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Regulatory Boot Camp: Infection Prevention
May 14, 2013
Jean Day, BSN, RN, CNOR
Director of Clinical Education
Infection Prevention Resources CMS - Revised Infection Control Surveyor Checklist
2012 www.cms.gov/sitevisit
CDC - Infection Prevention Checklist for Outpatient Settings www.cdc.gov/hai/settings/outpatient/checklist
ASGE - 2011 Multi-Society guidelines for reprocessing flexible gastrointestinal endoscopes http://cdc.gov.hicpac/disinfection_sterilization
CDC - 2013 NHSN Procedure Associated Events, SSIhttp://www.cdc.gov/nhsn/pdfs/pscmanual/9pscssicurrent.pdf
Objectives:
Identify common infection prevention deficiencies identified during survey conditions.
List best practices for the prevention of healthcare acquired infections.
Recognize 2013 changes to infection prevention accreditation standards.
Provide associated regulatory standards to achieve compliance of infection prevention practices.
Formal IP Plan IC.01.05.01 (RWD)
CH.7.SubCH.1.B (RWD)
CMS.416.51Approved by Governing Board – meeting minutes
Designated IPRN approved by Governing Board
IPRN accounts for time to conduct IP activities
IPRN demonstrates evidence of ongoing training & competence in IP practices
IPRN given authority to enforce IP policies
Infection Risk Analysis
IC.01.03.01 (RWD)
CH.7.SubCH.1.B.5 (RWD)
CMS.416.51.(b)(3)24% deficiency rating by TJC (YTD)24% deficiency rating by TJC (YTD)
Annual or when significant changes occur - New service: adding spine, total joint, pain management
Change in EVS contractor
Outbreak
Based on scope of services, geographic location & population served.
Clearly Stated Goals IC.01.04.01 (RWD)
CH.7.SubCH.1.C
CMS 416.51.(a)P&P represent nationally recognized practice
standardsstandards.
P&P make reference to practice standards the organization chooses to follow: AAMI CDC
AORN HICPAC
APIC SGNA
ASGE WHO
Clearly Stated Goals
HR.01.04.01 (RWD)Organization orients staff to key infection control
content before staff provides care, treatment or services.
CH.5.SubCH.2.D (new)
CH.7.1.F.1 (RWD)Infection control policies & processes are provided
to all staff within 30 days of commencement of employment; annually thereafter, or when need identified.
RISK ANALYSIS FOR INFECTIONS 2013
InfectionPrevention
PROBABILITY RISK CAUSE of transmission
Center Preparedness GOAL
HIGH – 3 MED – 2 LOW – 1 NONE – 0
See Below See Below Poor – 3 Fair – 2 Good - 1
See Below
SURGICAL SITE INFECTIONS
2 1 2,3 1 1,2,3,4,5,6,7,8,910, 11,13,14
MRSA (Community)MDRO
1 3 2,3,4 2 1,9,10,11,13
PANDEMIC FLU
1 5,4,3 4 1 1,6,9,10,11,12
Health Care Acquired (HAI) INFECTIONS CAUTI, C. Difficile
1 1 2 1 1,4,8,9,10,11,12
TB 1 1 4 2 1,10,11,13 Upper Respiratory (bacterial or viral)
2 1 1 1 1,6,9,11
Hepatitis B (HCW) 2 1 2 1 1,9,11,12,13,14 Other
RISK: 5 – Life Threatening 4 – Community Health Safety 3 – High Disruption to Business 2 – Moderate Disruption to Business 1 – Low Disruption to Business
Risk: 5 – Life Threatening 4 – Community Health Safety 3 – High disruption to business 2 – Moderate disruption to business 1 – low disruption to business
Cause of Transmission: 4 – Communicable, pre-existing 3 – Resistant organism, acquired 2 – Break in Sterile techniques, Quality Controls, direct contact 1 – Acute onset, diagnosed at time of admission
GOALS: Protect Patient from infection by:1. Consistent practice of hand hygiene. 2. Administering prophylactic antibiotics within 60 minutes of anticipated “cut” time. 3. Preparing surgical site by skin preparation & use of sterile barriers. 4. Maintaining sterile technique for invasive procedures. 5. Maintaining thermoregulation. 6. Cancelling patients showing signs & symptoms of acute illness. 7. Providing instruction and necessary supplies for wound management at home. 8. Applying best practices in reprocessing & sterilization of instruments. 9. Maintaining cleanliness in the environment using appropriate disinfectants. 10. Cancellation of patients with known communicable diseases until resolved. 11. Protect HCW, patients & visitors from infection by requiring compliance to infection
prevention practices. 12. Protect HCW from communicable diseases by providing vaccinations. 13. Protect HCW from exposure to BBP by providing PPE and evaluating protective sharp
medical devices. 14. Accomplish the above in a cost effective manner to the business.
