As skilled nursing facilities (SNFs) navigate the ever-evolving Sars-CoV-2 (COVID-19) pandemic into 2021, they will continue to face challenges on numerous fronts—from administering testing and providing optimal resident care to ensuring adequate staffing levels, pursuing reimbursement and more.

Given all that’s on your plate this year, the last thing your SNF needs is an infection prevention survey citation.

If your facility houses COVID-19 positive residents, then the mere act of reporting that opens the door to a possible infection prevention survey by your state’s Department of Jobs and Family Services. Surveys are designed to ensure total compliance with Occupational Safety and Health Administration (OSHA) and Centers for Medicare and Medicaid (CMS) rules.

A surveyor is permitted by law to present him or herself at a facility with no notice—and they must be granted access at that moment to begin the survey. Chief among the items on their list is personal protective equipment (PPE):

• The surveyor will carefully watch staff donning and doffing PPE to ensure they do so in accordance with OSHA regulations.
• They will assess whether the appropriate PPE is being worn in areas of the facility that require it.
• They will speak with the facility’s infection preventionist about training that has occurred around PPE and other infection prevention issues, as well as any issues that have been formally identified.
• They will check to see if the facility has adequate stocks of PPE.

As part of the inspection, the surveyor will also assess a facility’s testing history and protocols—specifically, whether the frequency of testing conforms to state and federal mandates.

Violations are costly; each one can generate a fine up to $55,000, and penalties can stack on top of one another. Moreover, plans of correction are mandated for each violation, and failure to provide documented proof can trigger additional fines or a temporary denial of payment.

Surveys are nothing new to SNFs; at any point in time, your facility could be subject to an annual survey (conducted once every 15 months), a complaint survey or the aforementioned infection prevention survey. Yet, damage from infection prevention surveys – both financially and from the standpoint of quality measures – can be minimized and perhaps even eliminated by following five best practice strategies:

1. Don’t incur a citation at the very moment the surveyor shows up at your door. When anyone enters a nursing home or other post-acute care facility, it is required that they have their temperature checked immediately and answer standardized COVID-19-related questions as part of a health questionnaire. Failure to do so will trigger an immediate violation. This is a basic protocol for any healthcare or senior living facility during these COVID-19 times, so make absolutely sure that anyone on staff who greets visitors follows this protocol.
2. Act like every day is the day your facility will be surveyed—that way, you’ll always be prepared. Never let anyone on staff let their guard down; they should think and act like a surveyor is watching. Not only will that prove useful when the day inevitably comes for a survey of some sort, but it’s key to keeping residents and staff safe and building a strong culture of infection prevention and control.
3. Train, train, train. Every SNF should have someone on staff – ideally an infection preventionist – and that person should be in constant training mode. Training shouldn’t happen only after a problem has been identified; it should be proactive, and feedback should be given immediately when staff are observed performing tasks incorrectly.
4. Related to that, we at Richter strongly recommend that facilities utilize a designated infection preventionist. We understand this isn’t always possible for smaller facilities, but the investment is a wise one and can pay off significantly in many ways, and at many points throughout the year.
5. Make sure your PPE game is rock-solid strong. This means:

• Ensuring adequate supplies at all times
• Having a PPE procurement plan in place, and adding it to your SNF disaster plan (related article: Emergency Preparedness for Long-Term Post-Acute Care Facilities: The Time Has Come to Add a Personal Protective Equipment Component)
• Making sure all resident-facing staff don and doff PPE properly. No deviations – even for the slightest oversight – should be permissible

To aid you in navigating issues surrounding COVID-19, we have developed a COVID-19 Resource Center for skilled nursing facilities which is regularly updated with the latest information.

Contact Richter’s Skilled Nursing Facility Consultants

Do you have questions about infection prevention surveys, or other LTPAC clinical challenges? Call Richter’s skilled nursing facility consultants at 866-806-0799 to schedule a free consultation.

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