CoP’s Continued…. Infection Control


Clean Hands Count

Historically, there have been very few studies concerning infection control and home Visits.  The work environment is the patient’s home and there is only so much we can do to control it.   We don’t have a housekeeping department to mop up our messes with industrial strength cleaning agents like hospital nurses.  We cannot fire other family members if they don’t wash their hands and what about those pets who jump on the bed after being outside?

One idea is to simply give up.  A better idea is to recognize that without a clean-up crew and a controlled environment, Infection Control is more important than ever.  And, since the new Conditions of Participation you must implement a program by mid January 2018,  the latter option might be best.

The condition is straight forward.  Here it is for reference.

The HHA must maintain and document an infection control program which has as its goal the prevention and control of infections and communicable diseases.

The reason Infection Control is getting an entire blog post to itself even though technically it is part of the QA Condition is because the Interpretive Guidelines list specific components that your surveyors will be assessing.  They include six components identified by the CDC as being relevant in the home.

  1. Hand Hygiene;
  2. Environmental Cleaning and Disinfection;
  3. Injection and Medication Safety;
  4. Appropriate Use of Personal Protective Equipment;
  5. Minimizing Potential Exposures; and
  6. Reprocessing of reusable medical equipment between each patient and when soiled.

Not only should your plan address all six of these issues, but they should be evident in practice.

Hand Hygiene

The Interpretive guidelines advise agencies that handwashing should occur:

  1. Before contact with a patient;
  2. Before performing an aseptic task (e.g., insertion of IV, preparing an injection, performing wound care);
  3. After contact with the patient or objects in the immediate vicinity of the patient;
  4. After contact with blood, body fluids or contaminated surfaces;
  5. Moving from a contaminated-body site to a clean body site during patient care; and
  6. After removal of personal protective equipment (PPE);

Alcohol based hand sanitizers are the most effective products for reducing the number of germs on the hands of healthcare providers most of the time. Antiseptic soaps and detergents are the next most effective and non-antimicrobial soaps are the least effective.  Bars of soap are so retro that they really don’t deserve much attention except that you might still find them in patient homes.

When hands are not visibly dirty, alcohol based hand sanitizers are the preferred method for hand hygiene. The agency must ensure that supplies necessary for adherence to hand hygiene are provided.  However, be careful if you have a patient diagnosed with Clostridium Difficile as hand sanitizers are not effective.  Gloves must be worn.

Environmental Cleaning and Disinfecting

The interpretive guidelines recognize that you have little control over the tidiness and disinfection in another person’s home.  However, they do state that the home health personnel ‘must maintain their equipment and supplies clean, during the home visit, during transport of reusable patient care items in a carrying case in the staff vehicle and for use of the items in multiple patients’ homes.’  Thus, your primary focus is on your supplies and equipment.

Safe Injection Practices

Safe injection practices include:

  1. Use aseptic technique when preparing and administering medications;
  2. Do not reuse needles, lancets, or syringes for more than one use on one patient; Use single-dose vials for parenteral medications whenever possible;
  3. Do not administer medications from a single-dose vial or ampule to multiple patients;
  4. Use fluid infusion and administration sets (i.e intravenous bags, tubing and connectors) for one patient only and dispose appropriately after use;
  5. Consider a syringe or needle/cannula contaminated once it has been used to enter or connect to patient’s intravenous infusion bag or administration set;
  6. Enter medication containers with a new needle and a new syringe even when obtaining additional doses for the same patient;
  7. Insulin pens must be dedicated for a single patient and never shared even if the needle is changed;
  8. Sharps disposal should be in compliance with applicable state and local laws and regulations.

Since none of you would dream of reusing or sharing equipment, your attention is needed at number 8.  Know your state and local laws and regulations about disposal of sharps.  Frankly, it is a little insulting that someone thought they had to tell home health nurses that they shouldn’t use insulin pens or IV sets on more than one patient.

Appropriate Use of PPE

This refers to the gear used as a barrier against infection.  The idea is that any contaminants thrown your way will hit your PPE and be disposed of as you leave the patient room.  Examples include gloves, gowns, masks, and eye protection depending on the nature of the potential threat.

Although it is not clearly spelled out, it is in inherent in any regulation about PPE that the staff understand how to use it.  It is not as easy as it looks and taking it off is even more difficult.  Do you remember the nurse, Nina Pham who contracted Ebola in a Dallas Hospital?   She might tell you to take every advantage to learn about PPE.

Minimizing Potential Exposures

This focuses on the protection of the family members, other caregivers and visitors and the transmission of pathogens while transporting specimens and medical waste such as sharps.  There isn’t much written on it in the interpretive guidelines or Conditions of Participation probably because each patient and family are in a different situation.  Nobody catches arthritis by breathing the same air as a patient but patients with contagious diseases need to be assessed and plan put into place that is specific to the nature of the patient’s contagious condition.

Reprocessing (cleaning and disinfecting) of Reusable Medical Equipment is essential.

