Empath Home Health

“Infection Prevention CFR(s): 484.70(a) Standard: Infection Prevention. The HHA must follow accepted standards of practice, including the use of standard precautions, to prevent the transmission of infections and communicable diseases. This Standard is not met as evidenced by: Based on observations, interviews and policy review the provider failed to ensure hand hygiene was completed properly and ensure multi-use equipment was cleaned for one (#1) of one patient observed during wound care and failed to utilize cleanable dedicated single-patient gait belts for two (#5 and #7) of three residents observed participating in physical therapy. The findings included: 1. On 4/20/26 at 11:04 a.m. Patient #1 was observed sitting upright in recliner with bilateral legs raised. During the visit Staff A, Registered Nurse (RN) arrived at the patients home. The staff member placed a barrier on next to the patients legs, below the knee and removed wound care supplies from a nearby cardboard shipping box. The staff member removed a 3x3 packaged foam dressing, a packaged black sock, a stack of unpackaged gauze squares, a roll of absorbent rolled foam gauze, a spray bottle of wound cleanser, a roll of cohesive rolled dressing, bottle of ammonium lactate, an opened package of an antibacterial foam dressing, and an open package of a clear fibrous material. Staff A rummaged through the shipping box to locate the patient’s scissors, removing a pair from the box, and placing them onto the clean wound care supplies. The scissors slid off the supplies onto the carpeted floor. The staff member cleaned the scissors with a germicidal wipe before using them to cut off the toe to knee cohesive and foam wrap dressing from the patient’s right lower extremity. Staff A removed gloves (used during the removal of old dressing), turned to clinical bag and removed other gloves, donning them without hand hygiene. The staff member placed the scissors used to cut off the old dressing on top of the clean wound care supplies, removing the inner dressing. The staff member sprayed the wound cleanser onto wound and dapped the area with gauze squares before using the dirty scissors to cut a small square from clear fibrous material (placed on wound) and a square of the antibacterial foam dressing (placed on wound), applied skin protectant to peri-wound, and applied ammonium lactate to the lower extremity. Staff A removed gloves, donning a clean pair without hand hygiene, wrapped right lower extremity with rolled foam, using the scissors to cut off unused portion, wrapped with cohesive and applied black sock, The staff member removed gloves and sanitized hands. The staff member stated after the scissors had fallen on floor they had been cleaned before removing old dressing. The staff member did not report cleaning the scissors after removing the old dressing and before cutting the antibacterial foam, clear fibrous material, rolled foam, and the cohesive dressings. Staff A reported working as needed (prn) for the agency. 2. On 4/21/26 at 10:30 a.m. Staff B, Physical Therapist (PT) was observed with Patient #5. The staff member removed an unpackaged thick woven gait belt made from a cotton-like material from the clinical bag and placed around the torso of the patient. The belt was labeled with the first name of the therapist. The patient stood against the kitchen island as Staff B, standing nearby, instructed on exercises. 3. On 4/21/26 at 1:59 p.m. Staff C, Physical Therapy Assistant (PTA) was observed with Patient #7. The staff member placed an unpackaged white thick woven gait belt made from a cotton-like material on a protective barrier. The PTA stated the gait belt was the staff member’s and it was cleaned with an alcohol pad. During an interview on 4/21/26 at 5:22 p.m. the home health agency administrator stated staff received hand hygiene education annually and during quarterly onsite visits. The administrator stated hand hygiene should be performed upon entering the home, performing invasive procedures (including dressing changes, before entering (clinical) bag, and in between glove changes. The administrator reported liking to use plastic gait belts, some clinicians have their own belts, patients should have their own gait belts and Thera-bands. The woven cotton gait belt should be cleaned with a Sani wipe “but it would be wet”, dampen it. The administrator reported not thinking the agency had a policy on disinfecting a gait belt. During the exit conference on 4/21/26 at approximately 6:30 p.m. the video attendees, including but not limited to the Vice President of Clinical Operations and the Infection and Employee Health Director, agreed a woven gait belt should not be used for multiple patients and the one labeled with the staff members name was not the patients. Review of the Hand Hygiene Observation Tool showed Staff A missed the opportunity for hand hygiene after every glove removal and did not perform hand hygiene for at least 20 seconds and was compliant with hand hygiene 82 out of 100%. The home health agency did not provide a policy on hand hygiene or cleaning of a gait belt. The agency provided incomplete policies (missing pages). Review of the policy (#497) Infection Control Plan, reviewed 7/28/25, showed the home health agency: 4. Prevent infections associated with the use of medical equipment, devices, and supplies: “(home health agency) implements