Preparing For CMS Infection Control Inspections CMS .

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Preparing for CMS Infection ControlInspectionsCMS Interpretive Guidelines and theRevised CMS Infection Control WorksheetThe information provided in AHC Media Webinars does not, and is not intended to constitute medical orlegal advice. Opinions, references and links provided by our speakers are provided for your convenienceand do not represent our endorsement of such opinions, products or services

Speaker Sue Dill Calloway RN, Esq.CPHRM, CCMSCP AD, BA, BSN, MSN, JD President of Patient Safety andEducation Consulting Board MemberEmergency Medicine Patient SafetyFoundation at www.empsf.org 614 791-1468 sdill1@columbus.rr.com2

Learning Objectives Discuss the infection control policies and proceduresrequired by CMS Explain how CMS is using the revised infection controlworksheet including why it is so important for staff toknow how to utilize it Discuss why CMS requires that the national standards ofcare and practice must be followed such as those fromthe CDC, SHEA, APIC, OSHA, and AORN, List the CMS required infection control officer’sresponsibilities in measuring, identifying, preventing andcontrolling infection3

Infection Control The CDC says there are 1.7 million healthcareinfection (HAI) in America every year There are 99,000 to 100,000 deaths in Americanhospitals every year CMS gets 50 million dollar grant to enforce infectioncontrol standards in 2010 and 2011 and HHS a billiondollars in 2013 so surveyors are more knowledgeable Leadership need to make sure there is adequatestaffing and resources to prevent and manageinfections Healthcare-Associated Infections (HAIs) are one of the topten leading causes of death in the US1 www.cdc.gov/ncidod/dhqp/hai.html/ 404

The Conditions of Participation (CoPs) Regulations first published in 1986 Revised many times since with IC changes, safeinjection practices, insulin pens, humidity in the ORetc. Manual updated August 30, 2013 and 457 pages First regulations are published in the FederalRegister then CMS publishes the InterpretiveGuidelines and some have survey procedures2 Hospitals should check this website once a monthfor s.gov/SurveyCertificationGenInfo/PMSR/list.asp5

The Conditions of Participation Good way to keep up is sign up for the FederalRegister 1 Hospitals should check the survey andcertification website once a month for changes 2 Another good place to check monthly is thetransmittal website 3 Have one person assigned to check these once amonth1 www.gpoaccess.gov/fr/index.html2 st.asp3 www.cms.gov/Transmittals/01 overview.asp6

CMS Survey and Certification /list.asp#TopOfPage7

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CMS Memo April 19, 2013 CMS issues memo related to the relative humidity(RH) AORN use to say temperature maintained between68-73 degrees and humidity between 30-60% inOR, PACU, cath lab, endoscopy rooms andinstrument processing areas CMS says if no state law can write policy orprocedure or process to implement the waiver Waiver allows RH between 20-60% In anesthetizing locations- see definition in memo9

Humidity in Anesthetizing Areas10

Transmittalswww.cms.gov/Transmittals/01 overview.asp11

The Conditions of Participation (CoPs) The manual is known as the conditions of participationor the CoPs for short The CoP sections are called tag numbers They go from Tag 0001 to 1164 All the sections contain a tag number so it is easyto go back and look up that section if you want toread more about it There were changes in the Federal Register went intoeffect July 16, 2012 and IG issued March 15, 2013and in the current manual12

Location of All of CMS CoPs ManualsNew website at www.cms.hhs.gov/manuals/downloads/som107 Appendixtoc.pdf13

Past CMS Hospital CoP Manual June 7, 201314

CMS Hospital CoP Manualwww.cms.hhs.gov/manuals/downloads/som107 Appendixtoc.pdf15

CMS Issues Final Regulation CMS publishes 165 page final regulations changingthe CMS CoP Published in the May 16, 2012 Federal Register CMS publishes to reduce the regulatory burden onhospitals-more than two dozen changes FR effective on July 16, 2012, IG issued 3-15-2013 and in currentmanual Eliminated the infection control log under Tag 750 June 7, 2013 added additions to surveillance June 7, 2013 added IP is infection preventionist Available at www.ofr.gov/inspection.aspx16

