Preventing CMS readmission fines due to Healthcare-Associated Infections (HAI’s)-Part II-Personal Protective Equipment

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Randy Charpentier

By Randall B. Charpentier, HEM, President/Principal Consultant: HealthSafe New England

In part II of my blogseries on CMS fines issued to hospitals for having too many patients return within a month for additional treatments, efforts to address readmissions must be ramped up.  (Blogseries IntroPart I-Hand Hygiene)

This post addresses personal protective equipment guidelines, how they are practiced, and adhered to by healthcare professionals. Personal protective equipment (PPE) utilization has been a standard practice in healthcare since the release of CDC guidelines on Universal Precautions that took effect in 1985. According to Wikipedia, Universal precautions refers to the practice of avoiding contact with patients’ bodily fluids, by means of the wearing of nonporous articles such as medical glovesgoggles, and face shields. The practice was introduced in 1985–88. In 1987, the practice of universal precautions was adjusted by a set of rules known as body substance isolation. In 1996, both practices were replaced by the latest approach known as standard precautions. Use of PPE is now recommended in all health settings.

As mentioned above, the typical PPE utilized in healthcare consists of medical gloves, goggles and a face shield to protect against contact with bodily fluids/body substances. I would add safety eyewear with sideshields, protective gowns and surgical masks latex glovescommonly referred to in the safety world as particulate/air purifying respirators (APR’s) to that list. Most healthcare facilities do an exemplary job of training staff on the utilization of PPE with Standard/Universal Precautions, but do they elevate their level of training with other types of PPE? If you noted the timelines involved with the CDC revised updates, it involved a 10 year span which is typical of governmental action. If you are responsible for OSHA compliance, that time frame is consistent with their regulatory updates.

The federal government is very slow to react to business change as was evidenced shortly after the adoption of Standard Precautions when latex allergies appeared as a common ailment for healthcare workers commonly used at the time to prevent contact with body substances/fluids. This created a stir in the industry, produced countless workers compensation claims/personal injury suits and to this day latex products are not as common as they once were and have been replaced with nitrile and pvc products.

Since that time period, we have successfully confronted TB, HIV/AIDS, H1N1, Avian Bird Flu, SARS and , Anthrax etc. with Standard Precautions and enhanced PPE such as HEPA filtered Respirators & N95’s (APR’s), Powered Air Purifying Respirators or PAPR’s, Tyvek Full Body Suits in some of the larger academic/teaching hospital facilities. I can personally attest to this because I fit tested and trained over 500 clinicians and support staff when a former facility admitted a TB/HIV positive patient who was transferred to the facility for a liver transplant. The training on PPE and fit testing required hands on time of approximately 1000 man hours with the initial patient, and another 2000 over the course of a year to prepare the entire organization for this level of protection.   The training and preparation paid off as there were no documented cases of patient to staff transmission of any type while I was in charge of the program. This technology and level of protection has been widely used routinely in other industries since the 1980’S, and in others dating back before that time period.

120px-Globe.svgIn today’s global economy, there is no telling what infectious disease will appear on our soil or in our hospitals. All healthcare facilities should have designated and trained staff in all high risk departments, and other points of entry to quickly isolate a patient and protect staff, patients and visitors from becoming a transmission source regardless of risk of contact or airborne exposure. This shouldn’t be a problem considering that all healthcare facilities should have personnel on staff who have received at least 40 hour or equivalent OSHA (Hazwoper/Asbestos/Lead/Formaldehyde-Formalin) training for compliance with CMS/TJC requirements regarding their potential exposures to chemicals, asbestos, lead, and other contaminants they may be occupationally exposed to with their Emergency Management Program, Hazardous Materials-Chemical Spill Responses, and routine Facility Maintenance Plans. (The Hazardous Waste Operations and Emergency Response Standard [HAZWOPER]

So when Ebola appeared in our country, I was appalled to hear and see facilities state that they were unprepared to deal with this virus and blamed the CDC for lack of guidance. If healthcare facilities do not adequately prepare their organizations for the next virus that appears on our soil, the outcome may be catastrophic. As you can see above, the regulators take an enormous amount of time to provide guidance to the healthcare industry, especially in times of crisis.

For clinical staff, when a patient is placed in negative pressure isolation, it may be appropriate to escalate their training to the CDC guidelines issued for Ebola. They may not need that level of PPE, but their awareness level will be elevated and they will have opportunities to perfect their technique. One area of improvement for non-clinical staff, especially Facilities and Environmental Services, is to escalate training equivalent to OSHA requirements orientation or overview training which is common/standard practice in most facilities. They are exposed to the highest degree of indirect or non -incidental contact with surfaces, equipment-facilities related or medical, bedding/gowning/soiled materials, waste, furnishings/furniture, etc. that may have a degree of contamination that is infectious.

It may be time for healthcare facilities to increase their prevention efforts to protect patients, staff and visitors from HAI’s and other preventable incidents, injuries and illness.

Randall Charpentier is a 20 year experienced, safety and risk management consultant specializing in healthcare compliance and best practice management. Project experience ranges from leading teams on the construction of the west coast space shuttle project, working internationally & domestically for leading environmental engineering firms conducting real estate assessments involving occupational and environmental risks, assessing business operational risks concerning commercial insurance policies, and reducing/eliminating exposures/hazards, to leading world renowned, top ten/one hundred community based & BioMedical Research/Teaching hospitals, with development and execution of best practices with EOC, Fire/Life Safety, Infection Prevention in Healthcare Construction, and Emergency Management programs.  HSNE’s/Randall’s passion is keeping patients, staff and visitors safe in a healthcare setting.  CMS is measuring safety and quality in healthcare facilities basing reimbursement on healthcare outcomes. Does your facility measure up? If not, you should conduct a risk assessment. Is your facility compliance or results driven? To find out, contact or, or LinkedIn profile.

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