Fresenius Medical Care Greenbrier County

“IC-SANITARY ENVIRONMENT CFR(s): 494.30 The dialysis facility must provide and monitor a sanitary environment to minimize the transmission of infectious agents within and between the unit and any adjacent hospital or other public areas. This Standard is not met as evidenced by: 38282 Based on observation, document review, and staff interview, it was determined Patient Care Technician (PCT) staff failed to properly sanitize their hands and change their gloves when applying a dressing to a fistula following treatment, and when changing a Central Venous Catheter (CVC) dressing prior to the initiation of treatment. This failure has the potential to adversely affect all patients. Findings include: Review of policy, titled “Personal Protective Equipment,” published 11/06/23, stated in part: “Personal protective equipment including a full-face shield or mask and protective eyewear with full side shield, fluid-resistant gowns, and gloves, must be worn to protect employees from blood or other potentially infectious materials ... (e.g. during initiation and termination of dialysis, cleaning of dialyzers, and centrifugation of blood) ... Staff must remove gloves and wash hands after: patient care, exposure to blood and body fluids, and touching any surfaces within the patient station ...” An observation was conducted on 12/04/23 at 3:32 p.m. of PCT #1 dressing a fistula at the end of treatment at station #8. The patient had been disconnected from the machine, and a pressure dressing had been applied. The patient was wearing a face mask, and had donned a glove and was holding pressure to the site. PCT #1 removed their gloves, sanitized their hands, and donned gloves. PCT #1 proceeded to program the computer, gather and discard the tubing, and collect patient belongings and hang them on the back of the wheelchair. PCT #1 then checked the fistula site, added tape, and held pressure for a few seconds without changing their gloves. Several times during the procedure, PCT #1’s face mask was noted to be improperly worn below the nose, prompting readjustment without washing hands or replacing gloves. An observation was conducted on 12/05/23 at 10:30 a.m. of PCT #2 changing the dressing on a CVC prior to the initiation of treatment at station #7. PCT #2 was observed removing and discarding the old dressing and a bandaid on the right chest next to the dressing, cleaning the CVC exit area with antiseptic and allowing it to dry, then applying a new dressing, all while donning the same gloves. Following the procedure, hands were sanitized and gloves were changed. The patient wore a mask throughout the procedure. An interview conducted on 12/05/23 at 12:50 p.m. with a Registered Nurse (RN) confirmed that PCT #1 and PCT #2 had not followed established protocols, and that the improper use of personal protective equipment (PPE) increases the chance of infection. The RN stated, “Whenever I see the staff performing improper procedures or the misuse of PPE, I address it immediately with that staff. We also hold annual training sessions for all staff.””

“IC-GOWNS, SHIELDS/MASKS-NO STAFF EAT/DRINK CFR(s): 494.30(a)(1)(i) Staff members should wear gowns, face shields, eye wear, or masks to protect themselves and prevent soiling of clothing when performing procedures during which spurting or spattering of blood might occur (e.g., during initiation and termination of dialysis, cleaning of dialyzers, and centrifugation of blood). Staff members should not eat, drink, or smoke in the dialysis treatment area or in the laboratory. This Standard is not met as evidenced by: 38282 Based on observation, document review, and staff interview, it was determined Patient Care Technician (PCT) staff failed to wear proper personal protective equipment (PPE) when applying a dressing to a fistula following treatment, changing a Central Venous Catheter (CVC) dressing prior to the initiation of treatment, and cleaning and preparing a station between patients. This failure has the potential to adversely affect all patients. Findings include: Review of policy, titled “Personal Protective Equipment,” published 11/06/23, stated in part: “Personal protective equipment including a full-face shield or mask and protective eyewear with full side shield, fluid-resistant gowns, and gloves, must be worn to protect employees from blood or other potentially infectious materials ... (e.g. during initiation and termination of dialysis, cleaning of dialyzers, and centrifugation of blood) ... Staff must remove gloves and wash hands after: patient care, exposure to blood and body fluids, and touching any surfaces within the patient station ...” Review of policy, titled “Exposure Task List,” revised 10/10/08, delineates the PPE equipment required during various procedures, and states in part: “Gowns, face shields, and face masks are to be worn, and hand hygiene and gloves are to be changed: After each patient contact care activity when touching any part of the dialysis machine or equipment at the dialysis station, ... Change catheter dressing, ... and stripping machine after patient treatment ... Footnotes: When face shield is used a mask is also required to prevent airborne contamination of catheter exit site from breath escaping under the edge of the face shield patient must also wear a mask.” An observation was conducted on 12/04/23 at 3:32 p.m. of PCT #1 dressing a fistula at the end of treatment at station #8. The patient had been disconnected from the machine, and a pressure dressing had been applied. The patient was wearing a mask and had donned a glove, and was holding pressure to the site. PCT #1 removed their gloves, sanitized their hands, and donned gloves. PCT #1 then proceeded to program the computer, gather and discard the tubing, and collect patient belongings. PCT #1 then checked the fistula site, added tape, and held pressure for a few seconds without changing their gloves. Several times during the procedure, PCT #1’s face mask was noted to be improperly worn below the nose, prompting readjustment without washing hands or replacing gloves. An observation was conducted on 10/05/23 at 10:30 a.m. of PCT #2 changing the dressing on a CVC prior to the initiation of treatment at station #7. The patient was wearing a mask. PCT #2 was observed removing and discarding the old dressing, cleaning the CVC exit area with antiseptic and allowing it to dry, then applying a new dressing, all while donning the same gloves. Following the procedure, hands were sanitized and gloves were changed. An observation was conducted on 12/05/23 at 10:50 a.m. of PCT #1 cleaning and preparing station #3 between patients. PCT #1 wore the face shield improperly on the top of the head, and the face mask was noted to be improperly worn below the nose, prompting readjustment throughout the procedure. An interview conducted on 12/05/23 at 12:50 p.m. with a Registered Nurse (RN) confirmed that PCT #1 and PCT #2 had not followed established protocols, and that the improper use of PPE increases the chance of infection. The RN stated, “Whenever I see the staff performing improper procedures or the misuse of PPE, I address it immediately with that staff. We also hold annual training sessions for all staff.” Regarding not wearing the proper PPE to clean the machine, the RN confirmed that the staff “was not wearing the PPE properly and they needed to because of the risk of bleach splash back.” An interview was conducted on 12/06/23 at 10:30 a.m. with the Clinical Manager (CM) regarding the use of PPE. The CM concurred that wearing a face shield on the top of the head and a mask under the nose was not the proper use of PPE.”