It is no secret that Long Term Care facilities, including Skilled Nursing Facilities as well as assisted living centers, have seen a challenging couple of years in the wake of the COVID pandemic. Now, to complicate matters even more, the Centers for Medicare and Medicaid Services (CMS) have issued new guidelines for evaluators to use when doing regulatory compliance inspections. Specifically, this June 29, 2022 CMS Fact Sheet states, “CMS is issuing surveyor guidance which clarifies specific regulatory requirements and provides information on how compliance will be assessed.”
They include reference to State agencies as well, stating, “In addition, CMS is revising its guidance to State agencies, to strengthen the management of complaints and facility reported incidents.”
When does the new guidance go into effect?
The new guidance to surveyors is to go into effect as of Oct 24, 2022. In addition to ten other topics with “significant changes”, the new CMS Guidance specifically addresses Infection Control.
Under the topic heading of Infection Control is the following:
- Requires facilities have a part-time Infection Preventionist (IP).
- While the requirement is to have at least a part-time IP, the IP must meet the needs of the facility.
- The IP must physically work onsite and cannot be an off-site consultant or work at a separate location.
- The IP role is critical to mitigating infectious diseases through an effective infection prevention and control program. (Emphasis is ours)
- IP specialized training is required and available.
What this means is that each location is to have an Infection Preventionist physically present on site at least part-time, but on site enough to meet the needs of that particular facility. In addition, that Infection Preventionist must have and implement an infection prevention and control program that is “effective”. (emphasis ours) How the effectiveness of the prevention and control program is to be determined is not specifically spelled out.
This Revised Long-Term Care Surveyor Guidance may serve as a guide to the on-site LTC Infection Preventionist as to what the site surveyors will be looking for to assure compliance with the CMS regulations.
Also, we have pulled together a list of references which we believe will assist the Infection Preventionist in the task of developing and implementing an effective infection prevention and control program.
Here is a list of links to presentations by independent, non-governmental, sources that we think may be helpful:
In addition, we have also pulled together a list of links to the Centers for Disease Control and Prevention (CDC) articles which you may also find helpful.
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