Reusable medical equipment (e.g., glucose meters, INR machines and other devices such as, blood pressure cuffs, oximeter probes) must be cleaned/disinfected prior to use on another patient and when soiled. The HHA must ensure that staff are trained to:

  • Maintain separation between clean and soiled equipment to prevent cross contamination; and
  • To follow the manufacturer’s instructions for use and current standards of practice for patient care equipment transport, storage, and cleaning/disinfecting.

There must be documentation that the staff has been trained.  To minimize the resources spent on training, an agency might limit the purchase of machines such as INRs and blood glucose machines to one or two brands so the instructions don’t change.  If, like many agencies, you opt to use the patient’s equipment whenever possible, be sure that patients know how to use and maintain their equipment.

The next standard is:

The HHA must maintain a coordinated agency-wide program for the surveillance, identification, prevention, control, and investigation of infectious and communicable diseases that is an integral part of the HHA’s quality assessment and performance improvement (QAPI) program. The infection control program must include:

Surveillance

According the Interpretative guidelines, The HHA infection control program should ‘use observation and evaluation of services from all disciplines to identify sources or causative factors of infection, track patterns and trends of infections, establish a corrective plan, and monitor effectiveness of the corrective plan.’

In other words, you should task all disciplines with looking for infections, their underlying cause and any trends.  A plan should be established to address any trends or patterns and the agency will monitor effectiveness.

The Interpretative Guidelines suggest the following activities be used in your surveillance:

  • Clinical record review;
  • Staff reporting procedures;
  • Review of laboratory results;
  • Data analysis for physician and emergency room visits for symptoms of infection; and
  • Identification of root cause of infection through evaluation of HHA personnel technique and selfcare technique by patients or caregivers.

More specifically, we suggest:

  • New orders for antibiotics
  • Hospitalizations for suspected infection
  • Deteriorating wounds
  • Fever – most computer systems have a trendline for temperature over time. Look for spikes.

If you have any other suggestions, please share them.

Now that you know who has been infected, an analysis should occur.  The easiest way to do this is to enter your numbers on a spreadsheet and then make a graph out of them.  If you are not friends with MS Excel, you can do the same thing manually.  Depending on the type of graph, you may see spikes, clusters or other indicators that ‘one of these things is not like the other’.

Put a plan into place that will address any variations in data or infections that might have arisen from your care or have been prevented by your care.  Instead of asking what your agency did wrong, consider what could have been done better.

Write down the steps that are needed to address any areas that could be approved.  Assign them to appropriate staff.  The agency does not have to break new ground in the science of infection control.  The tools and knowledge are there.  Use them.

Monitoring results is the missing step in many infection control programs.  When you write your plan that includes specific activities, include the frequency and method of monitoring results.  This will allow the agency to rapidly respond to any increase in infections that occur despite your well executed plan.  This is not failure, by the way.  Recognizing that a plan isn’t working and calling an impromptu meeting to make changes before your regular meetings is how good Infection Control Programs are managed.

When positive results are noted, they should be shared.  You have asked your nurses to participate in your Infection Control Program.  Let them know when their hard work has netted results.

The last standard in Infection Control concerns training and education.

The HHA must provide infection control education to staff, patients, and caregiver(s).

The interpretive guidelines are clear on what is expected:

HHA staff education should include as a minimum:

  • Appropriate use, transport, storage, and cleaning methods of patient care equipment according to manufacturer’s guidelines and receive the following provide the following for staff education:
  • Job-specific, infection prevention education and training to all healthcare personnel for all of their respective tasks;
  • Processes to ensure that all healthcare personnel understand and are competent to adhere to infection prevention requirements as they perform their roles and responsibilities;
  • Written infection prevention policies and procedures that are widely available, current, and based on current standards of practice;
  • Training before individuals are allowed to perform their duties and periodic refresher training as designated by HHA policy;
  • Additional training in response to recognized lapses in adherence and to address newly recognized infection transmission threats (e.g., introduction of new equipment or procedures);
  • Provide in-service infection control education for staff at periodic intervals (minimally annually) consistent with accepted standards of practice, such as: at orientation, annually, and as needed to meet the staffs learning needs to provide adequate care, identify infection signs and symptoms, identify routes of infection transmission, appropriately disinfect/sanitize/transport equipment and devices used for the patient’s care, medical waste disposal, including instructions on how to implement current infection prevention/treatment practices in the home setting.

It might be that Medicare is serious about Infection Control.  What do you think?

There is a plethora of tools on the internet to help with Infection Control.  As time allows, we will post links to some of them.  Many agencies have Infection Control programs that are outdated or not implemented and some of them are frankly too confusing to follow.   Simplify instead of complicate what is in place.  Put your real efforts into preventing and monitoring infections and let your computer do the data collection.

One approach that has a 100 percent chance of failure is writing or buying a pretty binder and keeping on the shelf between surveys.  The plan should be available and have clear instructions for anyone with a question.  The number of pages your plan has irrelevant.  The effectiveness of the program is where you should focus your efforts.

