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 protects patients, caregivers and staff from infections and communicable diseases through prevention, early identification, control and education.

This policy covers all care given in patients’ homes, the Agency’s office and branches, and the equipment and supplies staff carry, whatever the payer.

For the purposes of this policy, the following terms have the meanings below. Ohio’s home health licensing law (ORC Chapter 3740 and OAC Chapter 3701-60) and 42 CFR Part 484 say "patient"; the Ohio Medicaid rules (OAC Chapters 5160-1, 5160-12 and 5160-32) say "individual". This policy uses "patient" for the same person.

The Agency maintains and documents an infection control program which has as its goal the prevention and control of infections and communicable diseases (42 CFR §484.70). The Agency follows accepted standards of practice, including the use of standard precautions, to prevent the transmission of infections and communicable diseases (42 CFR §484.70(a)). It 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 QAPI program, and the program includes "A method for identifying infectious and communicable disease problems" and "A plan for the appropriate actions that are expected to result in improvement and disease prevention" (42 CFR §484.70(b)). "The HHA must provide infection control education to staff, patients, and caregiver(s)." (42 CFR §484.70(c)).

• The clinical manager is responsible for the program and designates an infection prevention lead in writing. The lead has training in infection prevention and keeps current with guidance from the Centers for Disease Control and Prevention (CDC) and the Ohio Department of Health.
• Each year the lead writes a program plan with priorities drawn from surveillance data, incidents, audits and new guidance, which the QAPI committee approves (Policy OH-HH-QA-01).
• The lead reports surveillance results, audits and actions to the QAPI committee at every meeting and at least quarterly, as the Agency’s own standard.

• Hand hygiene: on arrival and before leaving the home, before and after touching the patient, before clean or aseptic procedures, after contact with body fluids, after touching the patient’s surroundings, and after removing gloves. Use alcohol-based hand rub unless hands are visibly soiled; then wash with soap and water. Staff carry hand rub and their own paper towels and liquid soap.
• Personal protective equipment: wear gloves for contact with blood, body fluids, mucous membranes or non-intact skin; add a gown, mask and eye protection when splashes or sprays are likely. Put on and remove PPE in the right order and dispose of it in the home in a bag the household trash will take, unless it is regulated waste (Policy OH-HH-IC-02).
• Respiratory hygiene: staff with a cough wear a mask; patients and family are offered masks and taught cough etiquette.
• Safe injection practices: one needle, one syringe, one time; single-dose vials for one patient only; aseptic technique for all injections and line access.
• Sharps safety and environmental cleaning as set out in Policy OH-HH-IC-02 and Section 7.

• Choose a clean, dry work surface in the home and place a barrier before setting down the bag or supplies. Do not place the bag on the floor or bed.
• Perform hand hygiene before reaching into the bag. Take out only what is needed for the visit; supplies taken into a home on transmission-based precautions are left there or discarded.
• Reusable equipment (stethoscopes, blood pressure cuffs, thermometers, pulse oximeters, glucose meters) is cleaned and disinfected with an EPA-registered disinfectant according to the manufacturer’s instructions after each patient, before it goes back into the bag. Where possible, equipment stays in the home for that patient only.
• In the car, clean supplies and soiled items are kept apart in separate closed containers. Bags and car storage are cleaned at least weekly, as the Agency’s own standard.
• Clinical supplies are stored at the office in a clean, dry area off the floor, rotated by expiration date.

• At referral, intake staff ask about known infections or multidrug-resistant organisms and tell the assigned clinicians.
• Contact precautions (for example, for MRSA in a draining wound or Clostridioides difficile): gown and gloves for care, dedicated equipment, and soap and water for hand hygiene after care of a patient with C. difficile.
• Droplet precautions (for example, influenza): a facemask for close contact, and a mask for the patient if tolerated.
• Airborne precautions (for example, suspected or confirmed active tuberculosis or measles): a fit-tested N95 or higher respirator under the respiratory protection program (Policy OH-HH-IC-03; 29 CFR §1910.134). Only staff who are fit-tested and medically cleared visit.
• Where practical, patients on transmission-based precautions are scheduled as the last visit of the day, as the Agency’s own standard.
• Precautions and the reason are recorded in the plan of care and on the aide care instructions.

