Failure to Follow Enhanced Barrier Precautions and Hand Hygiene During Incontinence and Wound Care
Summary
The deficiency involves the facility’s failure to follow its own infection prevention and control policies for Enhanced Barrier Precautions (EBP) and hand hygiene during incontinence and wound care. The facility’s EBP policy required staff to wear gowns and gloves for high-contact resident care activities such as changing briefs, assisting with toileting, and wound care for residents placed on EBP. The hand hygiene policy required hand hygiene after handling contaminated objects, before and after PPE use, after handling items potentially contaminated with body fluids, and when moving from a contaminated to a clean body site, and specified that glove use does not replace hand hygiene. Despite these policies, multiple staff members did not use required PPE or perform hand hygiene as required during observed care. In two separate observations of incontinence care for a resident on EBP with a wound and MDRO in the urine, staff failed to wear gowns and, in one instance, failed to change gloves and perform hand hygiene after contact with stool and soiled items. In the first observation, a nurse aide and a medication aide entered the resident’s room, noted to have an EBP sign requiring gown and gloves for high-contact care, but only washed their hands and donned gloves without gowns. The nurse aide cleaned stool from the resident’s buttocks using both hands, then, without removing gloves, reached into the resident’s drawer for moisture barrier cream and applied it to the buttocks and abdominal fold. She removed the soiled brief and drawsheet, placed them at the foot of the bed, then placed a clean brief and drawsheet and completed the incontinence care. She then removed only one glove, carried the soiled items to the soiled utility room with the other gloved hand, disposed of them, removed the remaining glove, and washed her hands. Both the nurse aide and medication aide later stated they did not notice or pay attention to the EBP sign and acknowledged they should have worn gowns; the nurse aide also acknowledged she forgot to remove gloves and perform hand hygiene after cleaning stool. In the second incontinence care observation for the same resident on EBP, two nurse aides again entered the room without gowns despite the EBP sign requiring gown and gloves for high-contact care. They washed their hands and donned gloves only, then unfastened the resident’s brief and performed perineal and buttock cleansing with disposable wipes. One aide removed her gloves and washed her hands, then donned new gloves and assisted with transferring the resident using a total mechanical lift. After positioning the resident in a wheelchair, both aides removed their gloves and washed their hands. Both aides later reported they did not see or were not paying attention to the EBP sign and stated they knew gowns and gloves were required for incontinence care for residents on EBP. Additional deficiencies were observed in wound care performed by the Treatment Nurse for two residents. During wound care for a resident with multiple pressure ulcers on the left posterior thigh, left buttock, and right heel, the Treatment Nurse donned a gown and gloves, removed dressings from multiple wounds, and wiped the buttock without changing gloves or performing hand hygiene between wounds. She removed gloves and donned new ones without hand hygiene, then cleansed each wound sequentially with gauze moistened with wound cleanser, again without changing gloves between wounds. After another glove change without hand hygiene, she applied calcium alginate and dressings to each wound in sequence without changing gloves or performing hand hygiene between sites, then completed incontinence care and repositioning before removing PPE and washing her hands. The Treatment Nurse later stated she knew she was supposed to perform hand hygiene before and after wound care, after discarding used items, and after removing gloves and before applying new gloves, and acknowledged she should have used separate gloves and treated each wound separately. In a separate wound care observation for another resident with a sacral pressure ulcer, the Treatment Nurse washed her hands, donned a gown and gloves, and set up supplies. She touched the trash can with a gloved hand to move it closer, then removed her gloves and donned new gloves without performing hand hygiene. She removed the old sacral dressing with moderate light brown drainage, cleansed the wound with gauze moistened with wound cleanser, then again removed gloves and donned new gloves without hand hygiene before applying collagen to the wound bed and covering it with a hydrocolloid dressing. She then adjusted the resident’s brief and pillow, removed her gown and gloves, and washed her hands. In an interview, the Treatment Nurse reiterated that she knew hand hygiene was required before wound care, after the procedure, after discarding used items, and between glove changes, but stated she had forgotten to bring hand sanitizer and that there was no hand sanitizer in the rooms. The DON, who also served as the Infection Preventionist, confirmed that residents with catheters, feeding tubes, central lines, open wounds, or MDROs were placed on EBP and that staff were expected to wear gowns and gloves for care, and acknowledged that the observed staff did not follow EBP and hand hygiene requirements during the cited care episodes.
