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6 Tips for Building a Compliant Infection Prevention and Control Plan for Long-Term Care Facilities
Last week, I shared the new Centers for Medicare and Medicaid (CMS) requirements for long-term care facilities (LTCFs) that go into effect on Nov 28, 2019. All these changes can be overwhelming, so I’m offering six tips for building a robust infection prevention and control program (IPCP) in your LTCF:
- Educate yourself: Take the time to familiarize yourself with the regulatory requirements such as those from CMS and from state health codes. Infection Preventionists (IPs) should also be well-versed on accepted national standards or guidelines for infection control like those provided by the Centers for Disease Control and Prevention (CDC).
- Evaluate your current program: Evaluating your IPCP should include a gap analysis comparing your current program elements to what is required. Is anything missing from the program such as a designated IP, specific policies, or perhaps process surveillance data, which is essentially looking at staff compliance with Infection prevention and control (IPC) policies?
- Conduct a population assessment: Be sure to include demographic data that should include information on both the community and the facility populations.
Community information can be obtained from the U.S. Census Bureau or a local source such as the city website. Include basic demographic data such as population, persons per square mile, median age, percent of the population over the age of 65, racial composition, poverty level and community-associated infection risks.
It’s also important to consider the region of the country where the facility is located as this can impact infection risks. For example, states with high humidity may face mold issues that drier states do not. Also, consider that an inner city facility will likely face different issues than will a rural facility.
Once you have assessed the community dynamic, you are ready to gather the facility-specific information. This should include things such as facility type, number of beds, average daily census, staffing and services provided.
- Conduct the IPCP Evaluation: This would include assessing the occupational health program, healthcare-associated infection (HAI) rates, process surveillance data, employee and staff vaccination rates, status of the antibiotic stewardship program, approved disinfectants and policy status.
Other considerations include:
- What are the most common diagnoses of patients admitted to this facility?
- What are the infection control resources?
- What is their training?
- How many hours per week are IPs able to dedicate to infection control tasks?>
- Conduct an IPC Risk Assessment: The assessment will help in ranking the various infection risks as “high,” “medium,” or “low,” which will enable the IP to prioritize their activities. After all, we can’t solve every problem at once. There are modifiable risk assessment templates that can be downloaded from the Association for Professionals in Infection Control and Epidemiology (APIC) or the CDC websites.
- Input your goals into your Infection Control Workplan: Based on the findings from the program evaluation and the risk assessment, the top 4–5 goals can now be entered into the Infection Control Work Program. At a minimum, all risks identified as “high” in the risk assessment should be addressed in the Plan. Goals should be SMART: specific, measurable, achievable, realistic and time-bound.
The activities that need to be carried out to reach the goals should be outlined in the Plan. Be sure to consider and include all stakeholders. Last, the Plan should include a timeline for completing the various activities to keep the team on track. Think of the Infection Control Work Plan as a Care Plan for your IPCP.
Free Infection Control Resources and Tools
Use these free resources and tools to assist Infection Preventionists in long-term care facilities
It is important to remember that you are not alone. Today there are plenty of evidence-based tools and resources to help the LTC IP with program planning, including:
- General tools: You can find helpful tools on state and local public health department websites, state HAI program liaisons, state quality improvement networks, CMS, accrediting bodies, and professional organizations such as the APIC. The CDC also has Nursing Home Infection Control courses2 offered online at no cost. CMS is recommending that all LTC IPs take this training.
- Tools for building an Antimicrobial Stewardship Program: A great starting place is to use the CDC’s checklist for antibiotic stewardship in nursing homes.1
- Tools for cleaning and disinfection: Studies show that LTCF residents have considerable contact with environmental surfaces outside of their rooms such the dining hall, lounge or TV room, group activity areas and therapy areas.2 Establishing a product selection council, bringing in the right healthcare-grade disinfecting products and training to ensure compliant use of these products is critically important to the success of a LTCFs environmental disinfection protocol. Clorox Healthcare is a leader in environmental disinfection and provides free tools and resources specifically designed for long-term care.
There is going to be a bit of a learning curve for LTCFs to get up to speed, but it’s the right thing to do in the name of patient safety, and I believe that these new standards will reduce HAI rates, including Clostridiodes difficile (C. diff), in this country’s elderly care nursing homes.
1. Centers for Disease Control & Prevention. (2017). The Core Elements of Antibiotic Stewardship for Nursing Homes. Retrieved from www.cdc.gov.
2. Pineles, L., Perencevich, E., Roghmann, M., Gupta, K., Cadena, J., Barocco, G., Morgan, D. (2019). Frequency of Nursing Home Resident Contact with Staff, other Residents, and the Environment outside Resident Rooms. ICHE, https://doi.org/10.1017/ice.2019.117.