GOALS: Protect patient from infection by –
1. Consistent practice of hand hygiene.2. Administering prophylactic antibiotics within 60 minutes of anticipated
“cut” time.3. Preparing surgical site by skin preparation & use of sterile barriers.4. Maintaining sterile technique for invasive procedures.5. Maintaining thermo regulation.6. Providing instruction and necessary supplies for wound management
at home.7. Applying best practices in reprocessing & sterilization of instruments.8. Maintaining cleanliness in the environment using appropriate
disinfectants.9. Cancellation of patients with known communicable diseases until
resolved.10. Protect HCW, patients & visitors from infection by requiring
compliance to infection prevention practices.11. Protect HCW from communicable diseases by providing
vaccinations.12. Protect HCW from exposure to BBP by providing PPE and evaluating
protective sharp medical devices.13. Accomplish the above in a cost effective manner to the business.
Surveillance - continuous
Hand Hygiene ComplianceNPSG.07.01.01
CH.7.SubCH.1.C.1
CMS 416.44(b)(5)22% deficiency rating by TJC (2011)
6% d fi i i b TJC (fi h lf ) 16% deficiency rating by TJC (first half 2012)
Top 10 list of AAAHC
Business must adopt CDC or WHO guidelines
Evidence of corrective action leading to improvement
Observing HCW for artificial nails and natural nail length
Soap & H2O NOT ABHR for C. Difficele exposure
Hand Hygiene will be performed:Before coming on duty.
Before and after each patient contact and between different types of care on the same patient.
Before and after donning or removing gloves or other personal protective equipment.
Any time there is a probability of contact with blood or other potentially infectious materialsother potentially infectious materials.
Before and after invasive procedures.
Before and after using the restrooms.
Before and after eating.
After using the computer or PDA.
At the end of shift.
• Based on CDC Guidelines
Why so much resistance?
Male physicians WORST for hand hygiene compliance.
Hand hygiene surveillance demonstrates 50% compliance to CDC guidelines.
Clearly the best defense known for the prevention of transmission of micro-organisms.
ABHR = >60% alcohol concentration to be effective. (exception – soap & H20 for C. Diff)
Universal Precautions
IC.02.01.01 (2) Use of PPE to reduce risk.
CH.3.C.1-3
CMS 416.51(b)(3) & 416.41HCW failure to use PPE appropriate to task or HCW failure to use PPE appropriate to task or
anticipated exposure.
HCW failure to report exposure incident.
Business failure to provide follow up care after exposure incident.
OSHA Violations “OSHA Surveys are coming”– triggered by
complaints.
Most common deficiencies cited during survey: Non-existent or outdated Exposure Plan.
Business failure to provide annual training:Business failure to provide annual training: Prevent exposure to BBP or OPIM.
Business failure to include risk of exposure within job description.
Employee failure to use PPE appropriate to task.
Employee failure to keep QC checks as verification of processes & conditions.
Protecting the HCW from illness
Organization policy to provide flu vaccination?
State mandatory flu vaccination program?Mask required with symptoms?
Presentee-ism – IPRN given authority to send ill g yHCW home?
Monitor HCW illness rate?
Hepatitis B vaccination – provided by employerMonitor HCW exposure incident rate?
OSHA 300 – annual reporting?
