A Closer Look into Conditions for Coverage

Infection Control Miscellaneous

CMS said clinics need to analyze and document the incidence of infection to identify trends, establish baselines, take actions to reduce future infection control incidents, and report incidents of communicable diseases as required by federal state and local regulations.

Elsewhere, CMS wrote that scrubs or uniforms are okay to use in the dialysis clinic, except when staff may be exposed to blood splattering. In such a case, the conditions said cover gowns should be used in order to reduce blood exposure to staff.

As for medications, “Intravenous medication vials labeled for single use, including erythropoietin, should not be punctured more than once,” according to the CDC infection control guidelines. “Once a needle has entered a vial labeled for single use, the sterility of the product can no longer be guaranteed. Residual medication from two or more vials should not be pooled into a single vial.”

The Infection Control Officer

CMS originally proposed appointing a nurse to be an infection control officer, who would oversee the facility’s infection control program. However, there were many concerns over which professional would be best for the position and also cost concerns. In addition, the nursing shortage posed staff and time issues.

Given the concerns, CMS scrapped the idea and instead added infection control to the condition under quality assessment and performance improvement (QAPI). In addition, the conditions require that clinical staff report infection control issues to the medical director and the quality improvement committee instead of the chief executive officer or administrator. “The medical director has a critical role in addressing infection control issues in the dialysis facility,” CMS wrote, and added that the new conditions require “the medical director to ensure that staff adheres to infection control policies and procedures.” RBT

Web Resources for Condition Guidelines

Recommendations for Preventing Transmission of Infections Among Chronic Hemodialysis Patients: www.cdc.gov/mmwR/preview/mmwrhtml/rr5005a1.htm

Guidelines for the Prevention of Intravascular Catheter-Related Infections: www.cdc.gov/mmwr/preview/mmwrhtml/rr5110a1.htm