Nursing Home Requirements of Participation and the Role of the Infection Preventionist
The Centers for Medicare and Medicaid Services (CMS) is providing guidance for nursing homes and surveyors to implement the Phase 3 Requirements of Participation (RoPs), including guidance related to the requirement for all facilities to have an Infection Preventionist (IP), which has been underscored by the COVID-19 pandemic.
Per CMS QSO-22-19-NH, issued on June 29, 2022:
Revisions include guidance for implementing Phase 3 regulations which require nursing homes to have an Infection Preventionist (IP) who has specialized training onsite at least part-time to effectively oversee the facility’s infection prevention and control program (IPCP). This revision will strengthen our general infection control guidance to address frequently cited issues such as hand hygiene, transmission-based precautions, and surveillance of infectious diseases. While the requirement is to have an IP at least part-time, facilities are responsible for an effective IPCP and should ensure the role of the IP is tailored to meet the facility’s needs. With emerging infectious disease such as COVID-19, CMS believes the role of the IP is critical in the facility’s efforts to mitigate the onset and spread of infections. Additionally, CDC and CMS developed specialized IP training to include topics such as Transmission Based Precautions and Antibiotic Stewardship programs (ASP).
Lastly, to increase survey efficiency, we incorporated the review of COVID-19 requirements to the survey software for the following deficiencies: F-tag 885 (Reporting Coronavirus Disease 2019 (COVID-19) data to residents, their representatives, and families), F-tag 886 (COVID-19 testing of residents, and staff), F-tag 887 (offer/educate Page 5 of 6 on COVID-19 immunization) and F-tag 888 (Health Care Staff Vaccination Requirements).
The IP requirement provides that a facility must have an IP at least part-time, and the IP must be able to meet the needs of the resident population. The Facility Assessment nursing home regulation, effective Nov. 28, 2017, requires that a facility must conduct and document a facility-wide assessment to determine what resources are necessary to care for its residents competently during both day-to-day operations and emergencies. The facility must review and update that assessment as necessary and at least annually. It must also review and update this assessment whenever there is, or whenever it plans for, any change that would require a substantial modification to any part of this assessment. Therefore, if the infection rate increases in a facility, such as during a COVID-19 outbreak, the IP must increase hours in the facility to designate toward the needs of the residents in the facility.
Per the updated State Operations Manual (SOM) that will be used beginning in October 2022 (Appendix PP, pages 774-779), the IP must have primary professional training in nursing, medical technology, microbiology, epidemiology, or other related field; be qualified by education, training, experience, or certification; and have completed specialized training in infection prevention and control. The updated Appendix PP further states:
- A professionally trained nurse must have earned a certificate/diploma or degree in nursing.
- A professionally trained medical technologist (also known as clinical laboratory scientist) must have earned at least an associate's degree in medical technology or clinical laboratory science.
- A professionally trained microbiologist must have earned at least a bachelor's degree in microbiology.
- A professionally trained epidemiologist must have earned at least a bachelor's degree in epidemiology.
- Examples of other related fields of training that are appropriate for the role of an IP include physicians, pharmacists, and physician's assistants.
The updated Appendix PP also provides a description of the recommended types of experience, specialized training, and certifications for the IP and the factors that should be considered in determining the hours of work of the IP. The IP must be a member of the facility’s quality assessment and assurance committee and report to the committee on the infection prevention and control program (IPCP) on a regular basis.
The Centers for Disease Control and Prevention (CDC) has created an online training course for the IP. This is a 24-module course and is free of charge to qualified persons interested in becoming certified in infection prevention. To access the training site, click here.
Surveyors will begin surveying on the requirement on Oct. 24, 2022. Important resources for facilities include the following:
- QSO-22-19-NH, which outlines the significant revisions to Chapter 5 of the SOM;
- CMS fact sheet, which provides a quick reference for the upcoming changes; and
- Revised surveyor guidance, which provides several updated guidance documents the surveyors will use when surveying on these new RoPs.
If you have further questions, please feel free to contact any member of the Policy team.
Contact: Amy Nelson, anelson@leadingageny.org, 518-867-8383 ext. 146