Manage Point of Care DevicesManufacturer’s IFU cleaning instructions
Manufacturer’s current product insert, especially if reagent is used
Manufactured as single or multi-use
Manage Point of Care devices IC.02.02.01
CH.7.SubCH.1.M26% deficiency rating by TJC (first half 2012)
31% deficiency rating by TJC (YTD)
b ( )CH.7.SubCH.1.N (new)Manufacturer’s IFU cleaning instructions.
HCW demonstrates competency in decontamination of device using IFU or best practice.
HCW knowledgeable of dwell time requirement of surface wipes in use.
Which product do I
use ?
How much contact time is
needed ?Evidence of Reality
Safe Medication Administration
• CMS 416.48(a)CDC
recommendations: Single dose vials? Multi dose vials?
MDVSDV
Multi-dose vials?
One needle, one syringe,
one use!Drug, dose, time, initials
Safe Medication Administration
MM.06.01.01
CH.7.SubCH.1.C.2CH.11.I
CMS 416.48(a)CMS 416.48(a)CDC
recommendations:
IV spike < 60” before use
IV ports covered, ETOH wiped before use
Sharps Injury Prevention
E t h 2/3 f ll
IC.02.01.01 CH.7.SubCH.I.F (RWD)18% deficiency rating by TJC (YTD)Annual evaluation of safer devicesPuncture proof Empty when 2/3 fullPuncture proof
containersNeutral Zone
Improper surgical attireOther breaches contributing to infection
Contamination of sterile field
What is acceptable OR attire?
Freshly laundered scrub attire.
No home laundered scrubs!
Compliance to Healthcare Laundry Accreditation Council guidelines for healthcare textiles.g
Long sleeves for circulator.
Warm up jackets – high performance textiles.
Designer caps (covered or freshly laundered).
White doctor coats (remains open for debate).
Personal digital assistants
Ubiquitous
Source of distraction
Patient privacy
M f t IFU dManufacturer IFU does not include how to sanitize
Hand hygiene best practice documented
Cleanliness of EOC
LD.04.03.09 - Evaluation of contracted service –annual.
CH.7.SubCH.1.A, D, G
CMS 416.44(a)(3)( )( )Satisfaction with level of performance?
Verified competency of EVS personnel?
Agreement delineates who cleans what?
Laundry service applies Healthcare Laundry Accreditation Council standards
How clean is clean?Housekeeping is contracted serviceHigh turnover rate of human resources?
Verified HR competency & knowledge?
Correct cleaning agent for the level of sanitation or di i f ti ?disinfection?
FDA approved cleaning products?
Demonstrate best practice & cleaning materials?
Frequency of cleaning?
Clarity of who is cleaning what?
Random surveillance for microorganism kill?
Instrument Reprocessing IC.02.02.01
CH.7.SubCH.1.E, J, K (RWD)
CMS 416.44(a)(3)28% deficiency rating by TJC
Top 10 list of AAAHC
AAMI ST79:A1:2010 & A2:2011
AORN 2013 Sterilization RP
Spaulding Classification
Equipment Operating Manuals
Manufacturer’s Instruction for Use
Personnel CompetencyHR.01.06.01 Competency assessed q 3 yrs.
CH.4.A & CH.3.B.5
Demonstrate understanding of quality control measures performed, when & why.Ability to respond to surveyor questions with
confidence!
Ability to describe quality control measures and results contained within QC log books.
Ability to locate equipment manuals.
Ability to discuss routine PM& Repair schedules.
Instrument Storage
CH.7.SubCH.1.L (new)30 - 60% humidity
62 - 75° F
Impervious lower shelf 8 -10” above floor, 18” from pnearest sprinkler, 2” away from wall
Event related shelf life
AORN 2013 Sterilization RP
Class 5 Integrator
Immediate Use Steam Sterilization
Impervious8 – 10”
Immediate Use Steam Sterilization
AAMI, AORN, CDC do not recommend except when no other option is available.
Not an option for insufficient inventory.
IUSS instruments – shortest duration between sterilization & use.
Transport to OR in closed container
Keep IUSS log – requesting capital needs.
Track instruments to individual patient.
