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Regulations Update

Marci Pederson, RN, BSN, Nurse Educator/Consultant

Federal Regulation - F441 Infection Control

F441 Infection Control was the most cited regulation of the top 25 cited regulations in long term care facilities in the state of South Dakota for the year of 2010 with 49 deficiencies.

“F441 (Rev.52; Issued: 09-25-09; Effective/Implementation Date: 09-30-09)

§483.65 Infection Control

The facility must establish and maintain an Infection Control Program designed to provide a safe, sanitary and comfortable environment and to help prevent the development and transmission of disease and infection.

§483.65(a) Infection Control Program

The facility must establish an Infection Control Program under which it –

(1) Investigates, controls, and prevents infections in the facility;

(2) Decides what procedures, such as isolation, should be applied to an individual resident; and

(3) Maintains a record of incidents and corrective actions related to infections.

§483.65(b) Preventing Spread of Infection

(1) When the Infection Control Program determines that a resident needs isolation to prevent the spread of infection, the facility must isolate the resident.

(2) The facility must prohibit employees with a communicable disease or infected skin lesions from direct contact with residents or their food, if direct contact will transmit the disease.

(3) The facility must require staff to wash their hands after each direct resident contact for which hand washing is indicated by accepted professional practice.

§483.65(c) Linens

Personnel must handle, store, process and transport linens so as to prevent the spread of infection.”

Noncompliance with hand hygiene and glove use continues to be the biggest reason for Infection Control deficiencies. Why is this so? This is a very difficult question to answer. 

Part of the problem has to do with health care workers (HCWs) forgetting when hand hygiene is needed. In my observations during the past several years I found HCWs usually performed hand hygiene before and after caring for a resident. The problem seemed to occur when the HCW had performed a dirty task such as perineal care and then did a clean task such as cleaning the resident’s glasses or transferring from the bed to the chair while providing care. In the kitchen, deficiencies occurred because dietary staff did not do hand hygiene when they finished a dirty task or touched something which was not clean and then began a clean task such as vegetable preparation. By missing the opportunity of performing hand hygiene, cross-contamination of resident care equipment and the physical environment occurs thus increasing the potential transmission of infection.  

Sometimes we need to become creative in helping to trigger the behavior of hand hygiene for HCWs. In my webinar presentation on Clostridium difficile I included the mantra “Dirty to Clean Wash Hands in Between”. Perhaps using a mantra could be helpful. Another suggestion is to have brain storming sessions with all HCWs to discuss ways to improve compliance with hand hygiene and glove use. The following information is from the Guidance to Surveyors for F441, and it addresses hand hygiene and glove use.

Hand Hygiene

Hand hygiene continues to be the primary means of preventing the transmission of infection. The following is a list of some situations that require hand hygiene:

  • When coming on duty
  • When hands are visibly soiled (hand washing with soap and water); before and after direct resident contact (for which hand hygiene is indicated by acceptable professional practice)
  • Before and after performing any invasive procedure (e.g., fingerstick blood sampling)
  • Before and after entering isolation precaution settings
  • Before and after eating or handling food (hand washing with soap and water)
  • Before and after assisting a resident with meals (hand washing with soap and water)
  • Before and after assisting a resident with personal care (e.g., oral care, bathing)
  • Before and after handling peripheral vascular catheters and other invasive devices
  • Before and after inserting indwelling catheters
  • Before and after changing a dressing
  • Upon and after coming in contact with a resident’s intact skin, (e.g., when taking a pulse or blood pressure, and lifting a resident)
  • After personal use of the toilet (hand washing with soap and water)
  • Before and after assisting a resident with toileting (hand washing with soap and water)
  • After contact with a resident with infectious diarrhea including, but not limited to infections caused by norovirus, salmonella, shigella, and C. difficile (hand washing with soap and water)
  • After blowing or wiping nose
  • After contact with a resident’s mucous membranes and body fluids or excretions
  • After handling soiled or used linens, dressings, bedpans, catheters and urinals
  • After handling soiled equipment or utensils
  • After performing your personal hygiene (hand washing with soap and water)
  • After removing gloves or aprons
  • After completing duty

Alcohol based hand rubs (ABHR) cannot be used in place of proper hand washing techniques in a food service setting.

Recommended techniques for washing hands with soap and water include:

  • wetting hands first with clean, running warm water
  • applying the amount of product recommended by the manufacturer to hands
  • rubbing hands together vigorously for at least 15 seconds covering all surfaces of the hands and fingers
  • then rinsing hands with water and drying thoroughly with a disposable towel
  • turning off the faucet on the hand sink with the disposable paper towel

Except for situations where hand washing is specifically required, antimicrobial agents such as ABHR are also appropriate for cleaning hands and can be used for direct resident care. Recommended techniques for performing hand hygiene with an ABHR include:

  • applying product to the palm of one hand
  • rubbing hands together, covering all surfaces of hands and fingers, until the hands are dry

In addition, gloves or use of baby wipes are not substitutes for hand hygiene.”

Let’s set the intention for improved hand hygiene and glove use with HCWs.  The benefits to this are lower infection rates, better quality of life and care for the residents, fewer infections taken home to our families, and fewer survey deficiencies.

As a former health facilities senior surveyor, Marci worked at the Department of Health Office of Licensure and Certification for eight years. Marci provides Survey Preparedness Consulting designed to create a culture of constant survey preparedness by helping staff understand regulatory requirements, not just comply with them.

 

Contact me at mapederson@avera.org for all of your Regulatory Compliance and Survey Preparation needs.

Do the math! The facility bottom line improves when resident care continually improves.

As a former health facilities senior surveyor, Marci worked at the Department of Health Office of Licensure and Certification for eight years. Marci provides Survey Preparedness Consulting designed to create a culture of constant survey preparedness by helping staff understand regulatory requirements, not just comply with them.

Read more Regulations Updates. The Avera Solutions’ Blog contains writings from Marci and other Avera Education & Staffing Solutions staff and consultants.


Marci Pederson, RN, BSN

Marci Pederson, RN, BSN

As a former health facilities senior surveyor, Marci served a variety of health care facilities. Her experience includes nursing education, medical/surgical nursing, psychiatric nursing, infection control, utilization review and quality assurance.

Have a question for Marci? A topic idea for her next column? Need more information on having a mock survey at your facility? Send her an email at mapederson@avera.org.