Finding Description
**NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on observation, interview and record review, the facility failed to implement the facility's policy to address Legionella (a bacterium that can cause a serious type of pneumonia called Legionnaires' Disease (a bacterial disease commonly associated with water-based aerosols) in persons at risk) control that included specific control parameters based on Center for Disease Control and Prevention (CDC) and American Society of Heating, Refrigerating and Air Conditioning Engineers (ASHRAE) standards and failed to implement a water management team and parameters for findings related to water monitoring. The facility failed to ensure nursing staff performed appropriate hand hygiene during care for two residents (Residents #2 and #189), in a review of 13 sampled residents, and for two additional residents (Resident #23 and #31), failed to utilize Enhanced Barrier Precautions (EBP) (infection control measures designed to reduce the transmission of multidrug-resistant organisms (MDROs) in nursing homes and other long-term care facilities) per facility policy during wound care for one sampled resident (Resident #1). The facility census was 35.
1. Review of the facility's undated policy, Legionella Policy and Water Management, showed the following:
-As part of the infection prevention and control program, our facility has a water management program,
overseen by the maintenance department and the water management team;
-The water management team included the administrator, maintenance, Director of Nursing (DON) and medical director;
-The team is to identify areas in the water system where Legionella can grow and spread in order to reduce the risk of Legionnaire's disease;
-The Centers for Disease Control and Prevention (CDC) water prevention toolkit and ASHRAE recommendations have been used in developing a water management program;
-Measures used to control the spread of Legionella: diagram of where control measures are applied, monitor control limits, documentation of the program;
-The Water Management Program will be reviewed at least annually/or as needed if: the control limits are consistently not met, a major maintenance project, water service change, any diagnosis of disease associated with the water system.
Review of the Centers for Medicare and Medicaid Services (CMS) Survey and Certification (S&C) letter 17-30, dated 06/02/17 and revised on 06/09/17, showed the following:
-The bacterium Legionella can cause a serious type of pneumonia called LD (Legionnaire's disease) in persons at risk. Those at risk include persons who are at least [AGE] years old, smokers, or those with underlying medical conditions such as chronic lung disease or immunosuppression. Outbreaks have been linked to poorly maintained water systems in buildings with large or complex water systems including hospitals and long-term care facilities. Transmission can occur via aerosols from devices such as shower heads, cooking towers, hot tubs and decorative fountains;
-Facilities must develop and adhere to policies and procedures that inhibit microbial growth in building water systems that reduce the risk of growth and spread of Legionella and other opportunistic pathogens in water;
-CMS expects Medicare certified healthcare facilities to have water management policies and procedures to reduce the risk of growth and spread of Legionella and other opportunistic pathogens in building water systems. An industry standard calling for the development and implementation of water management programs in large or complex building water systems to reduce the risk of legionellosis was published in 2015 by American Society of Heating, Refrigerating, and Air Conditioning Engineers (ASHRAE). In 2016, the CDC and its partners developed a toolkit to facilitate implementation of this ASHRAE Standard (https://www.cdc.gov/Legionella/maintenance/wmp-toolkit.html). Environmental, clinical, and epidemiological considerations for healthcare facilities are described in this toolkit;
-Conduct a facility risk assessment to identify where Legionella and other opportunistic waterborne pathogens (e.g. Pseudomonas, Acinetobacter, Burkholderia, Stenotrophomonas, nontuberculous mycobacteria, and fungi) could grow and spread in the facility water system;
-Implement a water management program that considers the ASHRAE industry standard and the CDC toolkit, and includes control measures such as physical controls, temperature management, disinfectant level control, visual inspections, and environmental testing for pathogens;
-Specify testing protocols and acceptable ranges for control measures, and document the results of testing and corrective actions taken when control limits are not maintained.
Review of the undated, Centers for Disease Control and Prevention Legionella Environmental Assessment Form showed Legionella generally grow well between 77 degrees Fahrenheit (F) and 113 degrees F. The optimal growth range for Legionella is between 85 degrees F and 108 degrees F. Growth slows between 113 degrees F and 120 degrees F and Legionella begin to die above 120 degrees F. Growth also slows between 68 degrees F and 77 degrees F and Legionella become dormant below 68 degrees F.