May 16, 2012 Federal 617

CMS Updates to Manual18

Log of Incidents 750 Deleted 2013 Must maintain a log related to infections andcommunicable diseases CMS deleted the log requirement but not for CAH hospitals Log requirements use to require the following; Includes information from patients Includes employees, contract staff such asagency nurses, and volunteers Includes surgical site infections, patients or staffwith MDRO, patients who meet isolationrequirements/ 4019

Infection Control Officer 748 2013 Hospital infection control officers are often referredto as hospital epidemiologists (HEs), infectioncontrol professionals (ICPs) or IP APIC calls them Infection Preventionist or IP andJune 7, 2013 CMS added IP to tag 748 CDC has defined “infection control professional” as “aperson whose primary training is in either nursing,medical technology, microbiology, or epidemiologyand who has acquired specialized training in infectioncontrol” The hospital must designate in writing an individual asits infection control officer/ 4020

IPs Responsibilities 7492013 Mitigate risks associated with Patient infections present upon admission Risks contributing to HAI Conduct active surveillance (revised June 2013) Includes patients, staff, volunteers, and contractworkers Must identify and track infectious and communicablediseases Including HAI selected by IC program bases ontargeted surveillance based on nationally recognizedguidelines and periodic risk assessment/ 4021

IC Officer’s Responsibilities 749 2013 Active surveillance (continued) Culture or patient colonized with MDRO Isolation patients Patients or staff with reportable communicable diseases Staff or patients with signs and symptoms in which local,state, or feds request Staff or patients infected with significant pathogens Recommend use of automated surveillance technology Monitoring compliance with all P&Ps, protocols andother infection control program requirements22

Changes to Tag 749 Active Surveillance23

CMS Infection Control StandardsWhat Hospitals Need to Know.Hospitals Need to Know About theInfection Control InterpretiveGuidelines

Infection Control There are 12 pages in the interpretive guidelines oninfection control Updated to reflect changing infectious andcommunicable disease threats Includes current knowledge and best practices Must follow national standards of care and practice CMS announces unannounced surveys related toinfection control in 2014/ 4025

Infection Control Included four major sections Active infection control program Investigations and control of infections Infection control log (no longer mandatory somake sure P&P changed) CEO, CNO, and MS must ensure hospital-widetraining program and correction plan for problemareas Note that CMS has announced infection controlinspections of hospitals so need to do this right/ 4026

CMS Infection Control Sample Page/ 4027

HHS Action Plan Estimated that HAIs incur nearly 20 billion in excesshealthcare cost each year Many are preventable Top priority of HHS now Develop HHS Action Plan to Prevent HAIs Every infection preventionist (IP) should have a copy ofthis document HHS get a billion dollars to enforce IC and has a videoevery healthcare practitioner should see Partnering to heal video at /ophs/initiatives/hai/index.html/ 4028

The Cost of Healthcare Associated Infectionswww.cdc.gov/HAI/burden.html29

Watch the Video on Preventing HAIwww.hhs.gov/ash/initiatives/hai/training/30

Infection Control Follow the Money! This area is very important now Now if you do not do this right it could cost thehospital money CMS has hospital acquired conditions (HAC) inwhich no additional payment is made for Medicarepatients and CMS will do this for Medicaid patients Many states agree not to bill for some or all of the29 never events or serious reportable events (revisedlist in 2011) Insurance companies are putting it into their contractsthat hospitals will not bill for any of the never events/ 4031

CMS Hospital Acquired Conditions CMS has no additional payment for these HACs ornever events Studies show hugh cost to hospitals Vascular catheter-associated infection Surgical site infection such as mediastinitis aftercoronary artery bypass graft surgery Catheter-associated urinary tract infections Surgical-site infections following certain orthopedicprocedures (repair, replacement or fusion of joints)/ 4032

CMS Hospital Acquired Conditions ePayment/HospitalAcqCond/HospitalAcquired Conditions.html33

CMS Hospital CoP Definition of Infection The guidelines include a definition of infectiousdisease, infectious agent, and communicablediseases Hospitals may want to include these definitions intheir revised policies and procedures Definitions developed by the National Institute ofAllergy and Infectious Diseases (NIAID) Communicable disease is defined as a diseaseassociated with an agent that can be transmittedfrom one host to another/ 4034

