A Closer Look into Conditions for Coverage

Over the next few months, Renal Business Today will dissect Medicare's Conditions for Coverage, which set the rules under which dialysis clinics must operate. Also, visit www.renalbusiness.com to take the Summer Education Series quiz about these new requirements.

Infection is the second leading cause of death in U.S. dialysis patients. This makes it vital for dialysis clinics to do as much as they can to prevent the spread of infection through policies and practices. The Centers for Medicare & Medicaid Services recognized this as well in its updated dialysis conditions for coverage, which must be met in order for a clinic to be financially reimbursed by the government.

The Medicare dialysis rules were first set in 1976 and were not updated until the new Conditions for Coverage were released in early April. The new conditions will be effective Oct. 14. In its final rule for infection control, CMS states, “The dialysis facility must provide and monitor a sanitary environment to minimize the transmission of infectious agents within and between the unit and any adjacent or other public areas.”

Whittling down that broad statement into something more workable, CMS said, “We proposed that dialysis facilities implement appropriate procedures for patient isolation; for the handling, storage and disposal of waste; and the disinfection of surfaces, devices and equipment.”

The CDC Guidelines

Many of the infection control conditions in the final rule are based on the Centers for Disease Control and Prevention’s guidelines named, “Recommendations for Preventing Transmission of Infections Among Chronic Hemodialysis Patients.” (see sidebar)

Interestingly, because the CDC document is a guideline, the word “should” is peppered throughout the text. One commenter asked CMS if this meant the CDC guidelines aren’t mandatory as a result. CMS cleared this up by writing in the rule that the CDC infection control precautions “are mandatory and must be adhered to and demonstrated within the dialysis facility.”

The CDC infection control precautions state that items taken into the dialysis station should be disposed of, dedicated for use only on a single patient, or cleaned and disinfected before being taken to a common clean area or used on another patient.

Furthermore, anything that can’t be cleaned or disinfected—such as adhesive tape, cloth-covered blood pressure cuffs—should be used only once. The rules also said dialyzers being carried to a reuse room need to be transported in a leak-proof container, such as a plastic bag, in order to prevent cross-contamination.

One person commented to CMS that staff should have immediate access to gloves in case a patient suddenly starts to bleed and that staff should be allowed to carry extra gloves in their pockets in case that happens. The CDC precautions, however, do not allow that and say the facility should have gloves strategically placed so staff can get to them in routine and emergency situations.