Wednesday, December 15, 2021
EPIC Newsletter
For Arizona SNFs - Emergency Preparedness Infection Control
Meet Dr. Pete, EPIC Consultant
Dr. Peter Patterson is our newest consultant on the EPIC team. Dr. Pete brings years of experience and leadership in long term care and infection control and prevention. He has developed and implemented successful antibiotic stewardship protocols in a number of skilled nursing facilities and brings his subject matter expertise to our grant funded emergency management and infection control program. Check out this video introduction.
Mark Your Calendars for Upcoming EPIC Events

  • Wednesday, January 19 - EPIC Infection Control Emergency Preparedness Tabletop Exercise | Tucson Register Here
  • Wednesday, March 23 - Annual Disaster Ready Summit | Phoenix
  • Thursday, May 5 - EPIC Infection Control Emergency Preparedness Tabletop Exercise| Kingman| Register Here
  • Wednesday, May 25 - EPIC Training: Antibiotic Stewardship Training | Flagstaff
  • Thursday, June 9 - EPIC Antibiotic Stewardship Training | Tucson
  • Wednesday, June 22 - EPIC Infection Control Emergency Preparedness Tabletop Exercise | Kingman
  • Thursday, August 25 - EPIC Water Management Training | Phoenix

For more information or to register for any of these events contact Krysten Dobson.
F880 Infection Control is Top Citation

Infection Control was the #1 cited deficiency in the nation for the FFY 2021. According to the CMS QCOR data base it was cited in 39.5 % of the surveys conducted. In Arizona it was also the #1 cited deficiency and was cited in 50.7% of the surveys conducted in FFY 2021. The top five reasons F880 Infection Control was cited in FFY 2021 had not changed from FFY 2020; they are:

  1. Failing to use PPE required for transmission based precautions and as specified by facility policy.  
  2. Failing to screen staff and visitors entering the facility and failing to document the screening results.
  3. Failing to perform hand hygiene after providing care and according to facility policy.
  4. Failing to clean and/or disinfect personal care equipment between residents.
  5. No documentation employees were free from Tuberculosis. 
F886 COVID 19 Testing also Frequently Cited in Surveys

According to CMS F886 COVID-19 Testing is the sixth most cited requirement in Arizona. This requirement includes that facilities must test residents and staff based on the parameters set by the secretary, which includes routine, outbreak and symptomatic testing. It also includes that facilities are to have procedures for staff and residents who refuse testing or who are unable to be tested, and for what to do in an emergency situations when/if testing supplies are in short supply. This requirement can be found in its entirety on the CMS QSO-20-38-NH - revised on 9/10/2021.The requirement at F886 was most frequently cited for failing to conduct routine staff testing at the required frequency. It was also cited for failing to conduct outbreak testing for non-nursing staff and PRN nursing staff as required. To stay in compliance with this requirement facilities should review the CDC COVID Data Tracker weekly and follow the testing requirements in CMS QSO-20-38-NH Revised on 9/10/2021. Facilities also need to remember that if the level of community transmission increases to a higher level of activity, the facility should begin testing staff at the frequency as soon as the criteria for the higher activity level are met. Facilities should also establish a system to ensure that all unvaccinated staff are tested routinely as required and that during outbreak test no one is missed.  
Sample Policy and Procedures: 
Non-Compliant Resident Refusing to Evacuate (E-0020)
 
Revised interpretative guidance in Appendix Z for E-0020 issued on 4/16/21 states that skilled nursing facilities should have the ability to handle a situation when a resident refuses to evacuate. To illustrate how this type of situation could be managed, AHCA has developed a sample policy and procedure (click here) that can be customized and added to an individual facility's Emergency Operations Plan (EOP) to provide appropriate guidance as well as demonstrate compliance.  Special thanks to Joe Atkinson at Sante Operations and Maurine Salcido at Archstone for assisting with sample P&P development. For additional information, contact the Disaster Ready Team: Stan Szpytek at stan@azhca.org or Gil Damiani at gild@azhca.org with your questions or comments.
Join the Infection Preventionist Call - 12/16/21

Each month EPIC hosts a call targeted to infection preventionists in skilled nursing facilities. If you are interested in participating please send your contact information to Kay Huff and we will send you a link to the call. The call will be held Thursday, December 16th at 1:00 pm.

