Infection Prevention and Control Program

This section sets out the standing under which this policy is issued, who owns it, who is bound by it, and how it is kept current. It is not itself a procedure. The obligations begin at Section 1.

This policy sets up the Agency’s infection prevention and control program. "The HHA must maintain and document an infection control program which has as its goal the prevention and control of infections and communicable diseases" (42 CFR §484.70). Michigan does not license home health agencies, so this policy rests on the federal Conditions of Participation that bind the Agency as a Medicare-certified agency and on the Michigan laws and Medicaid rules it cites.

This policy covers the program’s leadership, standard and transmission-based precautions, hand hygiene, the nursing bag, equipment and supplies, surveillance and investigation, outbreak response, communicable disease reporting, education, and evaluation of the program through QAPI.

The following terms have the meanings given below when used in this policy.

Prevention: "The HHA must follow accepted standards of practice, including the use of standard precautions, to prevent the transmission of infections and communicable diseases" (42 CFR §484.70(a)). The Agency uses current Centers for Disease Control and Prevention guidance as its accepted standard of practice.

Control: the Agency maintains "a coordinated agency-wide program for the surveillance, identification, prevention, control, and investigation of infectious and communicable diseases that is an integral part of the HHA's quality assessment and performance improvement (QAPI) program", with a method for identifying infectious and communicable disease problems and a plan for actions expected to result in improvement and disease prevention (42 CFR §484.70(b)).

Education: "The HHA must provide infection control education to staff, patients, and caregiver(s)" (42 CFR §484.70(c)).

• The governing body designates the infection preventionist (the Administrator, or a qualified clinician such as an RN with infection control training). The designation is in writing and kept by the Administrator.
• The infection preventionist writes and reviews the Agency’s infection control procedures every year, runs surveillance, investigates problems, reports results to QAPI at least every quarter (Policy MI-HH-QA-01), and keeps up with CDC and MDHHS guidance.
• The clinical manager makes sure staff follow the procedures in the field, through supervisory visits and record review.

• Staff clean their hands on arrival and before leaving, before and after touching the patient, before clean or aseptic tasks, after possible contact with body fluids, after removing gloves, and after touching the patient’s surroundings.
• Staff use alcohol-based hand rub unless hands are visibly soiled, then soap and running water. Where no running water is available, staff use antiseptic hand cleanser or towelettes and wash with soap and running water as soon as feasible (Mich. Admin. Code R 325.70007(c)).
• Staff wear gloves, gowns, masks and eye protection according to the expected exposure (Policy MI-HH-IC-02), and change gloves between tasks on the same patient when moving from a dirty to a clean area.
• Staff practice respiratory hygiene, offer a mask to a coughing patient where tolerated, and keep a distance where possible.
• Safe injection practices: one needle and one syringe, one time; single-dose vials for one patient; never reuse a fingerstick device.

• The RN who identifies or is told of a patient with a known or suspected transmissible infection (for example, multidrug-resistant organisms, C. difficile, influenza, COVID-19, scabies, or active tuberculosis) adds the precautions CDC guidance recommends to the plan of care and the aide care instructions.
• The patient is scheduled, where practical, as the last visit of the day, and only the equipment needed is taken into the home. Dedicated equipment is left in the home where possible.
• Staff who are not immune or not fit-tested for a respirator do not visit a patient on airborne precautions (Policy MI-HH-IC-03).
• The patient and caregivers are taught how to protect others in the household.

• The bag is kept clean: it is placed on a clean, dry surface or barrier in the home, never on the floor or bed, and opened only after hand hygiene.
• Clean supplies are kept separate from used items. Used items are never put back into the bag.
• Reusable equipment (stethoscopes, blood pressure cuffs, thermometers, pulse oximeters, scales) is cleaned and disinfected after each patient with an EPA-registered disinfectant, following the product’s contact time and the equipment manufacturer’s instructions.
• Supplies taken into a patient’s home and not used are left for that patient or discarded; they are not used for another patient.
• Staff vehicles carry supplies in a clean container separate from waste and soiled items.

1. Clinicians report each suspected or confirmed home health-associated infection, and each patient or staff case of a communicable disease of concern, to the infection preventionist within one business day, as the Agency’s own standard.
2. The infection preventionist enters each case on the infection surveillance log (Form MI-HH-IC-01-A) using written case definitions based on CDC surveillance definitions adapted for home care.
3. Each month the infection preventionist counts infections by type (for example, catheter-associated urinary tract infections, central line infections, wound infections, respiratory infections) and calculates rates per 1,000 patient-days or per device-days where possible.
4. Each quarter the results, trends and any clusters go to the QAPI committee (42 CFR §484.70(b); Policy MI-HH-QA-01).
5. Hospitalizations or emergency visits for infection, identified through QAPI data, are reviewed for preventable causes.

