6 key infection control questions about the new LTC rules

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Lesly Marban, Senior VP, Post-Acute Care, Marketing, Medline Industries
Lesly Marban, Senior VP, Post-Acute Care, Marketing, Medline Industries

The first phase of the new rules of participation for long-term care facilities wishing to participate in the Medicare and Medicaid programs began Nov. 28. 

As part of the hundreds of pages of new requirements, providers are being required to develop an Infection Prevention and Control Program (IPCP) that includes an Antibiotic Stewardship Program and at least one designated Infection Preventionist.

The Infection Preventionist must be in place by Nov. 28, 2019, so there's time to get ready. But providers have a LOT to consider and should start preparing now — for many new provisions.

Here are six key questions we're asked often about the new rules provisions:

1.  What recommendations/best practices are suggested for coming into compliance? 

According to CMS, the IP's primary professional training must be in nursing, medical technology, microbiology, epidemiology or another related field. IPs can be qualified by education, training, experience or certification.

It is important that the IPs devote a majority of their time on an Infection Prevention and Control Program (IPCP). However, in smaller or rural facilities, this may not be feasible or even necessary to have one staff member devote such a substantial amount of their time to the IPCP or have it be their primary responsibility.

CMS has allowed for some flexibility for facilities to determine their own resource requirements for the IPCP, as long as those resources are provided for the IPCP to be effective.

2. How important is collaboration, education and supply chain in order for this role to be effective and strategic? 

It's not just a matter of setting up a plan and hitting the “start” button: The IP is tasked with being strategic in achieving ongoing improved infection prevention results. This means everything from plans to procuring the appropriate supplies and products to support infection prevention practice.

It is extremely important for the IP to collaborate with the clinical and leadership staff to ensure they are part of driving quality assurance and process improvement … not only within their facility but also with their referring hospitals. Why? Because we know that infection control in LTC facilities directly affect hospitals as well. The LTC resident with an infection today may be the patient the hospital must treat tomorrow when he or she arrives at the hospital's emergency department.

Ongoing education, training and competency testing will be essential and the IP must have strong ties with supply chain and or purchasing to ensure their facilities are using the right products for infection prevention and control. Gone are the days of working in silos or just within a facility's four walls.

In order to be strategic and effective, successful programs are often the result of multi-disciplinary teams. Infection prevention is everyone's responsibility in the facility. Some key players that need to be fully engaged and supportive of IPCP should include the C-suite, physicians, pharmacists, risk management and quality assurance, all employees including nurses, EVS, ancillary personal, supply chain and/or purchasing.

The one group that is most often forgotten is the resident and their family. They are a vital part in preventing the transmission of infections. We all play an important role.

3. How can you help facilities with this new role?

Medline has a number of infection prevention solutions that are used in the acute-care setting that can easily be utilized in LTC. Considering that these facilities are now caring for a higher-acuity patient population, they frequently have more complex residents who have indwelling urinary catheters and central venous catheters such as PICCs or ports. While the insertion of these catheters usually take place outside of the facility, the care and maintenance of these lines may need to be done at the LTC facility.

Medline's ERASE CAUTI and ERASE BSI solutions have products and education that address those maintenance issues. Medline also has a full line of environmental services products that include cleaning chemicals, germicidal wipes and microfiber cloths and mops. We are focused on solutions that use educational labeling to guide the EVS worker through the cleaning of high touch surfaces. Another great resource for round-the-clock education about infection prevention strategies is Medline University.

4. How can providers do this efficiently/inexpensively? 

Conducting an in-depth analysis of your infection prevention personnel needs is the first step. If those findings reveal that securing a staff member with a background in microbiology and/or epidemiology is difficult in that area, IPs can be existing nurses with an interest or passion for infection prevention and control.

These individuals can get incremental training or certification that will prepare them for the management of a sound IPCP.

Another point to consider surrounds financials and how the infection prevention program must be completely supported by the organization in order for it to succeed.

5.  What will be the hardest thing for providers to do when it comes to this new role? 

It can take time to adjust to new processes and personnel. Staffing and support for an infection control and antibiotic stewardship programs in LTC are lagging behind acute-care facilities.

So take the time to find the right staff member who is willing and able to take on this challenging role. It will require training, strong relationship building and tenacity.

Organizations should also consider a multidisciplinary team approach to risk analysis.  This can help the team decide what issues have the highest risk. Support and awareness are critical so new IPs know they aren't expected to tackle everything at once or alone.

6. Are there any "hidden" challenges (difficult OR easy) that providers might not have their radar ready for?

This new CMS rule calls for a sweeping upgrade of infection control in nursing homes. When you think about the current challenges LTC facilities face, like high patient-staff ratios, high staff turnover and inadequate implementation of infection control policies, this new role can pave the way for new thinking among staff and improved outcomes for residents.

Lesly Marban is Senior Vice President, Post-Acute Care, Marketing at Medline Industries.

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