CMS zeroing in on poor PPE use
New survey tool nears completion
Health care workers are notoriously lax about using the proper protective equipment. They rarely wear eye protection when it is called for, and they forget how to properly adjust or remove a respirator.
Those deficiencies may soon get scrutiny from an unexpected (and influential) direction: Inspectors from the Centers for Medicare and Medicaid Services (CMS). A draft CMS infection control survey includes items related to supply and use of personal protective equipment.
Hospitals can be cited if their employees do not wear gloves, gowns, eye, and face protection to prevent exposure or contamination. The CMS survey specifically highlights the use of protective wear when performing aerosol-generating procedures.
Although inspectors will not issue citations related to a hospital’s respiratory protection program, the checklist states that "The hospital infection control system ensures that respiratory fit-testing is provided at least annually to appropriate healthcare personnel." (For PPE-related items on the CMS draft survey, see box on p. 114.)
"Although CMS does not enforce OSHA rules, the strategy with this Patient Safety Initiative surveyor tool is to include some items that represent important infection control and employee safety practices," CMS said in an emailed response to questions from HEH.
PPE is an important element of preventing infectious disease transmission among patients and health care workers, CMS said. CMS is not prescriptive, but expects facilities to follow nationally recognized guidelines. "When surveyors go in and look at use of PPE among health care workers, they would cite the hospital for non-compliance if there was PPE use contrary to their own policies and procedures," CMS said.
The CMS Infection Control Surveyor Worksheet was used in a pilot project in Fiscal Year 2013, which ended September 30. A final version is expected this year.
The CMS also comes amid a closer working relationship between the government insurer and OSHA. OSHA plans to issue voluntary guidance documents through the CMS Hospital Engagement Network.
Failure to wear PPE, or to don and doff it properly, has implications for both worker and patient safety. That realization alone has prompted some hospitals to place a greater emphasis on PPE compliance.
Often, employees don’t realize that they’re putting themselves at risk because they aren’t using the PPE properly. The University of Nebraska Medical Center in Omaha discovered that simulation is an effective tool to uncover the errors — and teach the proper technique. The HEROES (Healthcare and Emergency Responder Organization Education through Simulation) program uses manikins in various emergency scenarios.
"Simulation has the potential to be an eye-opening experience for people," says Elizabeth Beam, MSN, RN, HEROES project coordinator. "People can see themselves doing [something] wrong without making them feel guilty that they’ve harmed someone."
In a small pilot study, Beam observed employees donning and doffing PPE in the simulated environment. Everyone made at least one error.1She also used glow germ to demonstrate the potential for disease transmission. Some employees had glow germ on the back of their heads — where they had untied their gown or removed their mask with contaminated hands.
"All it takes is for the person to have interacted with the patient, touched some really heinous things and go to remove their mask and not to have removed their gloves first. Then they bring their dirty hands right up to their face," Beam says.
The University of Nebraska Medical Center also has a series of online videos to educate health care workers about proper use of PPE and other emergency response issues (www.unmcheroes.org).
Real-life monitoring also is important to boost compliance, says Beam. Recently, UNMC focused on eye protection with education, awareness and monitoring. The hospital also purchased new, more comfortable — and colorful — eye wear.
"We want employees to use [goggles] whenever the splash risk is high," she says. "If you have a $3 pair of glasses that can stop thousands of dollars of post exposure [follow-up], it’s just good business."
Ultimately, hands-on education is effective, she says. "I want students and new providers to have a healthy fear of the environment they’re walking into," she says.
Reference
1. Beam EL, Gibbs SG, Boulter KC, et al. A method for evaluating health care workers' personal protective equipment technique. Am J Infect Control 2011;39:415-420.
What CMS wants to know about your PPE use
Based on a draft survey tool from the Center for Medicare & Medicaid Services (CMS), surveyors will look at the following PPE-related items:
2. C.1 Supplies for adherence to Standard and Transmission-based Precautions (e.g., gloves, gowns, mouth, eye, nose, and face protection) are available and located near point of use.
2. C.2 HCP wear gloves for procedures/activities where contact with blood, body fluids, mucous membranes, or non-intact skin is anticipated.
2. C.3 HCP change gloves and perform hand hygiene before moving from a contaminated body site to a clean body site.
2. C.4 Gowns are worn to prevent contamination of skin and clothing during procedures/activities where contact with blood, body fluids, secretions, or excretions are anticipated.
2. C.5 Gowns and gloves are removed and hand hygiene is performed immediately before leaving the patient's environment.
2. C.6 Appropriate mouth, nose, eye protection is worn for aerosol-generating procedures and/or procedures/activities that are likely to generate splashes or sprays of blood or body fluids.
2. C.7 Surgical masks are worn by HCP when placing a catheter or injecting materials into the epidural or subdural space.
2. D.1 [Environmental services] HCP wear appropriate PPE to preclude exposure to infectious agents or chemicals (PPE can include gloves, gowns, masks, and eye protection).
No citations
1. D.6 The hospital infection control system ensures the facility has a respiratory protection program that details required worksite-specific procedures and elements for required respirator use
1. D.7 The hospital infection control system ensures that respiratory fit-testing is provided at least annually to appropriate healthcare personnel.
