The Baltimore-area headquarters of the Centers for Medicare & Medicaid Services (CMS) closed on June 14 after Legionella was discovered in its water supply. The bacterium Legionella can cause a serious type of pneumonia called Legionnaires’ disease in people at risk. Outbreaks generally are linked to environmental reservoirs in large or complex water systems, including those found in healthcare facilities such as hospitals and long-term care facilities.
A recent Centers for Disease Control and Prevention (CDC) report said that in the healthcare facility setting, Legionella was implicated in 111 (52 percent) outbreaks, 444 (21 percent) cases, 364 (65 percent) hospitalizations, and 73 (85 percent) deaths. About one in 10 people who get sick from Legionnaires’ disease will die.
The CMS headquarters has been undergoing renovations, and the Legionella bacteria was discovered when new plumbing fixtures were tested. According to officials, the closure is precautionary. They expect the headquarters to remain closed for several weeks while the water is being treated and additional testing is conducted.
According to the CMS website, the Baltimore headquarters offers many amenities for its employees including a cafeteria, fitness center, daycare center, health unit, credit union, post office, and more.
Compliance Perspective
Issue
Transmission of Legionella can be aerosol generated or when an individual consumes contaminated drinking water. CMS requires that each facility establish and maintain an infection prevention and control program. CMS also expects that each nursing facility will have a policy and procedure to reduce the risk of growth and spread of Legionella and other opportunistic pathogens in the building’s water system. Facilities must have water management plans and documentation that, at a minimum, ensure each facility:
- Conducts a facility risk assessment to identify where Legionella and other opportunistic waterborne pathogens (e.g. Pseudomonas, Acinetobacter, Burkholderia, Stenotrophomonas, nontuberculous mycobacteria, and fungi) could grow and spread in the facility water system.
- Develops and implements a water management program that considers the ASHRAE industry standard and the CDC toolkit.
- Specifies testing protocols and acceptable ranges for control measures, and document the results of testing and corrective actions taken when control limits are not maintained.
- Maintains compliance with other applicable Federal, State, and local requirements.
Discussion Points
- Review the facility’s Infection Control Plan and the policies and procedures for water management to reduce the risk of growth and spread of Legionella and other opportunistic pathogens in the building water system. Revise as necessary.
- Train all staff on the facility’s Infection Control Plan and water management policy and procedures. Document that these trainings occurred, and file each signed document in each employee’s education file.
- Periodically audit to ensure that water samples are taken to test for presence of Legionella and other opportunistic pathogens in the facility’s water supply. Confirm that appropriate staff know how to collect and submit samples for testing, and that staff know what to do if the water samples test positive for Legionella or any other opportunistic pathogens. Ensure that a designated registered nurse is competently serving as the facility’s Infection Preventionist.
*This news alert has been prepared by Med-Net Concepts, LLC for informational purposes only and is not intended to provide legal advice.*