Penalty
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Below are regulatory guidelines relevant to this citation:
A resident with a chronic heel wound with drainage, classified as high risk under the facility’s Enhanced Barrier Precautions (EBP) policy, received wound care from a Wound Nurse and a NA who wore masks and gloves but did not don gowns during multiple high-contact wound care activities on both lower extremities. The facility’s EBP policy requires both gloves and gowns for high-contact care, including wound care, for residents with chronic wounds. At the time of care, there was no EBP sign on the door and no PPE caddie or supplies outside the room. In subsequent interviews, the Wound Nurse and NA reported they did not wear gowns because there was no sign on the door and the nurse was not wearing one, while the IP and DON stated they would have expected gown use and confirmed that wound care is considered a high-contact activity under the policy.
Staff failed to consistently implement and follow Enhanced Barrier Precautions (EBP) during wound care for two residents. For a resident with an indwelling urinary catheter and an EBP order, an RN and a CNA removed their gowns after catheter care and performed a heel and toe dressing change wearing only gloves, despite a door sign requiring gown and gloves for wound care and other high-contact care. For another resident with multiple open leg wounds and active wound care orders, an RN and a nurse aide performed dressing changes with gloves only, without gowns, and there was no EBP signage or order in place. Interviews with nursing staff, the IP, and the DON revealed inconsistent understanding and application of the facility’s EBP policy, which requires gown and gloves for high-contact care activities, including wound care and device care, for residents with chronic wounds or indwelling devices.
The facility failed to fully document infection surveillance and RTW decisions during a COVID outbreak. Multiple staff members reported symptoms such as sore throat, headache, congestion, diarrhea, vomiting, fever, and cough, but the employee illness logs were incomplete and left the RTW date blank, with no indication they were tested for COVID or cleared per CDC guidance. At the same time, multiple residents were diagnosed with COVID and others had GI symptoms with unknown testing status. The IP said she worked infection control only a few hours per week and had not thoroughly reviewed the logs for trends, while the DON had not been reviewing the surveillance logs.
Cross contamination occurred during a dressing change when an LPN placed a resident’s foot directly on the wheelchair seat without a barrier and did not clean the bedside table after the procedure. The facility also lacked infection surveillance documentation for several months, and its Legionella water management plan was incomplete, with no mapping of high-risk areas, no temperature logs, and no documented preventive measures for unused areas.
Infection Control Failures During Resident Care: Staff did not follow PPE, hand hygiene, and equipment-cleaning practices during care for several residents. An RN failed to clean a glucometer and basket after blood sugar checks, a CNA and a Central Supply staff member entered rooms with enhanced barrier precautions without PPE, and an LVN did not clean the glucometer or insulin vial, and did not properly perform hand hygiene during insulin administration and after emptying a urinal. Residents involved had significant cognitive impairment, diabetes, wounds, and other serious diagnoses.
Infection control failed during laundry services when staff reported using the same personal T-shirt for handling dirty laundry and then hanging clean laundry, while using disposable gowns only for laundry from a resident with an infection. The DON also acknowledged that the Infection Prevention Program policy was overdue for annual review, and the policy showed no indication of an annual review.
Failure to Follow Enhanced Barrier Precautions During Wound Care
Penalty
Summary
The deficiency involves the facility’s failure to implement its Infection Control policies and procedures for Enhanced Barrier Precautions (EBP) during wound care for a resident. The facility’s EBP policy, last revised on 04/15/26, requires staff to don both gloves and a gown for high-contact care activities with high-risk residents, including those with chronic wounds. High-contact activities listed in the policy include wound care, and the policy specifies that residents with chronic wounds should remain on EBP for the duration of their stay or until the wound resolves. Resident #12 was admitted with a chronic heel wound with drainage, placing the resident in the high-risk category under the EBP policy. During an observation of wound care on 05/12/26 at 12:33 PM, the Wound Nurse and Nurse Aide (NA) #1 entered the resident’s room wearing masks and gloves but no gowns. There was no EBP sign on the door and no PPE caddie or supplies outside the room. The resident was seated in a wheelchair beside the bed with the door open. The Wound Nurse performed multiple wound care steps on the resident’s right leg, right heel, left third toe, and left heel, repeatedly donning and doffing gloves and performing hand hygiene, while NA #1 assisted by holding the resident’s legs. At no point during these high-contact wound care activities did either staff member wear a gown. In interviews following the observation, the Wound Nurse stated he did not wear a gown because there was no sign on the door indicating the resident was on EBP and later acknowledged learning that a gown should have been worn. NA #1 similarly reported that she did not wear a gown because there was no sign on the door and the Wound Nurse was not wearing one, and she later learned that both should have worn gowns. The Infection Preventionist (IP) stated that the resident should have had an EBP sign on the door and a PPE caddie available, and explained that the sign and supplies were likely left on the resident’s previous room after a move. The IP and the Director of Nursing both stated they would have expected the Wound Nurse and NA #1 to wear gowns while providing wound care, and the DON identified wound care as a high-contact activity requiring gown use under the facility’s EBP policy.
