INFECTION CONTROL PLAN- MAINTAINING COMPLIANCE WITH THE INFECTION CONTROL AND PREVENTION STANDARDS AND REGULATIONS: CMS CfC 416.51 Lee Anne Blackwell, RN, BSN, EMBA, CNOR Vice President Clinical Services Practice Partners in Healthcare, Inc. 1
OBJECTIVES MAINTAINING COMPLIANCE WITH IC PLAN 1.Describe components of an InfecIon Control (IC) Plan. 2. Examine internal and external reporing requirements for the ambulatory surgery center related to your IC plan 3. Discuss responsibiliies of an IC Nurse PrevenIonist (ICP). 4. IdenIfy top infecion control focus areas during regulatory and accreditaion surveys. 5. Implement ONE new idea and acion to support your center s InfecIon Control Plan! 2
CMS CfC 416.51: Infec'on Control in 2 standards: Sanitary environment (416.51 a) Infec'on control program (416.51 b)- The infec2on control and preven2on program must include documenta2on that the ASC has considered, selected, and implemented na2onally recognized infec2on control guidelines. and The IC program must be under the direc2on of a designated and qualified professional who has training in infec2on control 3
OBJECTIVE ONE: Describe Components of an Infec'on Control (IC) Plan 4
The IC Plan must contain the following: 1. A purpose statement idenifying plan based on guidelines from leading authoriies in IC 2. IdenIficaIon of IC Plan role, responsibility, support, and oversight by organizaion management, GB (& MEC) 3. An authority statement who is in charge of the IC Plan 4. Plan goals 5. Plan scope 6. InvesIgaIon and surveillance processes 7. IdenIfied risks and risk assessment processes 8. IdenIfied strategies to miigate risks 9. EducaIon plan for ICP and staff (including MED /AHP staff) 10. ReporIng processes 5
1. A purpose statement iden'fying plan based on guidelines and best recommended prac'ces from leading authori'es in IC: Centers for Disease Control and PrevenIon (CDC) Assoc for Professionals in InfecIon Control and Epidemiology (APIC) Society for Healthcare Epidemiology of America (SHEA) AssociaIon of PeriOperaIve Registered Nurses (AORN) Society of Gastroenterology Nurses and Associates, Inc. (SGNA) OccupaIonal Safety and Health AdministraIon (OSHA) NaIonal InsItute for OccupaIonal Safety and Health (NIOSH) American InsItute of Architects (AIA) Assoc for the Advancement of Medical InstrumentaIon (AAMI) InternaIonal Assoc of Healthcare Central Service Materiel Management (IAHCSMM) AccreditaIon Agencies (TJC, AAAHC, AAAAF, etc.) 6
2. The IC Plan must iden'fy the organiza'on s role, responsibility, support, and oversight by management, GB/MEC. The IC plan must be developed by center Leadership and clinical IC designee The InfecIon Control Plan must be approved by MEC/GB Leadership must be commiked and supporive Leadership must acively paricipate in all efforts to control infecion Leadership must support IC best pracices, idenificaion of expert resources, and encourage coninuous improvement according to the foundaion of the PI program 7
3. The IC Plan must include an AUTHORITY statement (FACILITY NAME) Infection Control Professional Competency and Authority Statement The infection control professional will be responsible to demonstrate competency through interest in the field, formal and informal training, and through appropriate experience required for the position as described in the job description. The infection control professional will be responsible to abide by the Infection Control Policies and Procedures and related infection control competencies of (FACILITY NAME). AUTHORITY STATEMENT NAME OF INFECTION CONTROL NURSE For: (FACILITY NAME) The Governing Body of (FACILITY NAME) and the Medical Director hereby delegates authority to the infection control professional to act on all matters regarding infection control; to carry out the functions of the Infection Control Program, and institute any appropriate control measures or studies when there is reasonably considerable danger to any patient or persons. Chair, Medical Executive Committee/ Medical Director/Chief of Medical Staff Administrator / Nurse Manager Date Date 8
4. The IC Plan must have iden'fied goals that: Flow from overall philosophy, mission and vision of organizaion Allow flexibility room to alter plan in response to unexpected disease processes or environmental issues Support IC Plan review regularly, at least annually, for necessary changes Support the IC Plan to be communicated to everyone in the organizaion responsible to paricipate in the plan Focus on strategies for reducing infecion risks 9