September IP Call Summary
On the November call the current IP successes and challenges were discussed by all participants. One of the most critical challenges is the new visitation guidance and opening facilities to all visitors. The latest update from CMS on 11/10/21 regarding visitations was reviewed with participants, emphasizing that screening of visitors and vendors remains a requirement. It was also noted that while it is safer for visitors not to enter the facility during an outbreak investigation, visitors must still be allowed in the facility. Facilities must make sure visitors are educated on the risks either verbally or in writing. The issue of performing an outbreak response was also discussed. Facilities should always defer to the recommendations of the jurisdiction’s public health authority in this case. Dr. Patterson also continued dialogue about tools for antibiotic stewardship, as well. The complementary infection control training education opportunities were highlighted, and IP’s were encouraged to participate. 
Don’t Miss Out!
EPIC Offers FREE Infection Control Training
The Arizona Health Care Association Emergency Preparedness Infection Control (EPIC) program is offering free infection control training courses. These trainings will be for one person per facility for each of the two trainings. If you are interested in receiving one of these trainings, click on the links below(KRYSTEN ACTIVATE LINKS)  to complete the interest form. Once we have your contact information, you will receive an email from us (AHCA) with instructions on how to register for the course directly through AHCA/NCAL and a discount code to use when checking out. By using the discount code provided in the email there will be no registration fee at checkout.

Course Titles and Descriptions
  • AHCA/NCAL Infection Preventionist Specialized Training: This is an updated version of the Infection Prevention Control Officer (IPCO) training. Through this program, individuals will be specially trained to effectively implement and manage an Infection Prevention and Control Program in a nursing center. This updated version incorporates information from the COVID-19 pandemic, the most recent regulatory requirements as well as sections on Candida auris, Multi-Drug Resistant Organisms (MDROs), and Enhanced Barrier Precautions (EBP). Additionally, there is an entire section on how to get an effective water management program running in your center.  
  • AHCA/NCAL Infection Prevention and control in the Post-Covid-19 World: This course will review how COVID-19 spreads, how to track and report the illness including the regulatory requirements for infection prevention and control. It will review the basics of infection prevention and control practices and will look at the future of infection prevention and control. The course will describe the process for cohorting and utilizing testing to inform cohorting practices. It will look at how to conduct self-assessment processes to continually evaluate and improve the infection prevention and control program in long term care centers. Lastly, the course will review the process and necessity of screening practices and notifications to residents, families, and their representatives including the importance of communication.

Arizona Coalition for Healthcare Emergency Response (AzCHER) is working on compiling data from the 2021-22 Community Hazard Vulnerability and Resource Gap Assessment Survey Data for the survey was submitted from all coalition partners and health care provider types. The final result is a statewide compilation and includes the input from all health care provider types, hospitals, hospice centers, dialysis center, home health agencies, etc. While it is important to know and use the AzCHER data as a point of reference, each facility must identify their own vulnerabilities and complete a Hazard Vulnerability Assessment (HVA).  The HVA process will help you determine what are the most likely and possible vulnerabilities for your facility so that you may prepare accordingly. In the AzCHER survey, the following are the top 10 hazards are identified:
Statewide Top 10 Hazards
  1. Pandemic Coronavirus
  2. StaffingShortage 
  3. Cyber Attack
  4. Supply Chain Failure
  5. Pandemic Influenzas
  6. Information Systems failure
  7. Communication/Telephone failure
  8. Network Failure 
  9. High Winds (Weather)
  10. Highly/Acute Infectious Disease Outbreak   
List of Multi/Regional Hazards
1.    Pandemic Coronavirus
2.    High/Acute Infectious Disease
3.    Nuclear Incident
4.    Mass Casualty Incident
5.    Radiological Incident (External)
6.    Biological Incident
7.    Mass Electrical Failure
8.    Pandemic Influenza
9.    Staffing Shortage
10. Supply Chain Failure
For more information contact Gil Damiani at gild@azhca.org, or 480-682-7760.
Visitation Now Allowed for all Residents at all Times

