The Centers for Medicare & Medicaid Services (CMS) recently released Transmittal R51SOMA, which provides a thorough explanation of the skilled nursing facility (SNF) infection control requirements and components of an effective infection control and prevention program. The transmittal relocated Federal Tags (F-tags) 442, 443, 444, and 445 to F441 and revised the guidance included in F441. F-tags provide investigative protocols and clarification of CMS regulations for long-term care surveyors.
The revisions, which take effect September 30, do not include any CMS regulatory changes. However, the level of detail included in the guidance is substantial.
The transmittal, which issues policies in regards to infection control programs, preventing the spread of infection, and the handling, storing, processing, and transporting of linens, also provides CDC definitions, investigative protocol for surveyors, and compliance criteria, as well as a brief overview of the role infections play in nursing facilities. The latter cites infections as the reason for almost half of all resident hospital transfers, resulting in "an estimated cost of $673 million to $2 billion annually."
SNFs will have to look at their infection control and prevention programs and determine what needs to be changed to comply with the revised guidance. "Since there is always the potential for harm with failed infection control and prevention practices, the lower deficiencies (A-C) do not apply to this F-tag. Facilities will receive higher deficiencies (D-L) for noncompliance," says Frosini Rubertino, RN, CRNAC, C-NE, CDONA/LTC, a clinical services consultant at LTC Systems, a long-term care clinical consultant firm in Bella Vista, AR, and an HCPro Boot Camp instructor.
Most facilities will have to develop a more thorough infection control program, educate staff across all departments, and constantly monitor infection control and prevention efforts.
"The nursing home environment is very fast-paced and it is not uncommon for nurses and nursing assistants to forget to change gloves or clean equipment in between residents," Rubertino says. "Even though the guidance does not take effect until the end of September, facilities should start preparing now because the practices and procedures have to become habits for all staff members."
The new guidance comes at a time when providers are preparing for a potentially virulent flu season. In addition to a rise in cases of the traditional flu, this flu season may facilitate the spread of the H1N1 virus (also known as the swine flu), which the World Health Organization declared a global pandemic on June 11.