If you need any help designing and implementing an infection control program or any or all of the Conditions of Participation, you know who to contact.  We’re ready and willing to help.

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Nina Pham


 

The CDC, among others, have suggested that perhaps more training is needed to ensure that direct health care workers are properly using protective equipment.   According to that line of thought, poor Nina Pham simply did not know what she was doing when she picked up a touch of Ebola from her patient.  If only she had more education on how to put on gloves and a gown, this whole disaster could have been avoided.

I think not.

I posted my dismay regarding re-educating nurses on FaceBook and was amazed at how smart my friends are.

One non-nurse, Michelle said that education was a way to protect the facility.  In other words, when a policy is violated, the hospital is able to assure any surveyor or lawyer that they did, indeed, provide the education and training and have therefore met their responsibility.  Sadly, a successful healthcare facility (and by successful, I mean isn’t closed down) must cover all bases to minimize damages.  I would probably waste time and resources re-teaching PPE, too if I had to make the decisions.

She also pointed out that maybe protocols are not strictly enforced when the risks are lower which could lead to bad habits.  I agree.  Ever notice how MRSA is already a problem when we start monitoring hand hygiene?  (I love that.  Hand hygiene – soon there will be an aisle in the supermarket for hand hygiene products instead of soap, antibacterial gel and hand lotion.)

Lisa Selman Holman pointed out how very miserable PPE is to wear.  She is right.  It is hot and sticky, nothing fits right and it is ugly in the most unforgiving way.  I have yet to figure out how looking like Big Bird assists in the infection control process. Healthcare workers, especially those with a fashion sense, can’t wait to take it off.

If ever there was a time to spend money, this would be it.  Athletic clothing manufacturers have done amazing things with sports gear.  It seems like a clothing manufacturer who exists because they make comfortable, functional clothes that can wick away perspiration, kill enough germs to smell good and keep a body warm in water might be able to help design something comfortable, disease proof, easily taken on and off  with the assistance of an infection control specialist.

Sara Kawaguchi came up with the idea of having two people involved – one present simply to observe.  I love this idea and it is cheap to do when considering the stakes.  Having never met Miss Pham, I can only assume that she didn’t tear a glove, look at it and say, ‘Oh darn,’ and carry on with restarting an infiltrated IV line.   If she breached protocol, it was likely unnoticed by her.

My cousin, Steve, is a physician and his response was simple.

1) we are human
2) we make mistakes
3 there is no room for a mistake here, in flight or in surgery

There’s a lot of truth in that but we can minimize mistakes.  Even the world famous Quality Assurance plan designed by Toyota, Six Sigma refers to only six errors in a million.  When it comes to Ebola, nobody wants to be one of the six.

The Checklist Manifesto by Atul Gawande is written by a surgeon who almost killed a patient because he forgot to do something very simple and standard prior to surgery – type and match blood.  After this near catastrophe that left his confidence shaken, he set about researching how to prevent errors.  It turned out that aviation history was marred by the crash of the first B17 in which several people died.  It almost took Boeing aircraft out of the game completely.  The solution included a checklist which enabled the (highly skilled and trained pilots) to fly 12 planes a total of 1.8M miles without incident.  It is now used universally.

Checklists are not designed to educate anyone.  If you have ever turned in visit notes only to find out that you forgot to write a narrative because you were interrupted, you are prone to human error.  If you have ever been called about a bill you know you paid only to find the stamped envelope in your purse, you could have used a checklist.  They are designed to let you pick up where you left off in the event something slips your mind, you are preoccupied or there is chaos all around you.  They ground and center the user.

There are undoubtedly numerous approaches to improving the safety of healthcare workers but re-educating the staff in a critical care unit on how to put on and take off PPE is an intervention for the hospital – not the nurses.  Don’t tell me that the staff in an intensive care unit requires more schoolin’ to put on gowns, masks and gloves.  Make them more comfortable so they aren’t urgently ripped off like they were on fire the minute you clear the room.  Have someone else watch.  Use a check list.  Doing more of what was done in the past because it didn’t work doesn’t quite make sense to me.

What the healthcare staff needs the most is a cure for Ebola.  When it comes to caring for a patient with Ebola, especially at the end of life, perhaps the most important changes will come about from the staff who were actually there doing the job.  If the blame game stops and the focus is directed to increased protection of healthcare workers, why not consult that handful of clinicians who are the only ones in the United States to have cared for Ebola patients in US hospitals?

I know that you join The Coders in wishing Godspeed to Nina Pham’s recovery.  She was able to be there for a patient isolated from his family and friends when he needed them the most.  People like Nina Pham do not put their own lives on the line for a paycheck.  She has a calling and I pray she will be back at work sooner than later.

Also,  let’s not forget that Nina Pham is not alone.  A few dozen other healthcare workers who took the same risk as Nina Pham and so far, have been free of symptoms.  These include the staff in Dallas as well as Nebraska and GA where two other Ebola patients have been treated.  They are no less heroic because they have not contracted Ebola; they just haven’t made the news and I hope they don’t any time soon.