Thursday, June 10, 2021
DR EPIC Newsletter
For Arizona SNFs: Emergency Preparedness Infection Control
Infection Prevention Checklist Available

The Infection Preventionist (IP) role in Long Term Care facilities is essential to assuring the management of an infectious pandemic. Click on this link to view a document that provides a description of the role and a checklist that the IP can use to assure the necessary tasks are completed at the required frequency. The checklist includes tasks to be completed daily, weekly, monthly, quarterly, annually and as needed. Don’t miss the monthly IP networking call! Make sure to submit your contact information to khuff@azhca.org to participate in the ZOOM call. The next one is slated for: Thursday, June 24, 2021 at 1:00 p.m.!
Recognize the Important Role of CNAs in Infection Prevention

Your CNAs are a critical component of successful infection control. Make sure you recognize them during CNA Week- June 17 - June 24! The National Association of Health Care Assistants (NAHCA) has created a toolkit that covers everything! From a motivational video to social media posts and educational webinars, the CNA Week Toolkit is available to help all long term care facilities celebrate their hard working and dedicated CNAs.
Make Sure you are in Compliance with E Tag 0001

In the SNF survey process, E Tag 0001 requires the “Establishment of a Facility Emergency Program”. An emergency preparedness program describes a facility’s comprehensive approach to meeting the health, safety and security needs of the facility, its staff and the resident population and community prior to and after an emergency or disaster. The program must encompass four core elements including:

  1. An Emergency Plan
  2. Risk Assessment (Hazard Vulnerability Assessment)
  3. Policies and Procedures
  4. Communication Plan and the Training and Testing Program.

To learn more about these elements, AzCHER is presenting a program titled Introduction to Emergency Management and ICS Basics. It will be held today, Thursday, June 10, 2021 from 10 a.m. to 12 p.m. You can register here. If you are new to your role in emergency management… here is an opportunity to learn more about EM basics as well as the Incident Command System (ICS) that is essential to effective emergency response.
Are you Optimizing Personal Protective Equipment?

Thoughts from DR EPIC Consultant Dr Buffy Lloyd-Krejci…Is your SNF currently still reusing personal protective equipment (PPE) per the CDC optimization strategy? Have you paused to consider why you may still be operating under this protocol? It is important to remember that we only reuse PPE supplies when are supply chain is limited. This is not currently the situation for most PPE and therefore, we must utilize PPE under conventional capacity strategies. For example, if you have a new resident admission/readmission on a 14-day quarantine that requires contact/droplet precautions, be sure that the staff are utilizing a new gown every time they are entering the resident room. If you are laundering your gowns, the same protocol applies except instead of throwing the gown away, you place it in the soiled linen bin. If you are using face masks and eye protection for source control, we can follow the CDC’s extended use protocol and discard the PPE when visibly soiled, damaged, or hard to breathe through. It should also be immediately discarded after removal. If eye protection such as a face shield or goggles are being used as source control, they should be dedicated to one healthcare personnel and cleaned and disinfected whenever they are visibly soiled or removed (isolation area) prior to putting it back on. Be sure to clean and disinfect the eye protection per the CDC recommendations including using an EPA-registered hospital disinfectant solution. 
Conduct an Annual Review of Your EP Program and HVA (E-004 & E-006)

As 2021 continues to fly by and we approach the halfway point of the year, it's a good time to check and see if your skilled nursing facility has conducted the annual review and update of your Emergency Preparedness (EP) program as required by E 004. Additionally, your facility-based and community-wide Hazard Vulnerability Assessment (HVA) are required to be reviewed and updated annually per the requirements of E-006. Make sure that you have some type of system in place to ensure that these reviews and updates occur in accordance with the annual requirements. These tasks should be properly documented in your facility's EP Compliance Binder to help demonstrate compliance and to help avoid receiving a deficiency. Contact Stan Szpytek, Disaster Ready Consultant at stan@azhca.org or Gil Damiani, Disaster Ready Consultant at gild@azhca.org with any questions about CMS EP compliance.
Don’t Forget your Hand Hygiene!

The most fundamental and seemingly simple way we can literally save lives and harm in our facilities is through hand hygiene. We all know when and how to perform hand hygiene, but state surveys demonstrate that it may not be employed facility wide. It is a topic we must address over and over, no matter how tired of it we are. The issue usually isn’t dereliction of process, it often lies in the lack of access to hand sanitizer dispensers. The CDC recommends Alcohol Based Hand Rub (ABHR) dispensers inside of every resident room and outside of every resident room, if possible. In addition, in long-term care facilities, ABHR is considered the preferential use for hand hygiene in most situations. The greater the access to ABHR, the more hand hygiene will be performed.

The DR EPIC team is available for any other additional questions, and you can contact the DR EPIC Helpline at epic@azhca.org or by calling 602-241-4644.
Be Aware of the CMS QSO Memo on the Interim Final Rule for Vaccine Requirements

The CMS QSO-21-19-NH Memo that came out on May 11, 2021 describes the new interim final rule for COVID-19 vaccine immunization requirements for residents and staff. The new requirement requires long term care facilities (LTCF) to develop COVID-19 vaccination administration, reporting, and education policies and procedures. The LTCF are required to report COVID vaccine status, including refusal, of residents and staff, each dose of vaccine received, COVID-19 vaccination adverse events, and therapeutics administered to residents for treatment of COVID-19. In addition, the LTCF must demonstrate that it has provided COVID-19 vaccination education to all staff, residents, and resident representatives. CMS will begin reviewing facilities for compliance with the new vaccination reporting requirements on Monday, June 14, 2021. The QSO memo can be found here.
New NIOSH Guidance on N-95 Respirators