5. The IC Plan must have a defined SCOPE (the who, the what, and the how ) that: WHO: IdenIfies populaion to be served WHO: IdenIfies all healthcare workers who will paricipate in the ASC s IC Plan WHAT: IdenIfies what indicators or metrics will be measured to idenify paient safety opportuniies for improvement- QAPI; (hand hygiene compliance, ABX admin Iming, Influenza vaccine rates, surgical preps, sterilizaion processes, terminal cleaning, management of surgical apre, etc.) HOW: IdenIfies how the infecion control service will be implemented for paients, staff, environment 10
6. Inves'ga'on and Surveillance Processes: Ensure a consistent process to retrieve infecion informaion: Physician lekers Verbal communicaion with physicians PaIent care follow- up assessments IniIate consistent infecion surveillance processes: PaIent outcomes - the value of any plan lies in the data collected regarding paient outcomes InfecIon data must be accurately collected Methods of surveillance for infecions and animicrobial resistant pathogens Trending log 11
7. The IC Plan must address risks and risk assessment measures. InfecIon Control Risk Assessments (ICRA); idenifying risks for acquiring and transmipng infecions PopulaIon served Facility locaion Community ICRA idenifies external factors: Community disease and infecion prevalence Community risks (conduct risk assessments) ICRA IdenIfies internal factors: Internal disease and infecion prevalence Internal risks (conduct risk assessments) 12
7. The IC Plan must address risks and risk assessment measures (con'nued) Ques'ons to consider for IC risk assessment: What type of paients do we serve? What are the most common diagnoses and paient co- morbidiies? What are most frequently performed surgical or invasive procedures? What type of paients increase liability and/or costs for the center? What type of health concerns exist in the community? Which paients are at increased risk for infecion? 13
7. The IC Plan must address risks and risk assessment measures (con(nued) Once risks are idenified: PrioriIze idenified risks Establish GOALS and OBJECTIVES for risk prevenion, miigaion IdenIfy strategies to miigate risks Target resources to help with risk miigaion strategies Agencies: CDC, OSHA, etc. Professional organizaions: APIC, AORN, AAMI, IAHCSMM, etc. 14
8. Iden'fied Strategies to Mi'gate Risks: Review paient processes of care and paient outcomes to idenify best pracice strategies for prevenion and control Implement processes to support internal and external infecion outbreak control Implement appropriate precauions: Standard PrecauIons Transmission- based precauions Blood- borne precauions Implement Hand Hygiene program with monitoring Implement educaion plan 15
8. Iden'fied Strategies to Mi'gate Risks (con'nued): The IC Plan must address CollaboraIon with Environment of Care- Safety Coordinator (OSHA training, sharps safety, employee safety risk assessments) CollaboraIon with Employee Health Nurse (Bloodborne Pathogens training, vaccinaion program, employee health awareness program) State, Federal, AccreditaIon Standards and Guidelines 16
8. Iden'fied Strategies to Mi'gate Risks (con'nued): The IC Plan must address policies and procedures for Employee health and safety Workplace safety educaion & training, for employees, contractors, medical staff & AHP, and paients PaIent screening, tesing Standard PrecauIons/Transmission- Based PrecauIons AsepIc, sterile technique in all areas Cleaning, disinfecion, high- level disinfecion, sterilizaion Environmental safety and condiions, traffic pakerns 17
9. Educa'on Plan for Employees, Medical Staff, Contractors, Vendors, Guests, Pa'ents: ASC InfecIon Control Plan and program Hand Hygiene Instrument and equipment processing personnel SterilizaIon and High- Level DisinfecIon (CerIficaIon gaining momentum and recogniion) InfecIous Waste Management communicaion and educaion of appropriate disposal techniques Personal ProtecIve Equipment Sharps Safety and Bloodborne Pathogens Standard PrecauIons/Transmission- based PrecauIons MedicaIon InfecIon Control Safety PracIces Sanitary Environment 18