Definition of Infection Infectious disease is defined as a change from astate of health to a state in which part or all of ahost’s body cannot function normally because of thepresence of an infectious agent or its product. An infectious agent is defined as a living or quasiliving organism or particle that causes an infectiousdisease, and includes bacteria, viruses, fungi,protozoa, helminths (parasitic worms), and prions. Note that APIC now calls them infectionpreventionist or IPs CMS in 2013 now call them infection preventionist/ 4035

Infection Control (IC) Hospital must have sanitary environment to avoidsources and transmission of infection andcommunicable diseases Maintain an active IC program for prevention,control, and investigation of infections andcommunicable diseases Standards apply to all departments of hospitalsboth on and off campus All areas must be clean and sanitary No dried blood on the floor, side of stretchers or on theceiling tile/ 36

Infection Control Infection prevention must include monitoringof housekeeping (Environmental Services)and maintenance including constructionactivities Areas to monitor include food storagepreparation, serving and dish rooms,refrigerators, ice machines, air handlers,autoclave rooms, venting systems, inpatientrooms, treatment areas, labs, waste handling,surgical areas, supply storage and equipmentcleaning/ 4037

Infection Control (IC) A-0747 Include all standards of care and practice State and federal laws Look at national organization recommendations APIC (Association for Professionals in Infection Controland Epidemiology), CDC (Center for Disease Control),SHEA (Society for Healthcare Epidemiology of America),OSHA (Occupational Health and Safety Administration),AORN, IDSA, etc. Investigate infections and communicable diseasesfor inpatients and personnel working in hospitalsincluding volunteers/ 40

APIC’s Targeting Zero Campaign Targeting zero is the philosophy that every hospitalshould be working toward a goal of zero HAIs While not all HAIs are preventable, APIC believes weshould strive for the goal of elimination and strive forzero infections Association for Professionals in Infection Control andEpidemiology (APIC) put together many resources tohelp hospitals to start to meet this goal Prompt investigation of HAIs of greatest concern to thehospital (like MRSA, C-Diff, surgical site infections,catheter associated UTIs) Needed because of our declining arsenal of antibioticsto treat infections39

Infection Control Maintain active surveillance program So what’s in your IC plan and IC program? Specific measures for infection detection, datacollection, analysis monitoring, and evaluationsof preventive interventions Document surveillance activities Must have reliable sampling or other mechanism inplace to identify and monitor infections andcommunicable diseases/ 40

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Infection Control Infection control must be integrated in PI Surveillance activities should be conducted inaccordance with recognized surveillance practices CDC NHSN (National Healthcare Safety Net) NHSN is internet-based surveillance system managed by theCDC Hospitals now using to report ICU and NICU central lineinfections and selected reporting of CAUTIs Available for hospitals at no charge and great resource Provides multiple options for data analysis and moreflexibility for sharing information within and outside the facility/ 4042

Infection Control NHSN replaces the CDCs National NosocomialInfection Surveillance system (NNIS) Was considered the gold standard for tracking HAI formore than 30 years Designed to help hospitals better manage episodes ofHAI such as MRSA and VRE Used by the VA hospitals Hospitals report central line infections in ICUs and NICUs Enroll on-line for HAI surveillance and many n.html/ 4043

National Healthcare Safety Networkwww.cdc.gov/nhsn/44

www.cdc.gov/nhsn/training/45

www.cdc.gov/nhsn/acute-carehospital/index.html46

011.pdf47

4 Challenges in Infection Control CMS said there are four special challenges ininfection control (just four?) Challenge 1: Multidrug-ResistantOrganisms Challenge 2: Infection Control inAmbulatory Care Challenge 3: Communicable DiseaseOutbreaks Challenge 4: Bioterrorism/ 4048

Multidrug-Resistant Organisms Multidrug-resistant organisms (MDROs) areresistant to one or more antimicrobial agents Treatment is more difficult These bad bugs are more dangerous Have systems in place to identify and preventtransmission of these organisms. The CDC has a special publication on“Management of Multidrug-Resistant Organisms inHealthcare Settings, oGuideline2006.pdf/ 4049

df50

51

SHEA C-Diff Adults-2010.aspx52

APIC 2013 C-Diff ion-guides53

Infection Control in Ambulatory Care Infection control in ambulatory care presents specialproblems Patients remain in common areas such as thelobby and ED waiting areas Patients are turned around quickly with minimalcleaning Infectious patients may not be recognizedimmediately Immuno-compromised patients can receivetreatment in rooms with other patients who pose arisk of infection/ 4054

