Select Specialty Hospital - South Dakota

“NURSING SERVICES CFR(s): 482.23 The hospital must have an organized nursing service that provides 24-hour nursing services. The nursing services must be furnished or supervised by a registered nurse. This Condition is not met as evidenced by: 45383 A. Based on record review, interview, and policy review, the provider failed to ensure an order was obtained for the daily wound care provider for one of one sampled patient (3) who had drain site wounds. Findings include: 1. Record review of patient 3’s electronic medical record (EMR) revealed: *On 4/22/24 at 11:34 a.m. patient 3 had been admitted with a diagnosis of: -Acute respiratory failure, cerebral vascular accident (CVA), aortic valve replacement, atrial fibrillation (irregular heart rhythm), deep venous thrombosis (DVT). *On 4/22/24 at 8:24 p.m. an initial nursing assessment completed by registered nurse (RN) D revealed: -Patient 3 had four drain site wounds to his upper abdomen. -RN D had measured and photographed the wounds and provided wound care that had included iodoform packing to each drain site, and then covering with a silicone dressing. --This assessment by RN D had been performed nine hours after patient 3’s admission. *On 4/23/24 at 8:00 a.m. and 8:34 p.m. documentation indicated patient 3’s dressing was a non-adherent dressing. *On 4/24/24 at 8:00 a.m. and 8:00 p.m. documentation indicated patient 3’s dressing was a non-adherent dressing. *On 4/25/24 at 7:43 a.m., 8:00 p.m., and 4/26/24 at 8:00 a.m. documentation indicated patient 3’s wounds were open to air (not covered with a dressing). *On 4/26/24 at 12:30 p.m. documentation by RN G indicated that patient 3’s wounds had been measured and wound care was provided that had included iodoform packing to each drain site, and then coving the wound with a silicone dressing. *There had not been any order for daily dressing changes for patient 3 entered in his EMR. *On 4/30/24 patient 3 had a rapid response (a decline in a patient’s health requiring specialty health services) due to his declining health status. 2. Interview on 5/22/24 at 9:00 a.m. with RN wound care nurse B regarding wound care for patient 3 revealed: *She had received the order for his wound care evaluation on 4/29/24. *She completed the evaluation of patient 3 on 5/1/24 and clarified the orders that had been placed on 4/26/24. -She worked Monday through Friday and on off hours house supervisor nurses would have completed wound care. *Patients have wound care evaluated completed within 24 hours of receiving an order. 3. Interview on 5/22/24 at 2:25 p.m. with medical doctor (MD) C regarding patient 3’s history and physical including his wounds revealed: *He did not remember receiving any information on patient 3’s wounds and his wound care. *He would have put wound care orders in the EMR system with the assistance of the wound care nurse and skin team. *He had not documented patient 3’s wounds in his history and physical. *He had not assessed patient 3’s wounds. 4. Interview on 5/22/24 at 3:34 p.m. with MD K regarding wound care revealed: *Patient 3 had developed bacteremia and required a rapid response intervention on 4/30/24. *He could not confirm or deny that patient 3’s delay in wound care could have contributed to his rapid response on 4/30/24. *He stated proper documentation and sign off are very important for good patient care. 5. Interview on 5/22/24 at 3:51 p.m. with RN D regarding wound care for patient 3 revealed: *She had first assessed patient 3 on 4/22/24 on during the night shift. *She removed his dressing and packing that he was admitted with, documented his wounds, and packed them with iodoform gauze and covered the wounds with a silicone dressing. *RN D reviewed patient 3’s orders and noticed there had not been any orders in his EMR for his wound care. *She had passed on her wound care to the morning shift during report and then she was off work for a few days. *If a patient had arrived after hours and on a weekend when the wound nurse was not working, house supervisors would have provided wound care until the wound nurse returned. *She had been concerned that patient 3 had not received any wound care 4/22/24 until 4/26/24. 6. Interview on 5/23/24 at 9:00 a.m. with RN G regarding patient 3’s wound care revealed: *She had completed a dressing change to patient 3’s drain sites on 4/26/24. *She had found a transfer sheet from the sending provider with instructions for patient 3’s wound care and dressing change they had provided. *RN G had informed the hospitalist that day and received an order for daily and as needed dressing changes to patient 3’s drain sites. 7. Review of the provider’s July 2021 Admission of patient to the unit revealed: *” A registered nurse will perform the initial assessment of the patient upon admission to the nursing unit and place the appropriate identification bracelets on the patient.” *” Initial assessment should be done within the first 8 hours of admission.” B. Based on observation, and interview, the provider failed to ensure maintained visualization of dialysis catheters by two of two observed contracted RN (F and H) had maintained visualization for two of two patients (7 and 8) during their dialysis treatment. Finding include: 1. Observation and interview on 5/22/24 at 10:30 a.m. with RN F during patient 7’s dialysis treatment revealed: *RN F had been sitting at a portable computer desk. *Patient 7 had her left hand elevated on pillows. *RN F had not been able to visualize patient 7’s dialysis catheter due to patient 7 moving the pillow. *After RN F was asked about dialysis catheter visualization, she adjusted patient 7’s pillow and then asked the surveyor if that was good enough. *She was unsure of what she needed to have constant visualization of. 2. Observation and interview on 5/22/24 at with RN H during patient 8’s dialysis treatment revealed: *Patient 8’s catheter and dialysis connection sites had been covered by a part of the absorbent pad on his chest. *RN H stated she had been able to visualize patient 8’s catheter and connection site while seated at her portable computer desk. *RN H got up from her portable computer desk and uncovered the non-visible portion of the dialysis catheter. *She stated she had recently obtained vital signs on patient 8 and the absorbent pad had covered the catheter and connection site for only a few minutes. 3. Interview on 5/23/24 at 4:15 p.m. with director of quality management E regarding competencies (demonstration of fundamental skills) on contracted RNs revealed: *She had only performed competencies on contracted staff for infection control practices. *They had not received any dialysis completed competencies for the contracted nurses from the contracted service. *Their expectation that competencies are completed annually with contracted nurses by the contracted service that provided dialysis. *She agreed that constant visualization of catheters during dialysis was very important for patient safety. A request for a policy for contracted dialysis had been made prior to exit. The provider did not have a policy.”