The state agency requested, but the facility provided no documentation to show the facility's water management program was reviewed at least annually per facility policy.
The state agency requested, but the facility provided no documentation to show that the water management team, with the specific required staff members, actively held meetings.
Review of water temperatures, obtained by the state agency on 05/28/25, showed the following water temperatures fell between 77 and 113 degrees, where Legionella generally grows well:
-At 12:45 P.M., the Special Care Unit (SCU) room [ROOM NUMBER], hot water faucet temperature was 108.1 F (too cool);
-At 12:48 P.M., the SCU room [ROOM NUMBER], hot water faucet temperature was 102.4 F (too cool);
-At 12:51 P.M., the SCU dining room, cold water faucet temperature was 80.6 F (too warm) and hot water faucet temperature was 109.6 F (too cool);
-At 1:00 P.M., the central hall, room [ROOM NUMBER], hot water faucet temperature was 105.5 F (too cool);
-At 1:03 P.M., the central hall, room [ROOM NUMBER], cold water faucet temperature was 80.6 F( too warm) and hot water faucet temperature was 106.5 F (too cool);
-At 1:15 P.M., the southeast hall, shower sink, hot water faucet temperature was 104.4 F (too cool).
During an interview on 05/29/25 at 11:45 A.M., the infection preventionist (IP) said the following:
-The water management team consisted of the administrator, DON, IP, maintenance director, housekeeping supervisor and the medical director;
-Water management meetings were conducted with Quality Assurance (QA) meetings;
-The Maintenance Director checked the water temperatures;
-Maintenance and housekeeping flush the lines of sinks, showers, and tubs in rooms not in use.
During an interview on 05/29/25 at 2:20 P.M., the Maintenance Director said the following:
-The water management team met monthly with safety walks throughout the facility; he did not have documentation of these meetings;
-His role was to check the water temperatures and flush the unused water supplies, check the boiler room and showers for standing water; he did not have documentation of those checks;
-Hot water should not be over 122 degrees and had to be at least 109 degrees;
-He started checking the cold water temperatures in November;
-He did not know what ASHRAE was;
-The facility had developed the water management team and obtained the CDC packet.
During an interview on 05/29/25 at 2:45 P.M. and 06/09/25 at 1:51 P.M., the Administrator said the following:
-The facility used the CDC tool kit, but not the ASHRAE guidelines that the policy referred to due to the expense of the ASHRAE guidelines;
-The Maintenance and Housekeeping Supervisors do safety rounds and flush lines and report anything abnormal verbally to her; there was no written documentation of this being completed;
-They have discussed water management in the QA meetings.
2. Review of the facility's undated policy, Infection Control, showed the following:
-Purpose: to ensure precautions are taken when caring for residents regardless of their diagnosis or presumed infection status;
-Procedure: Hand washing; staff will wash hands:
-After touching blood, body fluids, secretions, excretions and contaminated items whether or not gloves are worn;
-Immediately after gloves are removed, between resident contacts, and when otherwise indicated to avoid transfer of microorganisms to another resident or environments;
-Between tasks and procedures on the same resident to prevent cross contamination of different body sites;
-Plain soap should be used for routine hand washing;
-An antimicrobial agent or waterless antiseptic agent can be used for specific circumstances (e.g. control of outbreaks or hyper-endemic infection);
-Gloves: Staff will wear clean, non-sterile gloves when touching blood, body fluids, secretions, excretions and contaminated items;
-Before touching mucous membranes and broken skin;
-Gloves will be changed between tasks and procedures on the same resident after contact with material that may contain a high concentration of microorganisms;
-Gloves will be removed promptly after use, before touching non-contaminated items and environmental surfaces, and before going to another resident;
-Hands should be washed immediately after removal of gloves to avoid transfer of microorganisms to other residents or environments.
3. Review of Resident #23's quarterly Minimum Data Set (MDS) , a federally mandated assessment instrument completed by facility staff, dated 05/12/25, showed the following:
-Always incontinent of bowel and bladder;
-Moderate assistance with toileting and personal hygiene.