(FACILITY NAME) MAINTAINING COMPLIANCE 9. IC NURSE SHOULD MAINTAIN DOCUMENTATION OF TRAINING (Example of Training LOG) Infection Control Coordinator TRAINING RECORD Infection Control Nurse: YEAR: PROGRAM NAME DATE 19
OBJECTIVE TWO: Examine internal and external repor'ng requirements for the ambulatory surgery center related to your IC plan (THE 10 TH ELEMENT of the IC Plan) 20
10. Repor'ng Processes: InfecIon data must be accurately reported CommunicaIng reportable diseases to public health authoriies (ENSURE POLICY IN PLACE!) CommunicaIng reportable diseases and events to ASC quality commikee, medical leadership RecommendaIons and acions based on infecion prevenion and control best pracices related to outcomes and trends Mandatory reporing requirements NHSN! 21
10. Repor'ng Processes: MANDATORY - NHSN! 22
10. Repor'ng Processes: MANDATORY- NHSN! http://www.qualityreportingcenter.com/asc/asc-status-listing-lookup-tools/ 23
10. Repor'ng Processes: MANDATORY- NHSN! 24
10. Repor'ng Processes: ASC 8- Influenza Vaccina'on Coverage among HCP Intent: assess the percentage of HCP immunized for influenza during the flu season Three categories of healthcare personnel will include: Employees on payroll Licensed independent praciioners- medical staff, allied health staff affiliated, credenialed Student/trainee and volunteers who do not get a paycheck Data collecion begins with immunizaions for flu season 10/1/2014 through 03/31/2015 Deadline for data reporing extended for 2014-2015 flu season from 03/15 to 08/15 and to 9/30/2015 25
10. Repor'ng Processes: Infec'on Control CLAIMS- BASED and WEB- BASED MEASURES InfecIon Control CLAIMS- based process measure to Ambulatory Surgery Center Quality ReporIng (ASCQR); Q- NET (for CY 2014 payment determina2on: ASC 5: Prophylac2c ABX 2ming InfecIon Control WEB- based process measure to NHSN for CY 2016 payment determina2on: ASC 8: Influenza vaccina2on coverage among healthcare personnel (HCP)- Due 9/30/2015 For more informaion on measures reporing, go to www.qualityreporingcenter.com; and hkp://www.cdc.gov/nhsn/ambulatory- surgery/index.html 26
WITH INFECTION CONTROL AND PREVENTION STANDARDS OBJECTIVE THREE: Discuss Responsibili'es of the Infec'on Control Nurse Preven'onist (ICNP or ICP) 27
The ICP MAINTAINING COMPLIANCE Is approved by the Governing Body (GB) DocumentaIon in ICP organizaion employee file Maintains documentaion of job descripion, competencies Is responsible for the facility IC Plan Provides educaion and training on IC plan, goals and objecives to staff Maintains documentaion of training, educaion and knowledge in infecion control Seeks guidance from leading authoriies in IC for ongoing educaion, training, IC Plan management including updates 28
The ICP connects with IC educa'onal resources to maintain current knowledge and trends, from leading authori'es such as: APIC: www.apic.org AORN: www.aorn.org CDC: www.cdc.gov OSHA: www.osha.gov NIOSH: www.niosh.gov SHEA: www.shea- online.org AAAHC: hkp://www.aaahc.org/en/ educaion/webinars/ SGNA: www.sgna.org IAHCSMM: www.iahcsmm.com AAMI: www.aami.org AIA: www.aia.org The Joint Commission: www.jointcommission.org There are PLENTY MORE of webbased resources available to the ICP! F 29
10. EDUCATION RESOURCES: Becker s Hospital Review- Original Producer/publisher of this content; http:// www.beckershospitalreview.com/quality/endoscopes-and-mdros-how-to-avoid-anoutbreak.html 30
http://solutions.3m.com/wps/portal/3m/en_us/ipd-na/3m-infection-prevention/education/ 31
InfecIon Control TODAY web- publicaion: hkp://www.infecioncontroltoday.com/ Medline University: https://www.medlineuniversity.com/ Olympus University: http://issuu.com/olympusamerica/docs/ olympus_university_brochure?e=0 32
The ICP MAINTAINING COMPLIANCE Conducts an ongoing & annual evaluaion of the IC Plan Encourages and directs collaboraion of medical staff and employees regarding IC Plan aciviies Conducts process of care and outcomes audits via MD lekers and paient postop call communicaion Performs risk assessments Completes invesigaions of reported infecions Reports plan and findings to facility medical leadership 33
IC plan surveillance process- IC Repor'ng sequence example: 1. InfecIon Report 2. InfecIon Log 3. Trending Report, monthly, quarterly, annual 4. SterilizaIon and HIGH Level DisinfecIon Compliance Report 5. IC Employee Exposure Risk Assessment 6. InfecIon Risk Assessment 7. ReporIng of Communicable Diseases to IdenIfied Health Authority 8. IC Monthly Audit (Grand Rounds) 9. IC compliance monitoring reports- Hand Hygiene, PI projects 10. Updates and changes to your IC Plan, including annual reviews. 34