Failure to Implement and Follow Enhanced Barrier Precautions During Wound Care
Penalty
Summary
Surveyors identified a deficiency in the facility’s infection prevention and control program related to improper use and implementation of Enhanced Barrier Precautions (EBP) during wound care. One resident with an indwelling urinary catheter had an active order and care plan for EBP, and a door sign specifying that gown and gloves were required for high-contact resident care activities, including wound care and device care. During an observation, an RN and a CNA entered this resident’s room, performed hand hygiene, donned gown and gloves, and completed catheter care in accordance with the posted EBP instructions. However, after completing catheter care, the RN instructed the CNA that they could remove their gowns because EBP was “only for the catheter,” and both staff removed their gowns and gloves, performed hand hygiene, and then donned only clean gloves to perform a dressing change on the resident’s right heel and pinky toe, despite the door sign indicating gown and gloves were required for wound care. A second resident had multiple open wounds on both lower extremities that required cleansing, application of collagen with wound gel and alginate, and coverage with border gauze dressings. Progress notes documented that these wounds originated as skin tears and were slowly healing, and active wound care orders were in place. During an observation of wound care for this resident, an RN and a nurse aide performed hand hygiene and donned gloves but did not wear gowns. There was no EBP sign or PPE set up outside the room, and there was no order for EBP in the electronic medical record, even though the resident had open wounds requiring dressing changes. In interviews, the RN stated that EBP was required for chronic wounds such as pressure, venous, and arterial wounds, and that EBP for the first resident applied only to catheter care. The CNA reported that she relied on the door sign and believed she only needed to gown for catheter care, brief care, or toileting, and not for transferring if she was not in contact with the catheter. The Infection Preventionist explained that EBP was used for chronic wounds and indwelling devices and stated that staff would only need to gown when providing care to the Foley catheter, while the DON stated that EBP was for residents with devices or dressing changes to prevent MDROs and that staff should wear gown and gloves even when not providing direct catheter care. The facility’s written EBP policy specified that EBP applies to residents with chronic wounds and/or indwelling medical devices and that PPE for EBP is necessary when performing high-contact care activities, including wound care and medical device care, which was not consistently followed in the observed wound care encounters.
Incomplete COVID Surveillance and Return-to-Work Tracking
Penalty
Summary
The facility failed to ensure its infection prevention and control program documented employee illness monitoring, testing, and return-to-work decisions during a COVID outbreak. The report states that 7 of 9 staff members with symptoms of COVID were not documented as having been tested, their illnesses were not tracked to identify possible links between resident COVID cases and staff exposure or subsequent illness, and there was no indication when they could return to work according to CDC guidance. The January 2026 resident infection surveillance log showed 12 residents diagnosed with COVID during the outbreak and exhibiting symptoms including cough, runny nose, congestion, and wheezing. Five additional residents had loose stools and vomiting, but it was unknown whether they had been tested or found positive for COVID. The January 2026 employee illness log showed multiple staff call-ins for symptoms including sore throat, headache, congestion, dizziness, lightheadedness, diarrhea, vomiting, fever, sinus congestion, and cough, but the logs were not completed fully and the date returned to work was left blank each time. The infection preventionist stated she had been in the role for less than a year, worked infection control only 4 to 5 hours per week depending on staffing, and transferred staff illness information from the business office into the employee illness logs. She said staff were to be off work for at least 24 hours after vomiting, fever, or diarrhea resolved, but she had not thoroughly completed the surveillance logs or looked for trends or patterns. The DON stated she reviewed the IP's monthly data before QAPI meetings but had not been reviewing the surveillance logs since the new IP started. The facility's infection control and surveillance policies described monitoring infections for trends and managing infections through education and record keeping, and the return-to-work policy included guidance for suspected or confirmed COVID, but the report states there was no indication this return-to-work process followed CDC guidance.