Review of the resident's care plan, revised 05/27/25, showed the following:
-The resident had an activities of daily living (ADL) self-care performance deficit related to Alzheimer's disease;
-Totally dependent on one or two staff for personal hygiene;
-The resident required assistance of one staff for toileting.
Observation on 05/27/25 at 11:00 A.M. showed the following:
-Certified Nurse Assistant (CNA) J was in the shower room with the resident;
-CNA J wore gloves and removed a urine soaked incontinence brief from the resident;
-While wearing the same soiled gloves, CNA J assisted the resident to put on compression hose and house shoes;
-With the same soiled gloves, CNA J assisted the resident to stand and provided peri-care with wash cloths then pulled up the resident's new incontinence brief and clean pants;
-CNA J removed his/her gloves, and without washing his/her hands, assisted the resident to walk to the dining room, touching the resident's gait belt and walker.
4. Review of Resident #31's quarterly MDS, dated [DATE], showed the following:
-Continent of bowel and bladder;
-Supervision with toileting;
-Moderate assistance with personal hygiene.
Review of the resident's care plan, revised 05/27/25, showed the following:
-The resident had bladder incontinence related to Alzheimer's disease;
-Staff to clean peri area with each incontinence episode.
Observation on 05/27/25 at 11:20 A.M. showed the following:
-CNA J entered the resident's room and without washing his/her hands with soap and water or using hand sanitizer, put on gloves;
-The resident lay in bed and was incontinent of urine;
-CNA J unfastened the resident's urine soiled incontinence brief and cleaned the resident's perineum with wash cloths, then rinsed the perineum;
-While wearing the same gloves he/she wore to provide peri-care, CNA J rolled the resident to his/her right side and touched the resident's left hip with his/her gloved hands;
-With his/her left-hand, CNA J washed and rinsed the resident's buttocks. With the same gloved hand, he/she touched a tube of barrier cream, removed cream from the tube and applied it to his/her soiled gloved hand and then applied the barrier cream to the resident's buttocks;
-CNA J removed his/her gloves and removed the urine soiled linens from the resident's bed with his/her bare hands;
-Without washing his/her hands or using hand sanitizer, CNA J put on clean gloves, and put a clean incontinence brief and pants on the resident as he/she rolled the resident back and forth in bed.
During an interview on 05/27/25 at 2:25 P.M., CNA J said the following:
-Staff should wash hands before and after providing cares, when soiled and when changing gloves;
-Staff should change gloves before and after cares and when soiled;
-He/She should have changed his/her gloves, and washed his/her hands after peri-care and before touching clean items.
Observation on 05/29/25 at 9:15 A.M. showed the following:
-CNA A wore gloves and rolled the resident to his/her right side, rolled a urine soaked bed pad up under the resident, rolled a clean bed pad under the wet bed pad, and cleaned urine from the resident's left buttock with wet wash cloths;
-While wearing the same gloves, CNA A rolled the resident partially to his/her left side, touched the resident's right thigh with his/her gloves, and provided front pericare;
-CNA A continued to roll the resident onto his/her left side by touching the resident's right hip with the same gloves he/she wore when providing peri-care and removed the urine soaked bed pad. CNA A did not remove his/her gloves and covered the resident with the top sheet and cover;
-While wearing the same soiled gloves, CNA A got clean clothes from the resident's closet, put a new incontinence brief and pants on the resident and covered the resident;
-CNA A removed his/her gloves, did not perform hand hygiene, and went out to the hall;
-CNA A returned to the resident's room, did not perform hand hygiene and put on new gloves;
-CNA A assisted the resident to sit up, removed the resident's gown and put on a clean shirt. CNA A applied deodorant to the resident, put house shoes and a gait belt on the resident, and assisted the resident to stand with a walker and walk to the door.
During an interview on 05/29/25 at 9:38 A.M., CNA A said the following:
-He/She was to perform hand hygiene before providing care, when hands were soiled during care, when changing gloves, and after providing care;
-He/She should change his/her gloves if his/her gloves were soiled;
-He/She was not aware he/she should change his/her gloves when only cleaning urine during incontinence care.
