The Center for Clinical Standards and Quality/Quality, Safety & Oversight Group released a QSO-21-08-NLTC (Non Long Term Care) on December 30, 2020 to State Survey Agency Directors. This QSO revised the COVID-19 Focused Infection Control (FIC) Survey Tool for Acute and Continuing Care, of which home health and hospice are a part.
Since the PHE (public health emergency) began on January 31, 2020 there have been revisions to surveys, initially suspending some surveys and implementing FIC surveys. However, even with full surveys in progress, depending on the local area COVID-19 surges, there remains a focus on the infection control areas for the surveys.
On March 20, 2020 the first FIC tool was introduced and then updated on September 28, 2020. Now there are some further revisions. The FIC Survey Tool is to be used by surveyors to help ensure an effective assessment of a provider’s implementation of the appropriate infection prevention standards (e.g., transmission-based precautions, face coverings, etc.).
The FIC survey tool is available to every provider in the country to make them aware of infection control priorities during this time of crisis, and providers and suppliers may perform a voluntary self-assessment of their ability to meet these priorities.
Surveyors will continue to utilize the COVID-19 FIC survey tool for Acute and Continuing Care as part of any survey that is conducted.
The FIC survey tool was updated to follow CDC related to screening and triage of those entering healthcare facilities. Specifically, facilities should have a screening process to assess for signs/symptoms consistent with COVID-19 and for exposure to others with known or suspected COVID-19. CDC recommends options for screening symptoms that include but are not limited to: screening questions with an assessment of illness, self-monitored pre-arrival temperature checks with reported absence of fever and symptoms, and facility-monitored temperature checks upon arrival. This will continue to effect home health and especially hospice in dealing with facilities. But also for the ‘facility’ of the home health and hospice agencies.
The full FIC tool can be reviewed at : QSO-21-08-NLTC (PDF)
The following are only the revisions (some were excluded since they were unrelated to home health and hospice) in the FIC tool:
- Appropriate hand hygiene practices (e.g., alcohol-based hand rub (ABHR) or soap and water) are followed. Unless hands are visibly soiled, an alcohol-based hand rub is preferred over soap and water in most clinical situations.
- If there are shortages of ABHR, do staff perform hand hygiene using soap and water instead?
- Do staff perform hand hygiene (even if gloves are used) in situations including After removing PPE (e.g., gloves, gown, eye protection, facemask).
- Interview appropriate staff to determine if hand hygiene supplies (e.g., ABHR, soap and paper towels) are readily available and who they contact for replacement supplies.
Personal Protective Equipment (PPE):
Determine if staff appropriately use PPE including, but not limited to, the following:
- Gloves are worn and/or removed if potential contact with blood or body fluid, mucous membranes, non-intact skin, potentially contaminated skin or potentially contaminated equipment;
- An isolation gown worn for direct patient contact if the patient has uncontained secretions or excretions;
- Appropriate mouth, nose, and eye protection (e.g., facemasks or respirator with goggles or face shield) along with isolation gowns are worn for patient care activities or procedures that are likely to contaminate mucous membranes, or generate splashes or sprays of blood, body fluids, secretions, or excretions;
- If PPE use is extended/reused, is it done according to national and/or local guidelines?
- If it is reused, is it appropriately cleaned/decontaminated/stored/maintained after and/or between uses?
- Interview appropriate staff to determine if PPE is available, accessible and used by staff.
- Are there sufficient PPE supplies available to follow IPC guidelines?
- In the event of PPE shortages, what procedures are the facility taking to address this issue?
Transmission based precautions
Determine if appropriate transmission-based precautions are implemented, including but not limited to:
- PPE use by staff (i.e., don gloves and gowns before contact with the patient and their care environment while on contact precautions; don facemask within six feet of a patient on droplet precautions; for facilities that use/have N-95 masks – don a fit-tested N95 or higher level respirator prior to room entry of a patient on airborne precautions);
- Dedicated or disposable noncritical patient-care equipment (e.g., blood pressure cuffs, blood glucose monitor equipment) is used, or if not available, then equipment is cleaned and disinfected according to manufacturers’ instructions using an EPA-registered disinfectant for healthcare settings (effective against the identified organism if known) prior to use on another patient or before being returned to a common clean storage area. Healthcare settings should refer to List N for EPA-registered disinfectants qualified for use against COVID-19;
Standards, Policies and Procedures
- Did the facility establish a facility-wide IPC Program (IPCP) including written standards, policies, and procedures that are current and based on national standards for undiagnosed respiratory illness and COVID-19?
- Interview appropriate staff to determine if IPC concerns are identified, reported, and acted upon.
Education, Monitoring, and Screening of Staff
- Does the facility have a screening process for all staff to complete prior to or at the beginning of their shift that reviews for exposure to others with known or suspected COVID-19, signs/symptoms of illness and includes whether fever is present (screened upon arrival or self-reported absence of fever)?
- Is there evidence the provider has educated staff on SARS-CoV-2 and COVID-19 (e.g., symptoms, how it is transmitted, screening criteria, work exclusions)?
- How does the provider convey updates on COVID-19 to all staff?
- If staff develop symptoms (as stated above) at work, does the facility:
- Have a process for staff to report their illness or developing symptoms;
- Inform the facility’s infection preventionist and include information on individuals, equipment, and locations the person came in contact with; and
- Follow current guidance about returning to work (e.g., local health department or CDC recommendations).
- Does the facility have a screening process for those entering the facility (patients and visitors) to mitigate the risk of COVID-19 exposure (for example: exposure to COVID-19 screening questions and assessment of symptoms/illness).
HPS stands ready to assist both home health and hospice agencies in ensuring compliance with infection control standards and readiness for a successful survey to occur in your agency. With our combined experience and easy-to-use online resources, we have many ways to help your agency regardless of your location. Please don’t hesitate to contact us.
Additional Resource Links:
- Interim Infection Prevention and Control Recommendations for Healthcare Personnel During the Coronavirus Disease 2019 (COVID-19) Pandemic (https://www.cdc.gov/coronavirus/2019-ncov/hcp/infection-control-recommendations.html)
- Discontinuation of Transmission-Based Precautions and Disposition of Patients with COVID-19 in Healthcare Settings (Interim Guidance) https://www.cdc.gov/coronavirus/2019-ncov/hcp/disposition-hospitalized-patients.html
- Summary for Healthcare Facilities: Strategies for Optimizing the Supply of PPE during Shortages (https://www.cdc.gov/coronavirus/2019-ncov/hcp/ppe-strategy/strategies-optimize-ppe-shortages.html)
- CMS current emergencies page that lists the latest updates and guidance related to COVID-19 survey activity: https://www.cms.gov/About-CMS/Agency-Information/Emergency/EPRO/Current-Emergencies/Current-Emergencies-page
- The HHS Office for Civil Rights (OCR) provides resources on complying with Federal civil rights laws during the COVID-19 pandemic at the following link: https://www.hhs.gov/civil-rights/for-providers/civil-rights-covid19/index.html. OCR also provides resources for assisting hospitals and other healthcare providers with satisfying their legal obligations to provide meaningful access to individuals with limited English proficiency and effective communication to individuals with disabilities at the following link: https://www.hhs.gov/civil-rights/for-individuals/special-topics/hospitals-effective-communication/index.html.
Contact: Questions may be submitted to: QSOG_EmergencyPrep@cms.hhs.gov.