• Method for identifying problems (42 CFR §484.70(b)(1)): clinicians report each new infection a patient develops while on service, and each infection of a staff member that could be passed to patients, on Form OH-HH-IC-01-A or in the electronic log. The lead also reviews hospitalizations, emergency visits, antibiotic orders and wound and catheter records for infections that were not reported.
• The lead uses recognized surveillance definitions so that cases are counted the same way each month, and records for each case the type of infection, devices in use, the organism if known, and whether it may be related to Agency care.
• Each month the lead analyzes the log by type of infection, device, team and clinician, and compares it with earlier periods.
• A cluster (two or more related infections in a short period, or any infection with an unusual organism) is investigated at once: review of the care given, observation of practice, and staff interviews. Findings and actions are recorded.
• Plan for improvement (42 CFR §484.70(b)(2)): the lead writes an action plan for each problem found, such as retraining, changes in supplies or procedures, or more observation, sets a date to check whether it worked, and reports it through QAPI.

• When an Agency clinician knows or suspects that a patient or staff member has a disease on Ohio’s reportable disease list (OAC Chapter 3701-3, including OAC 3701-3-02), the clinician tells the clinical manager the same day.
• The clinical manager confirms whether the patient’s physician or a laboratory has already reported the case and, where Ohio’s reportable disease rules place the duty on the Agency or its staff, reports it to the local health district in the time and manner those rules set. The lead keeps the current Ohio list and reporting instructions with this policy.
• If an outbreak among Agency patients or staff is suspected, the clinical manager contacts the local health district for advice, as the Agency’s own standard, and follows its directions.
• The Agency cooperates with health district investigations and contact tracing, sharing only the health information the law permits (Policy OH-HH-PRV-01).

Staff health screening, immunizations, tuberculosis screening and work restrictions for illness are set out in Policy OH-HH-IC-03. Staff who are ill with a condition that could spread to patients tell their supervisor before the visit and do not visit until cleared. Exposure incidents are handled under Policy OH-HH-IC-02.

• Staff and individuals under arrangement receive infection control education at orientation, before the first patient visit, and at least every year, as the Agency’s own standard, and when the program finds a problem (42 CFR §484.70(c)).
• Patients and caregivers receive infection control education matched to their needs, such as hand hygiene, care of devices and wounds, safe disposal of dressings and sharps, cleaning the home, and when to call the Agency about signs of infection. Teaching is recorded in the clinical record with the patient’s or caregiver’s response (42 CFR §484.70(c)).

• Every aide supervisory assessment and on-site observation checks compliance with infection prevention and control policies and procedures (42 CFR §484.80(h)(4)(iv); Policy OH-HH-AID-02).
• The lead or a designee observes each clinician’s hand hygiene, PPE use and bag technique at least once a year, as the Agency’s own standard, using a written checklist.
• Audit results are reported to QAPI and used to plan education.

The emergency preparedness program (Policy OH-HH-EP-01) is based on an all-hazards risk assessment (42 CFR §484.102(a)(1)) that includes infectious disease outbreaks, as the Agency’s own standard. During an outbreak or pandemic the clinical manager may change visit practices, PPE use and screening of staff and patients to follow current CDC, Ohio Department of Health and local health district guidance, and records each change and its date.

Accountability under this policy is allocated as follows.

The surveillance log (Form OH-HH-IC-01-A), monthly analyses, investigations, action plans, audit checklists, the annual program plan and education records are kept for six years, as the Agency’s own standard. Patient teaching and precautions are recorded in the clinical record. The infection rate by type and the audit results are QAPI measures (Policy OH-HH-QA-01).

All staff are trained on this policy at orientation and at least every year. Clinicians are also trained on bag technique, equipment cleaning and transmission-based precautions with a return demonstration before their first visit. The infection prevention lead completes training in infection prevention before taking on the role.

This policy implements the following authorities.

• 42 CFR §484.70, Condition of participation: Infection prevention and control
• 42 CFR §484.65, QAPI; 42 CFR §484.80(h)(4)(iv); 42 CFR §484.102(a)(1)
• 29 CFR §1910.1030, Bloodborne pathogens; 29 CFR §1910.134, Respiratory protection
• OAC Chapter 3701-3, including OAC 3701-3-02, Ohio reportable diseases
• CDC, Guideline for Isolation Precautions and standard precautions guidance (accepted standards of practice)

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 18 is amended, the amendment is recorded in this table and a new version of this policy is issued.