5. Review of Resident #2's quarterly MDS, dated [DATE], showed the following:
-Dependent on staff for toileting hygiene, chair/bed-to-chair transfers, rolling left and right, changing positions from sitting to lying and lying to sitting on the side of the bed;
-Needed partial to moderate assistance from staff for upper body dressing;
-Always incontinent of bowel and bladder.
Review of the resident's care plan, revised 05/05/25, showed the following:
-He/She had limited physical mobility and was totally dependent on two staff for toilet use;
-He/She had functional bladder incontinence;
-Clean peri-area with each incontinence episode.
Observation on 05/28/25 at 8:15 P.M., showed the following:
-Nurse Assistant (NA) E and NA F entered the resident's room;
-NA E did not wash his/her hands before donning gloves;
-NA E removed the resident's incontinence brief that was soiled with urine and feces;
-NA E performed peri-care to the resident's buttocks;
-NA E did not change gloves and performed front peri-care;
-NA E removed his/her gloves, did not perform hand hygiene, and put on a new pair of gloves. NA E put a clean incontinence brief on the resident, removed the resident's shirt, obtained mineral cream from a container with his/her gloved fingers, put mineral cream on the resident's back, arms, and chest, and put a new gown on the resident.
-NA E removed his/her gloves and used hand sanitizer (NA E did not wash his/her hands with soap and water as directed in facility policy after providing incontinence care.)
During an interview on 05/30/25 at 12:05 A.M., NA E said the following:
-He/She should wash his/her hands after performing any resident care;
-He/She should change gloves anytime they became visually soiled or when moving from a dirty area to a clean area during peri-care;
-He/She should change gloves after providing incontinence care, and should not touch clean items with soiled gloves.
6. Review of Resident #189's admission MDS, dated [DATE], showed the following:
-Partial/moderate assistance from staff for toileting hygiene and lower body dressing;
-Frequently incontinent of bowel and bladder.
Review of the resident's care plan, revised on 05/28/25, showed the following:
-The resident had an ADL self-care performance deficit related to confusion, dementia and impaired balance;
-He/She required assistance from one or two staff to dress and for toileting.
Observation on 05/28/25 at 11:38 A.M. showed the following:
-The resident lay in bed;
-The resident's incontinence brief, fitted sheet, cloth pad and mattress were soiled with urine;
-NA B and CNA D, did not perform hand hygiene before donning gloves;
-NA B performed front peri-care for the resident;
-NA B removed his/her gloves, did not wash his/her hands, and put on a new pair of gloves;
-CNA D performed peri-care to the resident's buttocks;
-Neither CNA D nor NA B wiped any other areas of the resident's skin that were soiled with urine, including the resident's legs or back;
-CNA D removed the resident's incontinence brief and placed it in a bag, removed the wet fitted sheet and cloth pad and placed them on the bare mattress at the end of the bed;
-NA C put the urine soiled bedding in a bag;
-The mattress had a visible wet spot from where the urine saturated bedding had been in contact with the mattress;
-While wearing the same gloves used to provide peri-care and to handle the soiled linens, NA B and CNA D rolled the resident to his/her back against the urine soiled mattress and dressed the resident;
-NA B and CNA D removed their gloves, did not perform hand hygiene, and put on new gloves;
-NA B and CNA D made the resident's bed without disinfecting or cleaning the urine from the mattress;
-NA B removed his/her gloves, did not perform hand hygiene, and left the resident's room;
-CNA D removed his/her gloves and used hand sanitizer. (CNA D did not wash his/her hands with soap and water as directed in facility policy.)
During an interview on 05/28/25, at 5:18 P.M., CNA D said the following:
-He/She should wash his/her hands before and after providing any care;
-He/She should wash his/her hands or use hand sanitizer before putting on gloves, when changing gloves, and after removing gloves;
-Staff should not place a resident on a urine soiled mattress without placing a barrier between the soiled mattress and the resident's skin;
-He/She did not perform hand hygiene before applying gloves or in between glove changes when providing care for the resident.