CMS is now requiring nursing homes to open their doors to visitors for all residents at all times. CMS also requires facilities to follow the Core Principles of COVID-19 Infection Prevention which were revised in the QSO-20-39-NH memo dated November 12, 2021. These core principles require facilities to screen all who enter and to not allow entry to individuals who currently have a positive COVID-19 test, or who currently meet the criteria for quarantine. The core principles also include performing hand hygiene, wearing face coverings/masks, physical distancing, visitor education, use of PPE, testing as required and clean and disinfecting frequently touched surfaces. The CMS QSO memo also included that visitation may occur during an outbreak investigation within a facility and for residents on transmission based precautions or quarantine. That facilities should educate visitors on the potential risks of visiting during these times and on the core principles of infection prevention. 
Promote the Booster Shot

SARS-CoV-2 is doing its job. Its job is to survive. It does this by mutating to a stronger, more transmissible variant. Researchers are busy identifying if the variant of concern, Omicron, is more transmissible than the Delta variant, whether it causes more severe illness, and how it affects the current efficacy of our vaccinations. Preliminary evidence suggests that the risk for reinfection is higher with this variant compared to others. The best defense against this variant is through vaccinations and boosters. Only 54% of Arizonan’s are fully vaccinated, while 63% have received at least one dose. Those that are not fully vaccinated are at the greatest risk for becoming infected with and spreading COVID-19. This is especially true as we go into the holiday season as people will be meeting with larger crowds and indoors. The key takeaway is to get vaccinated, if eligible get a booster. Even if you are fully vaccinated, the CDC recommends wearing a mask when indoors in public when county rates are substantial to high and if you are immunocompromised. For more information on vaccination and the booster, click here.
Joint Commission Begins Enforcing New Water Management Program

A water management program is already required in SNFs by the Centers for Medicare & Medicaid Services “CMS QSO-17-30: Requirement to Reduce Legionella Risk in Health Care Facility Water Systems to Prevent Cases & Outbreaks of Legionnaires’ Disease.”  Soon, the Joint Commission will be enforcing its new Environment of Care standard for Water Management Program (EC.02.05.02, EPs 1 through 4). The Joint Commission is a standards-setting and accrediting body in health care. The organization accredits post-acute, sub-acute, and some long term care facilities.  This new water management standard goes into effect January 1, 2022 and incorporates the latest research and best practices with the primary goal of improving quality and safety in these settings.
The new standard requires:
  • An individual or team be responsible for the oversight and implementation of the WMP, including but not limited to, development, management, and maintenance activities.
  • Specific elements to be included, such as a basic diagram that maps water supply sources, treatment systems, processing steps, control measures, and end-use points.
  • The water risk management plan to be based on the information in the diagram and include an evaluation of the physical and chemical conditions of each step of the water flow diagram.
  • Review of the water management program annually and when any changes have occurred.
EPIC Q & A

Q: During a facility outbreak of COVID-19 can a resident refuse to be tested?

A: The short answer is yes.

The CMS QSO-20-38-NH Revised September 10, 2021, includes:
 
“Residents (or resident representatives) may exercise their right to decline COVID-19 testing in accordance with the requirements under 42 CFR § 483.10(c)(6). In discussing testing with residents, staff should use person-centered approaches when explaining the importance of testing for COVID-19.
 
Facilities must have procedures in place to address residents who refuse testing. Procedures should ensure that residents who have signs or symptoms of COVID-19 and refuse testing are placed on TBP until the criteria for discontinuing TBP have been met.
 
If outbreak testing has been triggered and an asymptomatic resident refuses testing, the facility should be extremely vigilant, such as through additional monitoring, to ensure the resident maintains appropriate distance from other residents, wears a face covering, and practices effective hand hygiene until the procedures for outbreak testing have been completed.”
Don’t forget to utilize our DR EPIC website for valuable infection prevention resources! Go to: EPIC.DisasterReadyaz.org to explore these tools.
Questions? Contact EPIC@azhca.org |This program is funded by ADHS
The Disaster Ready Emergency Preparedness Infection Control (DR EPIC) program provides education and technical assistance for skilled nursing providers throughout the state. Individual providers will need to exercise their independent discretion in how to apply this information and technical assistance to the unique operation of each facility. For that reason, a facility’s of its professional judgment and due diligence in utilizing the program for infection control and risk management practices is solely within the facility’s control for which it is entirely responsible. 
Copyright 2021.