Cross Contamination During Dressing Change and Infection Control Program Deficiencies
Penalty
Summary
Cross contamination occurred during a dressing change for Resident R24. The resident was admitted to the facility and had diagnoses including peripheral vascular disease and diabetes. A physician order dated 4/27/26 directed the right lateral foot to be cleansed with normal saline, patted dry, treated with Santyl ointment, and covered with a dry dressing daily and as needed. During observation of the dressing change on 5/5/26, the LPN prepared a clean area on the resident’s over-bed table with a barrier and supplies, cleansed the foot, then placed the resident’s right foot directly on the wheelchair seat without placing a barrier before applying the ointment and dressing. After the dressing was completed, the LPN gathered and discarded supplies, removed the barrier from the over-bed table, and exited the room. During interview, the LPN confirmed that a clean barrier had not been placed on the wheelchair seat before the resident’s foot was placed there and confirmed that the bedside table was not cleaned after the supplies and barrier were removed. The LPN also confirmed the failure to prevent cross contamination during the dressing change. The facility also failed to maintain infection control surveillance for three months, as the infection control documentation did not show tracking of resident infections for February 2026, March 2026, and April 2026. When asked about the surveillance system, the RN who had taken over the program stated she had not done anything since taking over on 4/4/26 and had not looked at the infection control binders. The NHA confirmed the facility failed to implement an infection control program that included a system of surveillance to identify possible communicable diseases or infections for those months. In addition, the facility’s Legionella water management plan lacked mapping of high-opportunity areas, water temperature logs, and evidence of preventive measures for areas not in use, and staff could not provide logs or explain required temperatures during interviews.
Infection Control Failures During Resident Care
Penalty
Summary
The facility failed to maintain an infection prevention and control program for multiple residents during observed care and record review. Resident #7 had a diagnosis of type 2 diabetes mellitus and a BIMS score of 4, indicating severely impaired cognition. During an observation, RN A used a small amount of hand sanitizer for only a few seconds, checked the resident’s blood sugar, and did not clean the glucometer before placing it in the medication cart. RN A also used a purple basket to carry glucometer supplies into the resident’s room, placed it on the bedside table, and did not clean the basket before returning it to the medication cart. RN A stated the glucometer should be sanitized before and after each use and that not doing so could put the resident at risk of infection. Resident #32 had severe cognitive impairment and multiple injuries, including intracerebral hemorrhage, subarachnoid hemorrhage, fractured rib, fractured lower leg, fractured spine, and surgical and traumatic wounds. The care plan included enhanced barrier precautions. During observation, the resident’s room had an enhanced barrier precautions sign and the PPE station outside the door had only one glove and one gown. CNA A assisted with removing a brace from the resident’s right arm without using any PPE. CNA A stated that any time there was a PPE station, staff were supposed to use the PPE and that failing to do so could transfer something to another resident. Resident #95 had diagnoses including breast cancer, Asperger’s syndrome, protein-calorie malnutrition, anxiety, and hypokalemia, and the care plan directed staff to use gown and gloves during high-contact care activities that could transfer MDROs. During observation, the resident’s door had an enhanced barrier precautions sign, but staff entered the room without PPE while Central Supply assisted with pulling the resident up in bed. Central Supply stated PPE was required any time patient care was provided to the resident. Resident #101 had type 2 diabetes mellitus and an insulin order for lispro before meals for high blood sugars. During observation, LVN D did not perform hand hygiene before putting on gloves, did not clean the glucometer before checking the resident’s blood sugar, did not clean the top of the insulin vial before withdrawing insulin, performed hand hygiene for less than 5 seconds and did not cover the backs of her hands, and did not properly perform hand hygiene after emptying the resident’s urinal. LVN D also did not clean the glucometer or tray before placing them in the medication cart.
Infection Control Lapses in Laundry Services and Policy Review
Penalty
Summary
The facility failed to ensure appropriate infection control during laundry services and failed to review its Infection Prevention Program policy annually. During a laundry room tour and interview, other staff stated they put a personal T-shirt on over their clothes when handling dirty laundry and used the same T-shirt when hanging clean laundry. They also stated they used disposable gowns when handling laundry from a resident with an infection, but had no concerns about wearing the same clothing for clean and dirty laundry if the resident did not have an infection. The director of maintenance stated the facility used an external company for on-site laundry and housekeeping services and believed laundry staff wore gloves and a gown when handling dirty laundry, but was not concerned if no gown was worn as long as staff clothing did not touch the dirty clothing. The Bywood East Infection Control and Prevention Program policy dated 4/26/24 had no indication of an annual review, and the DON stated the infection prevention program policy was overdue for review.
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