• When surveillance shows a cluster, a rise in rates, or a breach of practice, the infection preventionist investigates: reviews cases and records, observes practice, and looks for common staff, equipment, supplies or procedures.
• The infection preventionist writes an action plan with steps expected to lead to improvement and disease prevention (42 CFR §484.70(b)(2)), such as retraining, changing supplies or procedures, or restricting a staff member from work (Policy MI-HH-IC-03), and the QAPI committee monitors it until rates improve.
• Where an outbreak or unusual occurrence may threaten public health, the Administrator or infection preventionist contacts the local health department for advice and to report it (Section 11), and follows the health department’s instructions.
• Exposure of staff to a communicable disease is handled under Policy MI-HH-IC-03; exposure to blood or body fluids under Policy MI-HH-IC-02.

• MCL 333.5111 directs MDHHS to keep a list of reportable diseases, infections and disabilities and allows rules for reporting. Under the Michigan Communicable Disease Rules, physicians and laboratories must report listed diseases to the appropriate local health department (Mich. Admin. Code R 325.173(1) to (5)). A physician reports each case of a serious communicable disease on the MDHHS list, other than HIV and AIDS, "within 24 hours of diagnosis or discovery" (R 325.173(1)).
• Nurses and an administrator, epidemiologist or infection control professional from a health care facility or other institution "may report" to the appropriate local health department any designated condition or other disease, infection or condition that comes to their professional attention and poses a threat to the health of the public (R 325.173(8)).
• The Agency therefore: makes sure the patient’s physician knows of any suspected reportable condition the Agency finds; reports to the local health department any unusual occurrence, cluster or outbreak among Agency patients or staff that may threaten public health; and gives the health department the information it asks for in an investigation, which Michigan rules require to be provided promptly to an investigator who presents official identification (R 325.174(2)).
• The local health department for the patient’s county of residence is the one the Agency calls (R 325.171(1)(a)). The infection preventionist keeps the phone numbers of the local health departments for Ingham and Eaton Counties.

• Staff: infection control training at orientation and at least every year, covering hand hygiene, standard and transmission-based precautions, personal protective equipment, equipment cleaning, the bag technique, and how to report infections. Aides are trained in basic infection prevention and control as part of their training and evaluation (42 CFR §484.80(b)(3)(iv); Policy MI-HH-AID-01), and supervision checks that they follow these procedures (§484.80(h)(4)(iv)).
• Patients and caregivers: teaching at the start of care, and as needed, on hand hygiene, care of devices and wounds, signs of infection to report, safe disposal of household sharps and dressings, cleaning, and vaccination (42 CFR §484.70(c)). Teaching is recorded in the clinical record.

Accountability under this policy is allocated as follows.

The infection preventionist keeps Form MI-HH-IC-01-A, monthly rates, investigation reports, action plans and QAPI reports for at least seven years, as the Agency’s own standard. Training records are kept under Policy MI-HH-HR-02 and, for bloodborne pathogens training, as MIOSHA Part 554 requires (Policy MI-HH-IC-02). Each year the infection preventionist evaluates the program, including results of hand hygiene and bag technique observations made during supervisory visits, and reports to the governing body through QAPI.

All staff complete infection control training at orientation and every year. The infection preventionist completes infection prevention training appropriate to home health, as the Agency’s own standard, and keeps up with CDC and MDHHS guidance.

This policy implements the following authorities.

• 42 CFR §484.70, Condition of participation: Infection prevention and control
• 42 CFR §484.65, Condition of participation: Quality assessment and performance improvement (QAPI)
• MCL 333.5111, Reportable diseases; rules for reporting (FindLaw copy, current as of January 1, 2025)
• Mich. Admin. Code R 325.171 to R 325.174, Communicable Disease Rules (Cornell LII copy)
• Mich. Admin. Code R 325.70005 and R 325.70007, MIOSHA Part 554, Universal precautions and work practices

The following documents are read together with this policy.

This policy is adopted by the governing body of Sample Agency, LLC. The effective date, the person who approved it, and the date of approval are shown in the header block and recorded in the signature lines below.

Every version of this policy, the date it took effect, a summary of what changed, and who approved it is recorded below. Where a rule cited in Section 16 is amended, the amendment is recorded in this table and a new version of this policy is issued.