infection prevention and control methods to reduce infections associated with medical equipment, devices, and supplies.” “EBSCO Dynamic Health skills procedures are referenced regarding the proper storage, disposal, cleaning, and disinfection of medical equipment such as stretchers, wheelchairs, walkers, intravenous (IV) poles, and commodes, as well as electronic equipment, and other supplies.” The provided documentation did not address the cleaning of scissors after removing an old dressing and preparing clean wound care materials or the use of patient – dedicated gait belts. Review of the policy (IC. 101.A) – Clinical Bag Technique defined Standard Precautions as “Precautions used for all patient care to protect health care providers from infection and prevent spreading infections from patient to patient from both recognized and unrecognized sources. This includes assessing the need for additional personal protective equipment (PPE) before healthcare activity, proper hand and respiratory hygiene, and proper handling of needles and patient care equipment or devices/ supplies.” The policy showed contamination was the “Introducing infectious material or pathogenic organisms on or into a normally clean area.” The policy did not address cleaning equipment (scissors) between dirty and clean tasks (removing old dressing and cutting clean wound care materials) and the use of patient-dedicated gait belts. Review of Centers of Disease Control and Prevention (CDC) guidelines, Clinical Safety: Hand Hygiene for Healthcare Workers (https://www.cdc.gov/clean-hands/hcp/clinical-safety/index.html), dated 2/27/2024, pointed hand hygiene was to “Protect yourself and your patients from deadly germs by cleaning your hands”. The recommendations included: Before moving from work on a soiled body site to a clean body site on the same patient.After touching a patient or patient’s surroundings.Immediately after glove removal.The guidance instructed “Gloves are not a substitute for hand hygiene” and “Always clean your hands after removing gloves.” Review of a healthcare supplier website (https://www.medline.com/strategies/safe-mobility/gait-belt-option-tips/) showed there were three (3) types of gait belts available: single-patient use, launderable, and wipeable. The single-patient use was made from a woven cotton/polyester blend. The photo was similar to what was observed other than the color.Launderable was made from polypropylene with a plastic quick release claspWipeable was made from vinyl or polyurethane-coated woven material and could be disinfected between each use.”

“Provide services in the plan of care CFR(s): 484.75(b)(3) Providing services that are ordered by the physician or allowed practitioner as indicated in the plan of care; This Element is not met as evidenced by: Based on observations, record review, policy review, and interviews the provider failed to provide wound care as described for one (#1) of one patient who received wound care in the plan of care and as ordered by the physician. The failure could promote microbial growth resulting in an infection and/or delay of healing. Findings included: On 4/20/26 at 11:04 a.m. Patient #1 was observed sitting upright in recliner with bilateral legs raised. During the visit Staff A, Registered Nurse (RN) arrived at the patients home. The staff member obtained necessary wound care supplies from a shipping box placing them on a barrier set next to the resident’s left leg. The observation showed Staff A spraying wound cleanser onto the resident’s right ankle and begin dapping the area with gauze squares for approximately 30 seconds to one (1) minute. The staff member continued with wound care placing a clear fibrous material, an antibacterial foam dressing, and skin protectant to the area before applying lotion, rolled foam and cohesive dressing from toes to below the knee. Immediately following the observation an interview was conducted with Staff A, RN who stated the wound had been washed and she had not timed the cleaning of the wound. Review of Patient #1’s Plan of Care showed the patient was admitted on 12/3/25 with diagnoses including but not limited to stage 3 pressure ulcer of right ankle. The provider was to visit the patient twice a week for 8 weeks for wound complications. The physician orders instructed to perform/teach pressure ulcer are to right lower extremity malleolus as follows: cleanse peri wound and wound bed with (name brand) wound solution, apply wound solution soaked gauze to wound bed x 5 minutes, apply skin prep to peri wound and apply (name brand) (wound matrix), apply to layer compression system to base of “toast” to two finger widths below the knee. The plan of care received from the provider was electronically signed by the nurse practitioner (NP) on 4/13/26. During an interview on 4/21/26 at 5:22 p.m. the administrator stated staff are to follow physician orders and if the order was to keep (name brand) (wound solution) on for 5 minutes it should have been. Review of the policy – Plan of Care, reviewed 7/5/23, showed “An individualized plan of care is developed utilizing the comprehensive and an initial assessment, as well as information provided by member of the interdisciplinary team and the physician that:” c. “Physician orders, comprehensive assessment, and patient input. Progress/ non-progress toward achieving the goals is evaluated through measurable outcomes.””