Failure to Ensure Hand Hygiene During Meal Tray Delivery
Summary
The deficiency involves the facility’s failure to ensure staff performed appropriate hand hygiene during meal service, as required by its infection prevention and control program and hand hygiene policy. During a lunch meal delivery on Hall 100, multiple CNAs passed meal trays to residents without using hand sanitizer or otherwise performing hand hygiene immediately before resident contact. Observations on 03/05/26 at approximately 12:19 PM showed two CNAs knocking on doors and entering rooms to deliver meal trays to two residents without sanitizing their hands beforehand. At 12:23 PM, another CNA exited the shower room and began assisting with meal tray distribution without sanitizing her hands. At 12:25 PM, this same CNA adjusted her clothing by pulling on her pants and then continued pushing the meal cart and delivered a tray to another resident. At 12:27 PM, she handed a tray to a fourth CNA, who took the tray into another resident’s room without sanitizing her hands. The residents involved had various medical and functional profiles documented in their records. One male resident had a history of traumatic subarachnoid hemorrhage, major depressive disorder, and anxiety disorder, and required setup or clean-up assistance for eating, with a care plan goal to maintain dignity by being clean, dry, odor free, and well groomed. Another male resident had dementia, peripheral vascular disease, schizophrenia, major depressive disorder, and hypertension, and was care planned for ADL self-care performance deficit related to dementia, with interventions including setup and supervision for eating; his MDS indicated he could eat independently. A third male resident had dementia, paranoid schizophrenia, encephalopathy, anxiety disorder, hypertension, and respiratory failure, and was care planned as being at risk for infection and viral respiratory infection, with interventions including education on signs, symptoms, and precautions. A female resident had type 2 diabetes, severe sepsis, schizophrenia disorder, cognitive communication deficit, and bipolar disorder, and was also care planned as being at risk for infection and viral respiratory infection with similar educational interventions. Several of these residents required setup or clean-up assistance for eating, meaning staff were expected to handle their meal trays and related items. Interviews with residents and staff further described the circumstances surrounding the lack of hand hygiene. Two cognitively intact male residents reported they did not know whether staff sanitized their hands before bringing food into their rooms; one stated staff did not wash their hands before leaving his room, and both acknowledged that clean hands were important, though they reported not having been sick. One cognitively intact female resident was unable to provide relevant information about staff hand hygiene during an interview, instead giving unrelated responses. Staff interviews revealed inconsistent access to and use of hand sanitizer: one CNA stated she did not use hand sanitizer when passing trays and reported that hallway sanitizer stations did not work, claiming she had informed nurses but did not receive sanitizer. Another CNA stated there was no or mostly empty hand sanitizer in the hall, that she usually washed her hands when passing and picking up trays, and that she had washed her hands in the shower room and therefore did not see a need to sanitize again; she denied reporting the lack of sanitizer. A third CNA stated staff were supposed to carry hand sanitizer in their pockets and believed there were sanitizer containers on the halls but would need to check, and she thought housekeeping was responsible for ensuring availability. The DON reported she was new, believed staff should have hand sanitizer at all times, was unsure about the presence of sanitizer receptacles in the halls, and denied being told sanitizer was unavailable. The Administrator stated the expectation was that CNAs practice good hand hygiene and notify her if sanitizer was not available. Facility policies on infection control and hand hygiene required staff involved in direct resident contact to perform proper hand hygiene to prevent the spread of infection, but observations and interviews showed this was not consistently implemented during meal service for the four residents. The facility’s own staff acknowledged that failure to sanitize hands placed residents at risk of infection, cross contamination, and transfer of bacteria. CNAs interviewed stated that residents were at risk of transmission of infection when staff did not sanitize their hands, and the DON stated that when staff did not sanitize their hands they placed residents at risk of transmission of infection. The Administrator similarly stated that residents had been at risk of getting sick with infection or a UTI. These statements, combined with the observed lack of hand hygiene during meal tray delivery and the documented policies requiring hand hygiene, form the basis of the identified deficiency in the facility’s infection prevention and control program. The infection control and prevention in-service record dated 1/5/26 stated that the purpose of the policy was to reduce the spread of infections by using evidence-based techniques and established infection control policies and procedures, and that it was the policy to use precautions to reduce the risk and prevent transmission of infectious agents. The hand hygiene policy dated 11/12/17 specified that staff involved in direct resident contact would perform proper hand hygiene procedures to prevent the spread of infection to personnel, residents, and visitors, and defined hand hygiene as either handwashing or use of an alcohol-based hand rub, to be performed when indicated using proper technique consistent with accepted standards of practice. Despite these written policies and in-service education, the observed practices during the lunch meal service on Hall 100 did not align with the facility’s stated infection prevention and control requirements, resulting in the cited deficiency.
Penalty
Resources
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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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