7. During interview on 05/30/25 at 1:13 P.M., the Director of Nursing (DON) said the following:
-Staff should wash their hands before and after resident contact, before and after providing care, before applying gloves, in between glove changes, and after removing gloves;
-Staff should wear gloves when providing any care to a resident;
-Staff should change their gloves after providing care, when gloves becoming dirty or are visibly soiled, and in-between front and back pericare;
-Staff should remove soiled gloves and wash their hands with soap and water prior to touching clean items;
-Staff could use hand sanitizer for hand hygiene, but should wash their hands with soap and water after using hand sanitizer two or three times during care.
During an interview on 05/30/25 at 1:39 P.M., the Administrator said the following:
-Staff should wash their hands before any procedure, in between cares, during care if hands become soiled, and when changing gloves;
-Staff should wear gloves when providing direct resident care.
8. Review of the facility's undated policy, Enhanced Barrier Precautions (EBP), showed the following:
-EBP is an infection control strategy to reduce the transmission of multidrug-resistant organisms (MDROs) and other infections in nursing homes. EBP expands on Standard Precautions by requiring gowns and gloves during specific high-contact resident care activities for residents at increased risk of MDRO acquisition or those known to be colonized or infected with an MDRO;
-EBP focuses on targeted use of personal protective equipment (PPE) (gowns and gloves) during specific high-contact activities, rather than requiring them for all residents;
-Activities like dressing, bathing/showering, transferring, and device care are examples of high-contact activities where EBP is used;
-EBP is generally intended to be in place for the duration of a resident's stay or until the risk factors (e.g., wound or device) are resolved;
-Residents may require EBP if they have an MDRO infection or colonization, have wounds or indwelling medical devices, or are deemed at higher risk by the facility;
-Gowns, staff will wear a clean, non-sterile gown to protect skin and prevent soiling of clothing during procedures and resident care activities that are likely to generate splashes or sprays of blood, body fluids, secretions, or excretions.
9. Review of Resident #1's quarterly MDS, dated [DATE], showed the following:
-Severely impaired cognition;
-Dependent on staff for bed mobility and transfers;
-Has one Stage II pressure ulcer (partial-thickness skin loss with exposed dermis, presenting as a shallow open ulcer).
Review of the resident's care plan, last reviewed 5/5/25, showed the following:
-The resident had a pressure ulcer or potential for pressure ulcer development related to mobility;
-Administer treatments as ordered and monitor for effectiveness;
-The resident's care plan did not identify the need for or the use of EBP when providing care for the resident.
Review of the resident's Physician Order Sheet (POS), dated May 2025, showed an order to cleanse daily with normal saline or wound cleanser and pat dry, apply Urgoclean (wound dressing that aids in the continuous removal of slough and wound debris) dressing to wound base, cover with optifoam (a foam dressing) dressing every day shift for wound care;
Observation on 5/30/25 at 9:32 A.M., showed the following:
-EBP supplies hung on the outside of the resident's room door;
-Licensed Practical Nurse (LPN) P pushed the treatment cart into the resident's room, applied hand sanitizer to his/her hands and put on gloves. LPN P did not put on a gown;
-LPN P gathered dressing supplies from the treatment cart and placed them directly on the resident's bed without a barrier;
-LPN P removed the heel protector, sock and dressing from the resident's right outer ankle;
-Wearing the same gloves, LPN P placed clean gauze under the resident's right foot, picked up a bottle of wound cleanser, sprayed the dime-sized wound and removed the packing from the wound;
-LPN P removed his/her gloves, applied hand sanitizer and put on new gloves;
-LPN P cut a small piece of Urgoclean dressing and applied it to the wound;
-LPN P applied an optifoam dressing to cover the wound;
-LPN P removed his/her gloves, did not wash or sanitize his/her hands, then dated the dressing with a pen, and put socks and the heel protector on the resident's foot.
During interview on 5/30/25 at 9:42 A.M., LPN P said residents with catheters or wounds usually have enhanced barrier precautions. He/She forgot to put on a gown prior to performing the resident's dressing change. He/She should have placed the dressing supplies on a barrier but the resident had his/her breakfast on the bedside table. He/She should wash his/her hands and change gloves when going from a dirty task to a clean task, before he/she started a procedure and when the procedure was complete.
During interview on 05/30/25 at 1:13 P.M., the DON said staff should use EBP on any resident with a wound.