Antibiotic Stewardship got the Headlines, but CMS Proposed Nursing Home Reg may Completely Transform Infection Control Programs

July 23rd, 2015

While requiring antibiotic stewardship programs in long term care has drawn the most reaction to a new CMS proposed rule, a sweeping upgrade of infection control programs in nursing homes could be the real game changer in the proposed regulation.

Specifically, the draft CMS regulation would require long term care facilities to designate an “Infection Prevention and Control Officer (IPCO)” with specialized training to have the “major responsibility” for managing a newly defined “Infection Prevention and Control Program (IPCP).” The requirements for specialized training and making infection prevention the primary duty of a single person address two longstanding concerns in long term care. These settings may be lax in infection control training, and program oversight is often diluted by giving the job to staff who have competing responsibilities.

“We understand that infection control is often assigned to a nurse who may have other administrative or patient care responsibilities,” the CMS states in the proposed rule. “We want to allow sufficient flexibility for facilities … but also ensure that an IPCO has the time and resources necessary to properly develop, implement, monitor and maintain the IPCP for the facility. Thus we require that the IPCP be a major responsibility for the individual assigned as the facility’s IPCO.”

In adding the specialized training requirement, the CMS comes very close to describing the Certified in Infection Control (CIC) professional licensure designation of hospital infection preventionists. However, the language leaves nursing homes the option to pursue other ways of meeting the training requirement.

“While nurses and other healthcare professionals may be likely candidates for the IPCO role, many of these professionals may have only received training in basic infection control practices in their core professional preparation for licensure,” the CMS states. “The responsibility and necessary knowledge for an IPCP likely goes well beyond basic infection control training. Therefore, we propose to require that the IPCO be a healthcare professional with specialized training in infection prevention and control beyond their initial professional degree. Considering the diverse nature of the resident population and of the healthcare delivery model, the qualifications, training, and time needed by an IPCO at each facility would vary widely, thus we are not at this time proposing more specific requirements.”

The Centers for Medicare and Medicaid Services proposed rule would require stewardship programs that include antibiotic-use protocols and a system for monitoring drug administration.

“Nursing homes are the next frontier where new antibiotic resistant organisms may emerge and flourish,” the CMS stated. “Organisms such as Clostridium difficile and MRSA are known concerns. Nursing homes need to have the tools to participate in surveillance, learn and use infection control and containment practices, and adopt a proactive approach to preventing spread while being good stewards of antibiotics to preserve effectiveness of the agents we have today.”

As previously reported in Hospital Infection Control & Prevention, the CMS is also working on a proposed regulation requiring antibiotic stewardship in hospitals, as reducing multidrug resistant bacteria has become a national priority. However, that hot-button topic is overshadowed by the new CMS emphasis on healthcare-associated infections (HAIs) in its first major rewrite of long-term care conditions of participation since 1991.

Annually, HAIs in nursing homes cause an estimated 150,000 hospitalizations, 388,000 deaths, and between $673 million and $2 billion dollars in additional healthcare costs, the CMS stated.

“We propose to require facilities to have a system for preventing, identifying, reporting, investigating, and controlling infections and communicable diseases for all residents, staff, volunteers, visitors, and other individuals providing services under an arrangement based upon its facility and resident assessments that is reviewed and updated annually,” the CMS stated.

The CMS estimated a $284 million annual cost for enacting such infection provisions in long term care settings nationally.

“Given the growing number of individuals receiving care in long term care settings and the presence of more complex medical care, these individuals are at an increased risk for HAIs,” the CMS stated. “[W]e have proposed revisions that we believe will provide more opportunities to achieve broad-based improvement and contribute to reduced healthcare costs. We also believe this approach would be flexible enough to be adapted to any business model and would allow for targeted interventions specific to the facility.”

Editor’s note: Following the July 16, 2015 publication of the proposed CMS rule there is a 60-day comment period. To submit a comment, go to www.regulations.gov and enter the ID number CMS-3260-P, then click on “Submit a Comment.”