APIC Resources for Ambulatory Care55

Infection Control in Ambulatory Care Guidelines have been developed by the CDC’sHealthcare Infection Control Practices AdvisoryCommittee (HICPAC) hwww.cdc.gov/hicpac/pubs.html Infection control plan for ambulatory care Norovirus gastroenteritis outbreaks 2011 Guidelines for Disinfection and Sterilization in HealthcareFacilities 2008 Guidelines for Isolation Precautions 2007 CDC Intravascular guidelines 2011 Management of Multidrug-Resistant Organisms 2006 Influenza Vaccination of Healthcare Personnel 2006/ 4056

CDC Norovirus Guidelineswww.cdc.gov/hicpac/norovirus/002 norovirus-toc.html57

CDC HICPAC58

Infection Control in Ambulatory Care CDC’s Healthcare Infection Control PracticesAdvisory Committee (HICPAC) Guidelines (continued) Guidance on Public Reporting of HAI 2005 Guidelines for Preventing Healthcare AssociatedPneumonia 2004 Guidelines for Environmental Infection Control inHealthcare Facilities 2003, 2002 Hand hygiene guidelines,Prevention of Surgical Site Infections and more HICPAC is a federal advisory committee made up of 14external IC experts who provide guidance and advice tothe CDC and HHS– Members from APIC, SHEA, AORN, CMS, FDA etc./ 4059

Preventing Infections in the Outpatient Unit 2011 CDC has a guide and checklist forpreventing infections in the outpatient setting The Guide to Infection Prevention forOutpatient Settings: Minimum Expectations forSafe Care and The Infection Prevention Checklist forOutpatient Settings; Minimum Expectations forSafe Care Free off the website tientsettings.html?source govdelivery60

CDC Guide Infection Control patient-careguidelines.html61

Communicable Disease Outbreaks Community-wide outbreaks of communicablediseases present many of the same types of issuesas hospital infection disease threats Understand the epidemiology Know how it is transmitted and the clinical courseof the disease in order to manage the outbreak Pandemics, or widespread outbreaks of an infectionrequire back up resources Hospitals need to work with state, federal, andlocal health agencies/ 4062

Communicable Disease Outbreaks There are at a minimum four things that must beaddressed: Preventing transmission among patients,healthcare personnel, and visitors Identifying persons who may be infected andexposed Providing treatment or prophylaxis to largenumbers of people Logistical issues (staff, medical supplies,resupply, continued operations, and capacity)/ 4063

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Bioterrorism Hospitals should be well versed in emergencypreparedness, including bioterrorism Terrorists could use bioterrorism There is a long list of bioterrorism agents Anthrax, arenaviruses, botulism, brucellosis,cholera, Ebola virus, hemorrhagic fever, E. coli,Lassa fever, plague, ricin toxin, salmonella, andcryptosporidium For a comprehensive list go to ist.asp/ 4065

http://emergency.cdc.gov/bioterrorism/66

67

Bioterrorism The hospital must be in compliance with theOccupational Health and SafetyAdministration’s Bloodborne Pathogensregulation 29 CFR 1910.1030.1 http://ecfr.gpoaccess.gov/cgi/t/text/text1idx?c ecfr&tpl %2Findex.tpl The Code of Federal Regulations can beobtained free from the internet Regulations address PPE, safer needles, anduse of universal precautions to prevent thespread of infection/ 4068

IP Officer’s Responsibilities Many have added these to their job descriptions Maintain sanitary hospital environment Ventilation and water controls, constructionmake sure safe environment, safe air handlingin areas of special ventilations such as the ORand isolation rooms, techniques for foodsanitation, cleaning and disinfecting surfaces,carpeting and furniture, how is pest controldone, and disposal of trash along with nonregulated waste/ 4069

Organizations and Policies 748 A person or persons must bedesignated as infectioncontrol officer or officers todevelop and implementpolicies governing control ofinfections and communicablediseases APIC and CMS call theseprofessionals infectionpreventionists/ 4070

Infection Control Officer 748 2013 Hospital infection control officers are often referredto as hospital epidemiologists (HEs), infectioncontrol professionals (ICPs) or IP APIC calls them Infection Preventionist or IP andJune 7, 2013 CMS added IP to tag 748 CDC has defined “infection control professional” as “aperson whose primary training is in either nursing,medical technology, microbiology, or epidemiologyand who has acquired specialized training in infectioncontrol” The hospital must designate in writing an individual asits infection control officer/ 4071