The National Institute for Occupational Safety and Health (NIOSH) issued new ​​guidance that health care providers should only use N-95 respirators and should not be using crisis standards as availability of N-95 respirators is sufficient. According to a situational update as of May 2021:

 “T​he supply and availability of NIOSH-approved respirators have increased significantly over the last several months. Health care facilities should not be using crisis capacity strategies at this time and should promptly resume conventional practices. Check the NIOSH Certified Equipment List to identify all NIOSH-approved respirators.  Health care facilities should stop purchasing non-NIOSH-approved respirators for use as respiratory protection and consider using any that have been stored for source control where respiratory protection is not needed. Respirators that were previously used and decontaminated should not be stored. We do not know the long-term stability of non-NIOSH-approved respirators and respirators that have been decontaminated, and if these will be recommended for use in the future. Health care facilities should return to using only NIOSH-approved respirators where needed.” 
OSHA Releases Top 10 Citations List for 2020 and Ways to Prevent Injuries, Illnesses, Fatalities and Costly Noncompliance Penalties

Protecting the health and safety of the U.S. workforce has improved over the years, but the Occupational Safety & Health Administration (OSHA) reports that 5,333 workers still died on the job as recently as 2019. In addition to these tragic deaths, countless more were injured on the job or developed preventable occupational diseases.

To protect workers, there are a number of OSHA standards that are enforced by the agency. Each year, a list of the 10 most frequently cited safety and health violations are released. The list is meant to build awareness of areas that need to be given more attention.
 
The OSHA Top 10 Citations list for 2020 includes:

  1. Fall Protection - General Requirements (5,424 violations)
  2. Hazard Communication (3,199 violations)
  3. Respiratory Protection (2,649 violations)
  4. Scaffolding (2,538 violations)
  5. Ladders (2,129 violations)
  6. Lockout/Tagout (2,065 violations)
  7. Powered Industrial Trucks (1,932 violations)
  8. Fall Protection - Training Requirements (1,621 violations)
  9. Personal Protective and Life Saving Equipment – Eye and Face Protection (1,369 violations)
  10.  Machine Guarding (1,313 violations)
Required Documentation for SNF Immunization Reporting Compliance
 
This article will address the documentation required to demonstrate compliance at F887: COVID-19 Immunization. The new interpretive guidance for surveyors’ states that the resident’s medical record must include documentation that indicates, at a minimum:

  • The resident or resident representative was provided education regarding the benefits and potential side effects of the COVID-19 vaccine;

  • The resident or representative, either accepted and received the COVID-19 vaccine or did not receive the vaccine due to medical contraindications, or refusal;

  • If there is a contraindication to the resident having the vaccination, the appropriate documentation must be made in the resident’s medical record; and

  • Date the education and offering took place, and the name of the representative that received the education and accepted or refused the vaccine.

  • Facilities should also maintain and provide samples of the educational materials that were used to educate residents or resident representative.
 
The facility must also maintain documentation that each staff member was educated on the benefits and potential side effects of the COVID-19 vaccine and offered vaccination unless medically contraindicated or the staff member has already been immunized. Compliance can be demonstrated by providing a roster of staff that received education (e.g., a sign-in sheet), the date of the education, and samples of the educational materials that were used to educate staff. The facility must document the vaccination status of each staff member (i.e., immunized or not), including whether fully immunized (i.e., completed the series of multi-dose vaccines). If a staff member is not eligible for COVID-19 vaccination because of previous immunization at another location or outside of the facility, the facility should request vaccination documentation from the staff member to confirm vaccination status.
Virtual SNF Tabletop Resources with Specific SNF Behavioral Care Videos Now Available

Announcing the availability of a new resource specifically for facilities specializing in behavioral care… the Disaster Ready Behavioral Care Virtual Tabletop Exercise videos. Click here for an overview. These exciting new resources were developed with funding from the ADHS Hospital Preparedness Program (HPP) grant and will allow you to use a virtual classroom model to meet your regulatory requirement for conducting an emergency preparedness tabletop exercise. This tool addresses the unique characteristics of the residents you serve and encourages you to plan for their needs. Our Disaster Ready consultants Stan Szpytek and Gil Damiani will lead you through the exercise implementation step by step in these videos. You should block 2 hours with your leadership team to conduct this exercise and all you will need is access to video/computer equipment to stream it. Contact Krysten Dobson if you need additional information, support or assistance at kdobson@azhca.org. 
DR EPIC Helpline Question
Q: If a staff member who is not vaccinated but is wearing a mask is present during a group activity or communal dining can the residents still go without source control or being physically distanced?
 
A: According to the CDC’s outline and our read of CMS guidance, if an unvaccinated staff or resident joins a group activity (e.g. dinning, activity, etc) with vaccinated residents or vaccinated staff, or both then everyone needs to use a source control mask. Of course, if an unvaccinated person briefly walks into a room, they don’t all have to rush to put on a mask but generally, yes when unvaccinated people interact with vaccinated people, all have to wear a source control mask.This is because of the asymptomatic carriage; the spread of variants and that the vaccination is not 100% effective and there is waning immunity which appears faster among the elderly and we don’t know how soon that will wear off. Also, we are seeing more and more immunocompromised people with a weaker immune response.
 
Thank you to Dr. David Gifford, Chief Medical Officer at AHCA/NCAL for this answer.
Check out our DR EPIC Helpline!
To submit questions, email the DR EPIC online Help Center at EPIC@azhca.org. You can also call the DR EPIC phone Helpline at 602-241-4644 and we will assist you.

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 HPP
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.