The Centers for Medicare and Medicaid Services (CMS) continues to expand its regulatory reach in infection control, recently announcing a pilot project to assess the infection risks during transitions of care between hospitals and nursing homes.
As infection preventionists are well aware, this is a longstanding problem that often involves communication breakdowns between transferring and receiving facilities regarding patient status or recent history of multidrug resistant bacteria.
The CMS sent out a Dec. 23, 2015, memorandum to its state survey agency directors announcing a three-year pilot project to assess the “continuum of infection prevention efforts between hospitals and nursing homes in order to prevent transmission of infections in both settings.”
All surveys during the pilot program will be “educational” - no citations will be issued - and will be conducted by a national contractor. The surveys will focus on existing regulations as well as recommended practices, such as those for antibiotic stewardship and transitions of care, the CMS said.
Ten pilot surveys will be conducted in fiscal year 2016 in nursing homes, followed by surveys in both nursing homes and hospitals in FY 2017 and 2018. The project outcomes include “new surveyor infection control tools and survey processes that can be used to optimize assessment of new infection control regulations,” the agency states.
The CMS finalized an infection control survey for hospitals in November 2014, essentially codifying a sweeping array of CDC infection prevention guidelines.1 In addition, in July 2015, CMS issued a proposed rule that calls for a significant upgrade of infection control in nursing homes, solidifying the role with a new title (Infection Prevention and Control Officer) and making it a higher priority through annual risk assessments and antibiotic stewardship requirements.2
The latest pilot survey project “in collaboration with CDC, will better assess compliance with long-term care facility infection control requirements that CMS published in 2015 in a Notice of Proposed Rule-Making,” the memo states. “To the extent that such requirements are published in final form, we believe that these educational surveys will help nursing homes become more prepared and help CMS and the CDC develop training materials for both nursing homes and surveyors. In FY 2017, we expect the educational surveys will be conducted in both hospitals and nursing homes.”
In announcing this latest CMS program, the agency cited the national Ebola experience, saying it highlighted the critical importance of infection prevention programs in protecting both healthcare personnel and patients.
“Translating lessons learned from the Ebola outbreak, including the importance of core infection prevention practices, to every setting where individuals receive healthcare is a significant opportunity to increase the safety of U.S. healthcare facilities,” the CMS notes.
The role of nursing homes in healthcare delivery has expanded significantly, with more than 3 million people now under long-term care. The CMS cites the following factors in targeting nursing homes for improved infection control:
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1 to 3 million serious infections occur every year in these facilities;
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Common infections include urinary tract infections, diarrheal diseases, antibiotic-resistant staphylococcal infections, and other multi-drug resistant organisms;
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Infections are a major cause of hospitalization and death - as many as 380,000 people die from infections in nursing homes every year.
A CLEAR NEED
“There is a clear need to assess the continuum of infection prevention efforts between hospitals and nursing homes to prevent transmission of infections in both settings,” the CMS states. “Assessments in these educational, pilot surveys will allow for further review of infection prevention practices by the healthcare facilities, as well as examination of infection prevention during transitions of care.”
While no citations will be issued, if an “immediate jeopardy” deficiency is noted inspectors are to call the CMS Regional Office for their area. In addition, where the risk of non-compliance is documented, technical expertise can be provided. Sustainable improvements can then be measured using the CDC National Healthcare Safety Network (NHSN) data, the CMS reports.
“Through this effort, issues related to the spread of HAIs between facilities in a local community will also be addressed,” the CMS states. “After the survey findings are determined, a team of infection control professionals will use those survey findings to develop an action plan for improvement and to organize on-site technical assistance.”
CMS staff will communicate details and updates regularly with regional offices and state survey agencies throughout the three-year pilot. The selection of the facilities to participate in this pilot will be communicated at a later time to the regional offices, the agency said.
REFERENCES
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Centers for Medicare and Medicaid Services. Hospital Infection Control Worksheet. Nov. 26, 2014. Available at: http://go.cms.gov/1B6NCSV.
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CMS. Medicare and Medicaid Programs: Reform of Requirements for Long-Term Care Facilities. Fed Reg July 16, 2015: http://1.usa.gov/1hIe6Du.
