Effective April 1st, surveyors will evaluate the use of EBP, Polaris Group suggests the implementation of 5 processes to avoid citations.
The Centers for Medicare and Medicaid Services (CMS) issued QSO-24-08-NH on March 20, 2024, regarding the implementation of enhanced barrier precautions (EBPs) in nursing homes to prevent the spread of multi-drug resistant organisms (MDROs). While EBPs were introduced by the Centers for Disease Control and Prevention (CDC) in 2019, they were not included in guidance for State Survey Agencies (SSAs). Effective April 1st, surveyors will evaluate the use of EBP when reviewing sampled residents for whom EBP are indicated and focus their evaluation of EBP use as it relates to CDC-targeted MDROs.
Key facts about EBP implementation:
- EBPs are used in conjunction with standard precautions. The guidance expands the use of personal protective equipment (PPE) during high-contact resident care activities which can result in transferring MDROs to staff hands and clothing.
- EBPs should be followed when performing transfers or assisting during bathing in a shared/common shower room and when working with residents in the therapy gym, specifically when anticipating close physical contact while assisting with transfers and mobility.
EBPs are indicated for residents with any of the following, regardless of where they reside in the facility:
- Infection or colonization with a CDC-targeted MDRO when contact precautions do not otherwise apply.
- Wounds and/or indwelling medical devices (including central lines, urinary catheters, feeding tubes, and tracheostomies).
CMS notes that facilities have some discretion when implementing EBP and balancing the need to maintain a homelike environment for residents. Residents are not restricted to their rooms or limited from participation in group activities. Because EBPs do not impose the same activity and room placement restrictions as contact precautions, they are intended to be in place for the duration of a resident’s stay in the facility or until resolution of the wound or discontinuation of the indwelling medical device that placed them at higher risk.
Effective implementation of EBP requires staff training on the proper use of PPE and the availability of PPE with hand hygiene products at the point of care.
Polaris Group's suggested implementation process:
1. Evaluate your current supply of gowns and gloves.
- Who tracks your par levels?
- Who orders supplies and what is current frequency?
- Do you anticipate obstacles in obtaining supplies timely?
2. Educate your employees about what EBP requirements mean for them, for the residents and for everyone’s safety.
- Who is required to gown and glove and do they know proper use of PPE?
- Who is not required to gown and glove.
- How will I know when to gown and glove?
3. Involve your Infection Preventionist in all angles of EBP implementation.
- How will they identify MDRO’s involved in this mandate?
- How will they communicate which resident’s care requires EBP?
- How will they track when EBP’s are no longer necessary?
4. Establish a communication board for ALL employees regarding EBP practices and daily communication.
- Every employee will be impacted by the ability to freely interact with residents, requiring them to know details of EBP practices.
- How will you communicate daily to all employees which resident is impacted by EBP requirements?
- How will you communicate with family members and visitors?
5. Integrate EBP training and competencies in facility orientation agendas.
- Add details of EBP to Relias or other platform training modules.
- Ensure EBP updates are added to annual staff training.
- Establish proper usage of PPE to staff competencies for training verification purposes.
Our Polaris Consultants are well versed in assisting facilities in all areas of infection control management. Contact us today to see how Polaris Group can help.
