December 2000
written by and for Long Term Care Infection Control Nurses
INFECTION CONTROL NEWSLETTER |
December 2000
written by and for Long Term Care Infection Control Nurses
Broad Street Solutions
James Marx, RN, MS, CIC Editor
PO Box 16557
San Diego, CA 92176
(619) 656-7887 Voice/FAX
jmarx@concentric.net
On September 25, the new Appendix Q regulations went into effect which now include infection control issues. It defines specific infection control issues that trigger Immediate Jeopardy. Immediate Jeopardy is defined as "A situation in which the providerŐs noncompliance with one or more requirements of participation has caused, or is likely to cause, serious injury, harm, impairment, or death to a resident.Ó (See 42 CFR Part 489.3.)
Failure to protect from widespread nosocomial infections; e.g., failure to practice standard precautions, failure to maintain sterile techniques during invasive procedures and/or failure to identify and treat nosocomial infections. The following is a list of the triggers listed in Appendix Q, along with some thoughts about what the trigger means:
Pervasive improper handling of body fluids or substances from an individual with an infectious disease
The term "infectious disease" will be challenge for the surveyor and the facility to agree upon. Infectious diseases will probably include everything from influenza to scabies. There are several infectious diseases that are not transmitted by improper handling of body fluids, such as chickenpox, tuberculosis and influenza.
High number of infections or contagious diseases without appropriate reporting, intervention and care
The interpretation of high number will be a challenge. Who will determine "high number"? In a 300 bed facility, will 5 cases of MRSA infection be considered high? What if they are not epidemiologically linked? In a 50 bed facility, will 2 cases of nosocomial aspirgillosis be considered high? Infection rates should be used, not numbers of infection. What is the difference between "infectious" and "contagious"? Finally, most infections are not reportable conditions. Urinary tract infections are the most common nursing home infection. If a central national or regional data base of nursing home infections was developed, then a high number of infections might be more objectively determined.
Pattern of ineffective infection control precautions
How will the effectiveness of an infection control precaution be measured? If there is no transmission of infection and the precautions are less than the facility's written policy, is that considered ineffective?
High number of nosocomial infections caused by cross contamination from staff and/or equipment/supplies
If infection control professionals could determine the actual cause of nosocomial infection, we would win a Nobel Prize. Unfortunately, most cases of nosocomial infections in skilled nursing residents are from the residentŐs own flora. Nosocomial infection very rarely are transmitted by equipment/supplies. I would be more concerned with a low number of nosocomial tuberculosis transmission, as evidenced by no employee skin test conversations, than with a high number of nosocomial scabies infestations. Scabies transmission is by direct physical contact, something that is not done often enough with our residents.
The implementation of Appendix Q as it relates to infection control is troubling. If your facility experiences a survey, in which this standard is applied, please contact us. We would like to share these experiences with others.