressed these topics, the current updates represent a more aggressive and proactive approach to infection. For example, new regulations are provided about the need for a surveillance system designed to both report and minimize spread of communicable disease, alcohol-based hand rub and handwashing policies, and other standard and transmission-based precautions.

In addition, policies are required on restricting employees with a communicable disease or infected lesions from direct contact with residents or food, and documenting how such risk to residents is minimized.

CDC also highlights the importance of restrictions on visitors with potentially communicable diseases.

Influenza and pneumococcal vaccination are also highlighted in the new regulations. The regulation includes education of residents and their representatives about the benefits and risks of vaccination. At the same time, the regulation acknowledges resident or resident representative choice, as well as situations when immunizations are contraindicated, and includes a requirement for documentation of vaccinations given or refused.

According to CDC, studies have found that less than 50 percent of health care workers and organizations consistently meet the known best-practice guidelines. This is consistent with a point I made in a last year’s column: F441, Infection Control, was the most frequently cited F tag in close to 50 percent of surveys.

While the fully developed infection prevention and control program, along with antibiotic stewardship regulations, are included in Phase 2 of the new rule, starting now to ensure you are developing and implementing the compliant and effective policies and procedures will ensure you are on track.