Finding Description
**NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on interview, record review and document review, the facility failed to ensure 1) infection event forms were being initiated and/or completed and discussions between nursing staff and prescribers were documented regarding adherence to the McGeer criteria for antibiotic orders (a set of guidelines used to determine if a patient has an infection which may need antibiotics) for 4 of 12 sampled residents (Residents and 87, 146, 149 and 5) and; 2) prescribers were being provided education regarding the facility's antibiotic stewardship program (ASP) on an annual basis and as needed in accordance with the facility's ASP policy. The deficient practice placed residents at risk for antimicrobial resistance and adverse effects of antibiotics.
Findings include:
The Antibiotic Stewardship Program policy and procedure (undated), documented the ASP was designed to improve the use of antibiotics to improve outcomes for patients with infectious disease, prevent antimicrobial resistance, and prevent adverse events associated with antibiotics such as Clostridium difficile diarrhea. The Infection Preventionist (IP) would evaluate the appropriateness of antibiotic therapy and would communicate recommendations with the prescribers. The prescriber would provide explicit written justification in the medical record for non-recommended antibiotic prescribing.
Infection Event forms
On 01/09/2025 at 10:08 AM, the Infection Preventionist (IP) and Clinical Nurse Manager (CNM) verbalized the facility utilized the McGeer Criteria as the facility's guideline for antibiotic use. The IP explained nurses initiated and completed infection event tracking forms for each infection event and/or antibiotic use.
On 01/09/2025 at 11:01 AM, the Regional Director of Clinical Services (RDCS) confirmed the facility adopted the McGeer criteria as the facility's guideline for antibiotic therapies and indicated expecting prescribers to follow the McGeer criteria. The RDCS clarified the facility utilized two different forms for tracking infections, one was titled Admit Infection Tracker which was used for residents who were admitted to the facility with antibiotic orders from the hospital and the other was titled Infection Tracker with McGeer criteria for in-house antibiotic starts. According to the RDCS, the infection tracking forms were expected to be initiated and completed for each antibiotic use.
On 01/09/2025 in the morning, the IP indicated there were currently four residents who were receiving antibiotics in the facility, namely, Residents 87, 146, 149 and 5.
Resident 87 (R87)
R87 was admitted on [DATE], with diagnoses including fracture of upper end of right humerus and subsequent encounter with routine healing.
A physician's order dated 01/08/2025, documented to give Amoxicillin-pot clavulanate 875 milligrams (mg) - 125 mg one tablet by mouth twice a day for seven days for ear pain.
The medical record lacked documented evidence the Infection Tracker with McGeer criteria document was initiated or completed, discussions with the prescriber regarding non-adherence to the McGeer criteria was documented and an explicit written justification for the antibiotic was provided by the prescribing physician.
On 01/09/2025 in the afternoon, the IP reviewed the McGeer criteria and confirmed R87's antibiotic order did not meet the criteria to be classified as a cellulitis, soft tissue, or wound infection because the only symptom present was ear pain. The IP confirmed there was no documented evidence the IP or any nurse questioned the prescriber's order nor did the prescriber record a written justification for the antibiotic order in the R87's medical record.
Resident 146 (R146)
R146 was admitted on [DATE], with diagnoses including sepsis due to Methicillin susceptible Staphylococcus aureus and infection and inflammatory reaction due to internal left knee prosthesis.
A physician's order dated 12/24/2024, documented to give Cefazolin reconstituted solution 2 grams/2,000 mg intravenously every eight hours for left knee septic joint times 116 doses.
A physician's order dated 12/24/2024, documented to give Metronidazole 500 mg one tablet by mouth three times a day for left knee septic joint for 42 days.
The medical record lacked documented evidence the Admit Infection Tracker was initiated appropriately and completed which would include a re-evaluation of R146's treatment plan such as status, progress or effectiveness of R146's current regimen.
On 01/09/2025 at 10:41 AM, the IP indicated R146's infection tracker was initiated but not completed.
On 01/09/2025 at 10:48 AM, the RDCS indicated R146's infection tracker was started but lacked basic information made available by hospital records such as infection type, site, signs and symptoms, and any diagnostic tests done at the acute setting.
Resident 149 (R149)
R149 was admitted on [DATE], with diagnoses including laceration without foreign body of abdominal wall and protein-calorie malnutrition.
A physician's order dated 01/06/2025, documented to give Amoxicillin-pot clavulanate 875 mg-125 mg one tablet by mouth twice a day for urinary tract infection (UTI).
The medical record lacked documented evidence the Infection Tracker with McGeer criteria document was initiated or completed, discussions with the prescriber regarding non-adherence to the McGeer criteria was documented and an explicit written justification for the antibiotic was provided by the prescribing physician.
The McGeer Criteria for Infection Surveillance Checklist revised 11/05/2024, revealed residents without indwelling catheters must fulfill one sign and symptom such as acute dysuria (pain when urinating), fever or leukocytosis, suprapubic pain or gross hematuria if afebrile AND a positive diagnostic urine test showing equal to or greater than 10 colony-forming units per milliliter.