IC plan inves'ga'on and surveillance process- steps when infec'ons are iden'fied: 1. Complete Infec'on Report: a. Review medical record b. Explore processes of care 1. PaIent assessment 2. H &P 3. SterilizaIon and high- level disinfecion records 4. Get culture report if at all possible! 2. Assess for Trends: staff, room, procedure type, MD 3. Report findings to management, QC, MEC/GB for ac'ons 35
WITH INFECTION CONTROL AND PREVENTION STANDARDS OBJECTIVE FOUR: Iden'fy Top Infec'on Control Focus Areas During Regulatory and Accredita'on Surveys 36
HISTORY: Beginning 2009- accrediing bodies revised their guidelines to include the new CMS (Center for Medicare and Medicaid Services) CondiIons for Coverage. Both TJC and AAAHC completed pilots in ASC s to include CfC s and expanded the infecion control assessment using the CMS InfecIon Control Worksheet in the survey process. The CMS IC Worksheet is periodically updated and consistently used for accreditaion/regulatory surveys.; last updated June 2015 37
INFECTION CONTROL SURVEYOR WORKSHEET 2015 CMS IC Worksheet 2015: https://www.cms.gov/medicare/provider-enrollment-and-certification/ SurveyCertificationGenInfo/Downloads/Survey-and-Cert-Letter-15-43.pdf Also see on ASCA website to download the current worksheet at: http://www.ascassociation.org/viewdocument/?documentkey=ae5c22acc283-4a36-b548-06ce81f200a0 38
Top Infec'on Control Focus Areas: 1. Hand Hygiene / Personal Protec've Equipment (PPE) 2. Safe Injec'on prac'ces 5. (A.) Single- Use Devices, (B.) Steriliza'on, and (C.) High Level Disinfec'on 6. Environmental Cleaning Sanitary Workplace 9. Point of Care Devices HINT! This is STRAIGHT OFF THE CMS IC WORKSHEET! 39
Surveyors will look at the types of IC training for the ICP Acceptable training topics include but are not limited to: 1. Elements of the IC Plan 2. Role of the ICP 3. InfecIon Risk Factors (SSI, PaIent, Environment, HCW s) 4. Hand hygiene compliance 5. ImplemenIng and maintaining a sanitary work environment 6. Best pracices w/ sterilizaion processes, including flashing 7. Cleaning and disinfecion 8. AsepIc technique best pracices 9. Employee Health 10. InfecIon Control PaIent Screening and Assessment 40
OBJECTIVE FIVE: Implement at least ONE new idea and ac'on to support your center s Infec'on Control Plan and Survey Readiness! 41
Ac(on Items! 1. Review and communicate your IC plan, policies 2. Ensure your facility ICP has an authority statement, JD, and documented competencies in place 3. Implement clear and systemized invesigaion and surveillance processes 4. Complete your IC risk assessments and reports 5. IdenIfy & implement strategies to miigate infecion risks 6. Report your IC plan aciviies to your QC/MEC/GB 7. Educate your team members, medical staff, vendors 8. Develop, manage and direct IC policies and procedures 42
- RESOURCES CMS ASC Quality ReporIng Program Quality Measures SpecificaIons Manual, available at www.qualitynet.org Quality ReporIng center at www.qualityreporingcenter.com Ambulatory Surgical Center Quality Repor2ng Program Quality Measures Specifica2ons Manual 5.0 for measure informaion & specificaions for Medicare's ASC Quality ReporIng Program: hkp://qualitynet.org/dcs/contentserver? c=page&pagename=qnetpublic%2fpage %2FQnetTier2&cid=1228772475754 ASCs can contact the ASCQR Program Support Contractor (SC) with quesions regarding data or for technical support. Contact the ASCQR Program SC by email at oqrsupport@hsag.com or 43
- RESOURCES CDC s NaIonal Health and Safety Network (NHSN) website for 5 step enrollment: www.cdc.gov/nhsn/ambulatory- surgery/enroll.html NSHN facility administrator enrollment guide Need to complete the 5 step SET- UP hkp://www.cdc.gov/nhsn/ambulatory- surgery/setup.html BEFORE reporing ReporIng data to CDC s NHSN requires user authorizaion through Secure Access Management Services (SAMS) for access to NHSN: 44
WITH INFECTION CONTROL AND PREVENTION STANDARDS INFECTION CONTROL IS EVERYONE S RESPONSIBILITY! Lee Anne Blackwell, RN, VP Clinical Services PracIce Partners in Healthcare, Inc. Lblackwell@pracIcepartners.org 1-205- 824-6250, ext. 5005 45