The US Department of Health and Human Services (HHS) Office of Inspector General (OIG) issued a new report January 19, 2023, which says that for the health and safety of residents, nursing homes must be better prepared to face current and future health emergencies. According to the report, in the first year of the COVID-19 pandemic, more than 1,300 nursing homes had extremely high infection rates—75 percent or more of their Medicare beneficiaries. Nursing homes with extremely high infection rates experienced dramatic increases in overall mortality (not limited to deaths of beneficiaries who had or likely had COVID-19). Specifically, these nursing homes experienced an average overall mortality rate approaching 20 percent during these surges—roughly double the mortality rate of other nursing homes during the same time periods. For comparison, in 2019 the average mortality rate in these same nursing homes was 6 percent.
The OIG said that these findings make it clear that nursing homes were not prepared for the sweeping health emergency that COVID-19 created, nor were they able to stem the devastation once it was evident that nursing homes were especially vulnerable. Significant changes are needed to protect the health and safety of residents and better prepare nursing homes for current and future health emergencies.
They recommend that the Centers for Medicare & Medicaid Services (CMS), as it supports the administration’s initiative, take the following actions: (1) re-examine current nursing staff requirements and revise them as necessary; (2) improve how surveys identify infection control risks to nursing home residents and strengthen guidance on assessing the scope and severity of those risks; and (3) target nursing homes in most need of infection control intervention, and provide enhanced oversight and technical assistance to these facilities as appropriate.
You can read the full report, along with CMS’s response, here.
Compliance Perspective
Issue
Infection prevention and control is a critical issue for nursing home residents because of the high number of healthcare-associated infections, residents’ increased susceptibility to infections, and the significant exposure to healthcare-associated infections residents face. Federal regulations on infection control require nursing homes to establish and maintain an Infection Prevention and Control Program (IPCP) designed to provide a safe, sanitary, and comfortable environment and to help prevent the development and transmission of communicable diseases and infections. In addition, Federal regulations on emergency preparedness include specific requirements for nursing homes’ emergency preparedness plans, such as requirements that facilities complete a facility-based and community-based, all-hazards (including emerging infectious diseases) risk assessment and develop strategies to address the risks identified. A nursing home’s QAA Committee must meet at least quarterly and as needed to coordinate and evaluate activities under the Quality Assurance and Performance Improvement (QAPI) program.
Discussion Points
- Review policies and procedures for your IPCP, infection preventionist requirements, and QAA meetings. Ensure that policies are up to date with the most recent CDC and CMS infection control guidelines. Review your emergency preparedness plan and update as necessary. Make sure the plan is available to staff so they can easily access the guidelines for the various components should an emergency occur.
- Train all staff to follow the facility’s policies and procedures for infection prevention and control. Train all staff on your emergency preparedness plan. Conduct drills for the various disaster response plans to ensure staff competency with each. Document that these trainings and drills occurred, and file the signed documents in each employee’s education file.
- Periodically audit to ensure that all staff members are following infection control policies and procedures correctly, and that the IPCP is reviewed annually. Provide additional education if necessary. Audit staff to ensure that they are aware of their roles during an emergency per your emergency preparedness plan. Audit to ensure that quarterly QAA meetings are conducted with all key members.
*This news alert has been prepared by Med-Net Concepts, LLC for informational purposes only and is not intended to provide legal advice.*
