CMS targets employee health in infection control survey

Survey tool cites TB screening, fit-testing, sharps, and vaccinations

The high-profile effort to reduce health care associated infections (HAIs) nationally is casting light on employee health programs as well, as the Center for Medicare & Medicaid Services recently finalized an infection control assessment tool that blends patient and worker safety.

“This is a great opportunity for hospital leaders to take a look at the role of the employee health department and bring them out of the shadows,” says Sena Blickenstaff, RN, MBA, BSN, principal consultant with Compass Clinical Consulting in Cincinnati, OH.

The 49-page Infection Control Survey, which has been under development for two years, will be a guide for CMS surveyors and a risk assessment and improvement tool for hospitals. That said, the survey also includes many provisions that CMS can cite under its conditions of participation requirements. Although it emphasizes the role of the “infection control officer” and doesn’t specifically mention employee health, it includes many fundamental occupational health tasks.

Reducing hospital-acquired infections is a high priority for CMS. More than 700,000 Americans develop infections in a hospital annually and about 75,000 die, according to the Centers for Disease Control and Prevention. CMS has begun reducing payments by 1% to hospitals that have the highest rates of medical errors and hospital-acquired infections.

The survey includes directives and recommendations on tuberculosis screening, sharps injury prevention, respiratory protection, and health care worker vaccinations. The CMS document enables employee health professionals to partner with infection control and quality improvement on these issues and gain a higher profile with the hospital leadership. The tool was released along with similar CMS surveys on quality assessment and performance improvement and discharge planning. Although The Joint Commission uses a different methodology in its surveys, the accrediting body must align its standards with CMS requirements, says Blickenstaff, who has served as a Joint Commission surveyor. CMS also conducts validation surveys, in which hospitals are selected at random for an unannounced survey.

“Anybody potentially runs the risk of CMS turning up at their doorstep, so it’s best to be prepared,” Blickenstaff says.

CMS to observe PPE use

In small hospitals, the roles of employee health and infection control are often merged. In large facilities, the departments may work so independently that they are like “siloes,” as one exclusively deals with employees and the other handles patient safety.

When the CMS worksheet refers to the “hospital infection control prevention system,” it is allowing hospitals to define different ways of handling the tasks, says MaryAnn Gruden, MSN, CRNP, NP-C, COHN-S/CM, manager of employee health services for the Allegheny Health Network in Pittsburgh and association community liaison for the Association of Occupational Health Professionals in Healthcare.

“They’re giving the employer the option of deciding how these things get accomplished,” she says.

For the first time, CMS surveyors will observe whether health care workers are properly wearing personal protective equipment — gloves, gowns, facemasks or respirators, as appropriate, notes Gruden. The worksheet advises surveyors: “If possible, observe health care personnel use of personal protective equipment in two different patient care areas or settings in hospital.”

“It will be incumbent upon employers to make sure employees know how to wear their PPE, including N95 respirators,” Gruden says.

The spread of Ebola to two nurses in Dallas brought sharp national attention to issues surrounding health care worker protection, she notes. “For a small segment of the workforce, that has beefed up the importance of properly donning and doffing PPE,” Gruden says. “That needs to cascade down to frontline employees.”

Hospitals must track, reduce exposures

When it comes to employee health, the CMS worksheet is not all-encompassing. Some items just offer a starting point, says Mary Gene Ryan, MPH, BSN, RN, COHN-S/SM, CSP, FAAOHN, an occupational health consultant and executive director of MGRyan & Co. in Ventura, CA. For example, “they just mention that you have to have an ongoing respiratory protection program,” she says.

CMS calls for fit-testing “at regular intervals” and doesn’t mention medical screening. The Occupational Safety and Health Administration requires fit-testing of N95 respirators at least annually and medical evaluations before an employee wears a respirator.

Beyond the items on the CMS survey, hospitals need to make sure they’re complying with both state and federal regulations, Ryan says. Some of the provisions in the CMS survey related to employee health include:

• The hospital infection control system puts in place and monitors efforts to prevent needle sticks, sharps injuries, and other employee exposure events.

• The hospital tracks healthcare personnel exposure events, evaluates event data, and develops corrective action plans to reduce the incidence of such events.

• The hospital infection control system ensures all personnel are screened for tuberculosis (TB) upon hire and, for those with negative results, determine ongoing TB screening criteria based upon facility/unit risk classification.

• The hospital infection control system ensures personnel with TB test conversions are provided with appropriate follow-up (e.g. evaluation and treatment, as needed).

In a section that is “for information only,” CMS suggests hospitals ensure and document that all personnel have immunity to measles, mumps, rubella and varicella, that they provide Tdap (tetanus, diphtheria, pertussis) to all personnel and the hepatitis B series to employees with potential occupational exposure, and that they offer the annual influenza vaccine. (See related article on Tdap on page 23.)

An opportunity for quality improvement

Many of the items in the CMS survey can be numerically tracked, and Blickenstaff suggests working with the hospital’s quality improvement team to set goals.

“Identify where you have an opportunity to improve and ask to champion that project,” she says.

The worksheet offers an opportunity to improve communication with other departments and with senior leadership, she says. Employee health professionals can provide feedback on compliance with the employee-related items to hospital leadership and improve documentation of that compliance, she says. For example, sometimes employees continue to work despite not having had their required TB screening or a vaccination.

“A lot of times there’s a disconnect between human resources and the department manager about who they think is responsible for tracking that information,” she says. “Organizations need to have clearly defined processes for who is responsible for collecting the information, who is responsible for follow up, and whether employees can continue to work.”

The CMS survey calls for education of health care workers about infection prevention, providing another opportunity for employee health to assist and raise awareness about employee protections. “It helps to validate what we’re doing,” says Gruden.

Employee health professionals should be proactive in addressing the personnel-related aspects of the CMS worksheet, Ryan says.

“These [items] are becoming standards of practice. It’s seen as a line of achievement,” she says. “You don’t want to be below it.”

[Editor’s note: A copy of the CMS Infection Control Survey Worksheet is available at https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Downloads/Survey-and-Cert-Letter-15-12-Attachment-1.pdf]