On 01/09/2025 at 11:14 AM, the IP confirmed no infection tracker was initiated when R149 was started on antibiotics for a suspected UTI on 01/07/2025. The DON recalled the prescriber ordered antibiotics based on a staff report of foul-smelling, cloudy urine, a urine sample was collected with pending results.
On 01/09/25 at 11:19 AM, the RDCS confirmed the R149's infection tracker should have been initiated on 01/07/2024 with information such as infection type, site, signs and symptoms, antibiotic order and indication for use, diagnostic tests, whether the treatment was ordered for prophylactic use or otherwise.
01/09/25 11:33 AM, the RDCS verbalized there should have been documented evidence of a discussion between the nurse and the prescriber regarding R149's signs and symptoms, history of UTI, and recommendations when antibiotic orders for the resident was received.
On 01/09/2025 in the afternoon, the IP reviewed the McGeer criteria and stated the physician did not follow the McGeer criteria for R149's antibiotic order since R149 met none of the symptoms for a UTI. The IP confirmed there was no documented discussion between the IP and the prescriber regarding non-adherence to the McGeer criteria and there was no documented justification by the ordering physician regarding the antibiotic prescription.
Resident 5 (R5)
R5 was admitted on [DATE], with diagnoses including fracture of left tibia with subsequent encounter for closed fracture with routine healing.
A physician's order for Doxycycline hyclate 100 mg one capsule by mouth twice a day for seven days for possible wound infection on left lower lateral and medial leg open wound.
The medical record lacked documented evidence the Infection Tracker with McGeer criteria document was initiated or completed, discussions with the prescriber regarding non-adherence to the McGeer criteria was documented and a written justification for the antibiotic was provided by the prescribing physician.
The McGeer Criteria for Infection Surveillance Checklist revised 11/05/2024, revealed cellulitis, soft tissue or wound infection must present with pus at wound, skin or soft tissue site, or four of the following symptoms to include heat, redness, swelling, tenderness, serous drainage and fever or a positive superficial wound culture.
On 01/09/2025 at 3:29 PM, the CNM confirmed an infection tracker was not started and completed, a diagnostic test such as a wound swab was not recommended or ordered.
On 01/09/2025 at 3:30 PM, the IP indicated the prescriber ordered R5's antibiotics based on reports of serosanguinous drainage of left leg wound with no other accompanying symptoms or a positive wound culture. The IP confirmed R5's infection status did not meet McGeer criteria for cellulitis, soft tissue or wound infection. The IP stated there was no documented evidence of a nurse-physician discussion regarding adherence to the McGeer criteria and no documented justification by the prescriber for R5's antibiotic order.
On 01/09/2025 at 11:47 AM, the IP acknowledged there were gaps with the facility's implementation of the ASP program particularly with 1) completion of infection event tracking forms, 2) documentation of nurse-physician discussions regarding adherence to the McGeer criteria and 3) prescribers providing written justifications for antibiotic orders which went against the McGeer criteria for example prophylactic use.
On 01/09/2025 at 3:43 PM, the RDCS indicated the infection tracking forms served the purpose of confirming the presence of an infection and ensuring appropriate antibiotic use. The completion of the form allowed the facility to identify prevalence or trend of an organism, classification of drug being used or a certain physician's trend with antibiotic ordering. Based on all the information, the facility could identify practices of care by staff or providers for timely interventions and education needs, if any. The RDCS indicated the following information was expected to be completed before initiation or upon receipt of new antibiotic order:
Phase 1: infection type, site, origin, signs and symptoms, history of infection, device involved, type of diagnostic (results may be pending), and whether treatment was prophylactic or not, and order origin (ex: hospital, clinic, other nursing facility).
Phase 2: laboratory results made available. New antibiotic orders. Communication with doctors for clarification on whether orders met criteria.
Phase 3: resolution or outcome of treatment.
On 01/09/2025 at 3:53 PM, the RDCS indicated expecting the infection tracker was expected to be completed or at least phases one and two, for resident who were admitted with existing antibiotic orders. The RDCS indicated the infection event form should be initiated with basic information present prior to the start of a new antibiotic order. Phase three would be completed if the resident was still in the facility when the infection resolved.
01/09/25 03:54 PM, the RDCS reiterated the infection tracker served as a guide to ensure clinicians were following the McGeer criteria which was the criteria the facility elected to employ for antibiotic therapy. The purpose of following the McGeer criteria was to ensure antibiotics were not being misused or abused thereby preventing antibiotic resistance. The RDCS acknowledged gaps with the facility's implementation of the ASP program and identified a knowledge deficit with nursing staff and prescribers.
ASP Education for Prescribers
The ASP policy and procedure (Undated) revealed education of practitioners regarding appropriate use of antibiotics would be done by the members of the ASP team as needed but not less than annually.
On 01/09/2025 at 11:44 AM, the IP reported there were currently four physician groups who had rounding privileges in the facility. The IP confirmed there was no documentation education was provided to any of the physicians regarding the facility's ASP program and use of the McGeer criteria on an as needed basis or at minimum once a year in accordance with the facility's policy.