On November 28, 2019, CMS implemented the role “Infection preventionist” for long term care facilities as defined in F882. This term is used for the person(s) designated by the facility to be responsible for the infection prevention and control program and requires specific, individual, detailed training, qualifications, and hourly requirements as described below:
- The Infection Preventionist (IP) must have primary professional training in one of the following:
- Medical technology
- or a related field
- The IP must be qualified by education, training, certification or experience
- The IP needs to work at least part-time at the facility; and
- The IP must have completed specialized training in Infection Prevention and Control
The individual designated as the IP, or at least one of the individuals if there is more than one, must be a member of the facility’s QAA Committee and report on the Infection Prevention and Control Program on a regular basis.
It is to be noted that in the CMS bulletin on May 6, 2020, the COVID-19 Focused Survey for Nursing Homes does not include F882 as one of the tags to be investigated. However, on June 1st the memorandum included “providing guidance for the limited resumption of routine survey activities”.
On May 13, 2020 during this COVID-19 Pandemic, Dr. Nimalie Stone from the CDC discussed the role of the Infection Preventionist with her recommendation for a full-time IP position during the COVID-19 response. Her rationale for this included:
- Need for more surveillance
- Screening of residents and staff with review to be sure there is early detection of new cases.
- Need for reinforcement of the infection prevention practices through the observation on the units, coaching and “just-in-time” training for front line staff and environmental and housekeeping staff.
- There is a lot of stress in buildings with new, unfamiliar equipment, staffing challenges, fatigue, and long hours.
On May 19, 2020 the CDC in the Preparing for COVID-19 in Nursing Homes, added a recommendation to “assign an individual to manage the facility’s infection control program” as one of the Core Practices that should remain in place even as nursing homes resume normal activities:
Assign One or More Individuals with Training in Infection Control to Provide On-Site Management of the IPC Program.
- This should be a full-time role for at least one person in facilities with more than 100 residents or that provide on-site ventilator or hemodialysis services. Smaller facilities should consider staffing the IPC program based on the resident population and facility service needs identified in the facility risk assessment.
- CDC has created an online training course that can be used to orient individuals to this role in nursing homes.
With all the changes happening during the COVID-19 Pandemic, it is more critical than ever that you, the front line caregivers, stay current with the CDC and CMS updates. Please refer to the HealthCap Risk Management COVID-19 portal for current updates. Thanks for all you do, stay well and as always, stay tuned!
State Operations Manual Appendix PP; November 22, 2017; https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/downloads/som107ap_pp_guidelines_ltcf.pdf
Infection Prevention Training; July 10, 2019; https://www.cdc.gov/longtermcare/training.html
Interim Final Rule Updating Requirements for Notification of Confirmed and Suspected COVID-19 Cases Among Residents and Staff in Nursing Homes; May 6, 2020; https://www.cms.gov/files/document/qso-20-29-nh.pdf
COVID-19 Survey Activities, CARES Act Funding, Enhanced Enforcement for Infection Control deficiencies, and Quality Improvement Activities in Nursing Homes; June 1, 2020; https://www.cms.gov/files/document/qso-20-31-all.pdf
Preparing for COVID-19 in Nursing Homes; May 19, 2020; https://www.cdc.gov/coronavirus/2019-ncov/hcp/long-term-care.html