Blog: CMS Infection Control Precaution Mandate

On March 20, 2024, CMS issued a memorandum (Ref: QSO-24-08-NH) providing new guidance for state survey agencies in long-term care (LTC) facilities on Enhanced Barrier Precautions (EBP) to better align with nationally accepted standards. This updated guidance has been incorporated into the F880 Infection Prevention and Control tag effective April 1, 2024. 

Conditions included: 

  • Chronic wounds
  • Indwelling medical devices
  • Infection or colonization with a CDC-targeted MDRO when Contact Precautions do not otherwise apply 

When to use EBP with these conditions: 

  • During high-contact resident care activities
    • Dressing
    • Bathing/showering
    • Transfers requiring close contact and prolonged activity (not required in common areas such as dining rooms or activities)
    • Providing hygiene
    • Changing linens
    • Changing briefs or assisting with toileting
    • Device care or use; central line, urinary catheter, feeding tube, tracheostomy/ventilator
    • Wound care (any skin opening requiring a dressing)
  • Regardless of their multidrug-resistant organism (MDRO) status 

What EBPs are required? 

  • Gown and glove use (may not be required prior to entry)
  • Note: PPE and alcohol-based hand rub must be readily accessible to staff 

Why? 

  • Research in June 2021 resulted in findings of more than 50% of nursing home residents “may” be colonized with an MDRO
  • This serves as a guideline to surveyors when evaluating the use of EBP in SNFs in effort to prevent the spread of MDROs 

For consideration: CMS does note the need for discretion in effort to maintain a homelike environment and specifically states this does not restrict residents to their rooms or limit them from participation in group activities or therapy in a gym. 

Additional information can be found on the CDC’s webpage, “Implementation of Personal Protective Equipment (PPE) Use in Nursing Homes to Prevent Spread of Multidrug-resistant Organisms (MDROs).”  

The Point Is: Understanding the surveyor guidelines rationale and expectations is critical to successfully maintaining infection control compliance and avoiding penalty-loaded Ftags. 

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