Effective March 4, 2020, the Center for Medicare and Medicaid Services (CMS) announced the suspension of non-emergency survey inspections of nursing homes in order to focus on infection control complaints.
In Transmittal QSO20-12, CMS stated that survey activity will be prioritized and limited as follows:
(1) Investigating immediate jeopardy complaints and allegations of abuse and neglect;
(2) Investigating complaints alleging infection control concerns, facilities with potential COVID-19 cases or other respiratory illnesses;
(3) Conducting statutorily required recertification;
(4) Conducting re-visits necessary to resolve current enforcement actions;
(5) Initial certification surveys
(6) Surveying nursing homes with a history of immediate jeopardy infection control deficiencies;
(7) Surveying nursing homes with a history of non-immediate jeopardy infection control deficiencies.
Based on the priority list above, nursing homes that have been found out of compliance with infection control regulations in the past, specifically Tags F880, F881, and F883, should be aware that they may be subject to a survey pursuant to this current guidance.
SURVEYS
If there is a COVID-19 confirmed case or presumptive positive case (positive local test but pending confirmatory test) in a nursing home, a federal complaint or recertifcation survey will be conducted. The survey will take place only after the CDC has cleared the nursing home. It is possible if the conditions at the nursing home are not deemed to rise to the level of immediate jeopardy that a desk audit could occur. However, it is unclear how it will be determined that an immediate jeopardy situation does not exist in a nursing home with a confirmed case of COVID-19.
Limitations
Infection control surveys related to coronavirus findings will be limited to assess infection control requirements. Absent extenuating circumstances all onsite observations and interviews should be completed within two days.
Surveyors are encouraged to conduct as much record review offsite as possible by gathering records to take off site and accessing EHR records remotely.
Focus
Surveys will focus on compliance with 42 C.F.R. § 483.80. Surveyors have been instructed to consider:
- Transmission precautions procedures
- Staff knowledge of transmission precautions
- Staff use of PPE and adequate hand hygiene
- High-risk, significant environmental cleaning issues
- Proper laundering of linens
- Infection Control surveillance program
- Implementation of Antibiotic stewardship program
- Completion of Influenza and Pneumococcal Immunizations
CMS CHECKLIST FOR INFECTION CONTROL COMPLIANCE
CMS also provided surveyors with a detailed task list to use when investigating complaints related to Infection Prevention, Control & Immunizations. It will be beneficial for nursing homes to review the checklist to help ensure compliance with infection control regulations and as a tool to further protect their residents.
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