Infection Control Preventionist The person assigned to the job should be educatedand competent in that area Qualified through education, training, experience,or certification Certification offered by: Certification Board of Infection Control andEpidemiology Inc. (CBIC) Specialty boards in adult or pediatric infectiousdiseases– American Board of Internal Medicine (for internists)– American Board of Pediatrics (for pediatricians)./ 4072

APIC Competency in Infection 2)00165-4/fulltext73

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Infection Control Preventionist (IPs) Infection control officers should maintain theirqualifications This should be done through ongoing educationand training APIC has excellent educational conferences This requirement can be demonstrated byparticipation in infection control courses, or in localand national meetings organized by recognizedprofessional societies, such as APIC and SHEA Develop and implement IC measures (hospitalstaff, contract workers, volunteers)/ 4075

IPs Responsibilities 749 Mitigate risks associated with Patient infections present upon admission Risks contributing to HAI Conduct active surveillance (revised June 7, 2013) Includes patients, staff, volunteers, and contract workers Must identify and track infectious and communicablediseases Including HAI selected by IC program bases on targetedsurveillance based on nationally recognized guidelinesand periodic risk assessment/ 4076

IC Officer’s Responsibilities 749 2013 Active surveillance (continued) Culture or patient colonized with MDRO Isolation patients Patients or staff with reportable communicable diseases Staff or patients with signs in which local, state, or fedsrequest Staff or patients infected with significant pathogens Recommend use of automated surveillance technology Monitoring compliance with all P&Ps, protocols andother infection control program requirements77

IPs Responsibilities749 Evaluate and revise of the program, whenindicated Coordinate with federal, state, and localemergency preparedness and health authoritiesto address communicable disease threats,bioterrorism, and outbreaks As required by law Comply with the reportable disease requirements ofthe local health authority Integrate IC program into hospital-wide QAPI/ 4078

Infection Control (IC) A- 749 Long list of IC policies that hospitals must have The 22 policies are now organized under 5sections Maintain a sanitary physical environment Hospital staff related measures (evaluate hospitalstaff immunization status for infectious diseases asper CDC and APIC, how you screen hospital stafffor infections likely to cause significant infectiousdisease to others, policy on when staff are restrictedfrom working)/ 40

IC Policies Include: New employee orientation (include handwashing) How to mitigate risk when patient admitted withinfection Must be consistent with the CDC isolation guidelines Staff knowledge of PPE Mitigate risk that cause or contribute to HAI SCIP measures, appropriate hair removal, timely antibioticsin OR, DC in 24 hours except 48 hours for cardiac patients,beta blockers during perioperative periods for select cardiacpatients, proper sterilization of equipment, etc./ 40

CDC Isolation recautions.html81

Norovirus Guidelineswww.cdc.gov/hicpac/norovirus/002 norovirustoc.html82

CDC Coronavirus Guidance CDC has interim infection prevention and controlrecommendations Recommend standard, contact, and airborneprecautions for patients hospitalized with MiddleEast Respiratory Syndrome Coronavirus (MERSCoV) Suspect high rate of mortality, limited human to humantransmission, unknown mode of transmission Similar to coronavirus that caused severe acuterespiratory syndrome (SARS) See New England Journal of Medicine, June 19, 2013, "Hospital Outbreak of Middle East Respiratory SyndromeCoronavirus.“ at ?query TOC&#t abstract83

CDC Coronavirus Guidance84

IC Policies Include: Isolation procedures for: Highly immuno-suppressed patients (HIV or chemo patients) Trach care, respiratory care, burns, and other similar situations HAI risk mitigation Promotion of hand hygiene Measures to prevent organisms that are antibiotic resistant such asMRSA and VRE Central line bundle, VAP bundle or sepsis bundle,prompt removal of foley catheter Use of disinfectants, antiseptics, and germicides inaccordance with manufacturers instructions/ 40

IP Toolswww.infectionpreventiontools.com/86

IC Policies Include: Appropriate use of facility and medicalequipment (hepa filters, negative pressureroom, UV lights and other equipment) toprevent the spread of infectious agents Education on infection and communicablediseases for patients, visitors, care givers,and staff Active surveillance system, method for gettingdata to determine if there is a problem Policy on getting cultures from patients, etc./ 40