Sterilization Assurance
Quality Controls:Repeatable SOPs
Manufacturer’s IFU
B i Di k f d d dBowie Dick – performed, recorded
Daily Biological Indicator
QC documentation maintained & current
Confidence of sterility
CONTROL
CONTROL
Sterile or Not Sterile?
LOT CONTROL NUMBER
Failure to adhere to established reprocessing guidelines (repeatable steps) accounts for most if not all accounts for most, if not all, of reportable bacterial & viral transmissions.
- American Society for Gastrointestinal Endoscopy
CLEANING = removing visible soil & foreign matter at bedside.
DECONTAMINATION =
Removing or reducing infectious organisms.
TWO most critical steps in preventing transmission of bacterial & viral contaminants.
Rapicide Test Strip
Quality Control Log is complete & current
Surveillance Activities
IC.01.05.01 (RWD)
CH.7.SubCH.1.I
CMS416.51(b)(3)Surveillance conducted on regular basis
Evidence investigation conducted – RCA or PI studies
Use of surveillance checklists SSI surveillance
Hand Hygiene
Environment of Care
Chart Audit
Surveillance Surgical Site Infection
NPSG.07.05.01 & IC.01.04.01 (RWD)
CH.7.SubCH.1.I
CMS 416.51SSI = Unexpected Outcome (CMS considers SSI
as preventable)
Deep Incision SSI surveillance – Time sensitive (30 day + 90 day when implant involved) Ongoing
Investigation
Data collection
Reporting
Patient Chart # 03478 03321 03452 03433 03382 03405
Prophylactic antibiotic IV administered < 60" of incision timeMethod of hair removal, time & person
Blood glucose within normal range pre-operatively (if applicable)Skin prep solution used, location & person
Normothermia (>96.8) maintained intraoperatively and up to 15" afterintraoperatively and up to 15 after anesthesia endPsO2 > 90% intraoperative
PsO2 > 90% initial reading in PACU
Blood glucose, 200 mg/dl in PACU (if applicable)Evidence of wound care instructions & supplies provided at time of discharge
Frequency Action Jan Feb Mar
Weekly Provide new hire orientation to Infection Prevention Policies (upon request)Weekly/ Monthly
Run Infection Surveillance report by surgeon from PAS allowing > 30 day lapse from DOS
MonthlyRun Infection Surveillance report by surgeon using implant report naming patients identified for DOS with 90 day interval.
Monthly Send surgeon surveillance form(s) > 30 day or > 90 day
Monthly Conduct investigation of reported SSI: contact surgeon, patient, hospital
Monthly Enter SSI in Action Cue reporting system
Monthly Obtain Employee Illness report from HR Coordinator
IPRN Concurrent Checklist - Example
Monthly Conduct follow up from reported employee illness , or exposure incident
MonthlyConduct Hand Hygiene surveillance in one specialty area (HH & glove use surveillance)
MonthlyConduct Universal Precautions surveillance in one specialty area (IP & Safety Surveillance)
Monthly Conduct chart review for infection prevention initiatives (Chart Audit)
Monthly Read current periodical, select one article for staff education
Quarterly Review infection rate reported from Action Cue reporting system
Quarterly Review employee illness/exposure incident rate from Action Cue report system
Quarterly Conduct staff education of selected topic, IP PI, other
Questions?Jean Day, RN / Director of Clinical Education
719-256-5831
jday@pinnacleiii [email protected]
www.pinnacleiii.com
References:
• AAAHC; Ambulatory Handbook, 2013
• AAMI ST-79;A1:2010 Comprehensive Guide to Steam Sterilization & Sterility Assurance in Healthcare Settings
• AORN; 2013 Perioperative Standards & Recommended Practices
• AJIC; November 2011, Rethinking hand hygiene improvement
b h bl• AJIC; September 2011, Nursing & physician attire as possible source of nosocomial infections
• CDC; Jan.2013, NHSN – Procedure Associated Events SSI
• CMS; Conditions for Coverage, 2009
• FDA; 2011, Processing/Reprocessing Medical Devices in Healthcare
• Outpatient Surgery Magazine; May 2012, Manager’s Guide to Infection Control
• TJC; CAMAC, 2012