Policies and Organization Need IC officer (now called IP or InfectionPreventionist) and IC committee IC officer must develop and implementpolicies on control of infection andcommunicable diseases Person must be designated in writing who isqualified through education and experience Lists the responsibilities of this personconsider putting into job description/ 40

Infection Control The IP must develop a system foridentifying, reporting, investigating, andcontrolling infections and communicablediseases of patients and personnel Applies to both healthcare-associatedinfections (HAI) and communityacquired infection/ 4089

Infection Control Activities Tag 749The following activities should be based on nationalguidelines: Maintenance of a sanitary hospital environment Development and implementation of infection controlmeasures related to hospital personnel (hospital staff, forinfection control purposes, includes all hospital staff,contract workers (e.g., agency nurses, housekeepingstaff, etc.), and volunteers Mitigation of risks associated with patient infectionspresent upon admission and risks contributing to HAI Active surveillance/ 4090

Infection Control Activities Monitoring compliance with all policies, procedures,protocols and other infection control programrequirements Program evaluation and revision of the program,when indicated Coordination as required by law with federal, state,and local emergency preparedness and healthauthorities to address communicable diseasethreats, bioterrorism, and outbreaks Complying with the reportable disease requirementsof the local health authority/ 4091

Log of Incidents 750 Deleted 2013 Must maintain a log related to infections andcommunicable diseases CMS deleted the log requirement effective 7-16-2012 Log requirements use to require the following; Includes information from patients Includes employees, contract staff such asagency nurses, and volunteers Includes surgical site infections, patients or staffwith MDRO, patients who meet isolationrequirements/ 4092

CEO, DON, and MS A-756 2013 The CEO, DON, and MS must ensure that thereis hospital-wide QAPI and training program thataddress problems identified by IC officer QAPI now means Quality Assessment not Assurance Implement a successful corrective actionplan in affected problem areas Train staff in problems identified Problems must be reported to nursing, MS,and administration/ 40

CMS WorksheetsInfection Control

CMS Hospital Worksheets Third Revision October 14, 2011 CMS issues a 137 page memo in thesurvey and certification section Memo discusses surveyor worksheets for hospitals byCMS during a hospital survey Addresses discharge planning, infection control, andQAPI It was pilot tested in hospitals in 11 states and on May18, 2012 CMS published a second revised edition Piloted test each of the 3 in every state over summer 2012 November 9, 2012 CMS issued the third revisedworksheet which is now 88 pages95

CMS Hospital Worksheets Will select hospitals in each state and will completeall 3 worksheets at each hospital From 1-9 hospitals in every state with more in states withlarger numbers and will select hospitals with higher thanaverage readmissions for all causes This is the third and most likely final pilot and in2013 will use whenever a validation survey is doneat a hospital by CMS Third pilot is non-punitive and will not require actionplans unless immediate jeopardy is found Hospitals should be familiar with the three worksheets96

Third Revised MSR/list.asp#TopOfPage97

CMS Hospital Worksheets Goal is to reduce hospital acquired conditions(HACs) including healthcare associated infections Goal to prevent unnecessary readmission andcurrently 1 out of every 5 Medicare patients isreadmitted within 30 days Many hospitals (66%) financially penalized afterOctober 1, 2012 because they had a higher thanaverage rate of readmissions and same in 2013 Forfeited 280 million dollars and 2013 is 228 million The underlying CoPs on which the worksheet isbased did not change98

CMS Hospital Worksheets However, some of the questions asked might not beapparent from a reading of the CoPs A worksheet is a good communication device It will help clearly communicate to hospitals what isgoing to be asked in these 3 important areas Hospitals might want to consider putting together ateam to review the 3 worksheets and complete theform in advance as a self assessment Hospitals should consider attaching thedocumentation and P&P to the worksheet99

CMS Hospital Worksheets This would impress the surveyor when they came tothe hospital The worksheet is used in new hospitals undergoingan initial review and hospitals that are notaccredited by

Aug 30, 2013 · Hospital infection control officers are often referred to as hospital epidemiologists (HEs), infection control professionals (ICPs) or IP APIC calls them Infection Preventionist or IP and June 7, 2013 CMS added IP to tag 748 CDC has defined “infection control professional” as “a person whose primary training is in either nursing,

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