“INFECTION PREVENTION CONTROL ABX STEWARDSHIP CFR(s): 482.42 The hospital must have active hospital-wide programs for the surveillance, prevention, and control of HAIs and other infectious diseases, and for the optimization of antibiotic use through stewardship. The programs must demonstrate adherence to nationally recognized infection prevention and control guidelines, as well as to best practices for improving antibiotic use where applicable, and for reducing the development and transmission of HAIs and antibiotic resistant organisms. Infection prevention and control problems and antibiotic use issues identified in the programs must be addressed in collaboration with the hospital-wide quality assessment and performance improvement (QAPI) program. This Condition is not met as evidenced by: 45383 50715 A. Based on observation, interviews, and policy review, the provider failed to ensure two of four observed glucometers had been cleaned and disinfected properly prior to patient use. Findings include: 1. Observation on 5/21/24 at 9:30 a.m. of one glucometer docked outside of room 2475 revealed it had visible blood near the glucometer strip insertion site and on the backside of the machine. 2. Interview on 5/21/24 at 9:33 a.m. following the above observation with registered nurse (RN) D regarding the visible blood on the glucometer revealed: *The glucometer having been in the docking station meant it had been cleaned, disinfected, and ready for patient use. *She: -Confirmed there was visible blood on the glucometer in the docking station. -Agreed that it was not cleaned and disinfected prior to docking it in the station. -Would have someone clean and disinfect it right away. 3. Observation on 5/21/24 at 11:08 a.m. at the nurse’s station located in the north hallway revealed a glucometer in the docking station that had visible blood on the front, sides, and back of the machine. Interview on 5/21/24 at 11:30 a.m. with director of quality management (DQM) E and chief nursing officer (CNO) I regarding the docked glucometers revealed: *After use, the glucometers should have been cleaned and disinfected with a purple top disinfectant wipe per the manufacturer’s recommendations and placed in the docking station. *When the glucometers were in the docking station, they were considered by staff as cleaned, disinfected, and ready for patient use. 4. Observation on 5/22/24 at 8:22 a.m. of the same docked glucometer at the nurse’s station located in the north hallway again revealed visible blood on the same areas as observed on 5/21/24 at 11:08 a.m. 5. Interview on 5/22/24 at 8:37 a.m. with DQM E regarding the above observation revealed: *The docked glucometer should have been cleaned, disinfected, and ready for patient use. *She agreed that the above glucometer had visible blood on it and it and required cleaning and disinfection. *She would clean and disinfect it immediately. 6. Interview on 5/22/24 at 8:40 a.m. with RN A regarding docked glucometers revealed he stated: *”If the glucometer is in the docking station it is clean and ready for patient use.” *”Glucometers are cleaned with a purple top wipe and the contact time is two minutes.” 7. Review of the provider’s October 2023 Cleaning: Environment, Patient Equipment and Medical Devices policy revealed: *”If it is unclear where or not the equipment is clean, it must be cleaned before use. *The standard of cleanliness is that all parts of the equipment including the underneath be visibly clean with no blood and body substances, dirt, debris, dust, adhesive tape, stains or spillage.” B. Based on observation, interviews, and monthly infection control rounding tool review, the provider failed to ensure wound care for one of one sampled patient (3) had been performed using a clean technique by one of one observed registered nurse (RN) B. Findings include: 1. Observation on 5/21/24 at 9:54 a.m. with RN B while performing wound care to patient 3 revealed she: *Washed her hands and put on a pair of clean gloves. *Removed the dressing and packing from four drain sites located on patient 3’s abdomen. *Removed her gloves, washed her hands, and put on a new pair of clean gloves. *Placed dressing supplies next to the sink and the patient’s clothing without a clean barrier under the wound care supplies. *Irrigated the drain sites with normal saline and wiped them with gauze. *Removed her gloves, washed her hands, and put on a pair of clean gloves. *She opened a sterile Q-tip, layed it on the bedsheet, cut a string of iodoform gauze, and placed the scissors on the bedsheet. *She then used that same Q-tip to pack one drain site with iodoform gauze. *She repeated that same process three more times using the same technique all with those same gloved hands. *With those same gloves she applied a silicone dressing over four drain sites, removed the gloves, and washed her hands. *She then placed the scissors she had used in a locked drawer of a cabinets in the patient’s room that contained clean supplies. -She had not cleaned the scissors prior to placing them in that drawer. 2. Interview on 5/22/24 at 2:20 p.m. with RN B regarding a clean surface for wound care supplies revealed she: *Stated she had wiped the surface near patient 3’s sink with a purple top disinfectant wipe before setting wound care supplies down on it and prior to the surveyor arriving. *Considered a clean workspace to be dry, not visibly dirty, and by using a clean sheet, disposable pad, or towel under the supplies. *Considered the area by the sink to be clean workspace if it had been wiped with a purple wipe. *Confirmed she had placed the scissors used to cut the iodoform dressing back into the drawer with other clean wound care supplies without cleaning it. *Remembered receiving education regarding contaminated equipment must be cleaned and stored appropriately, and to designate a clean area for wound care supplies. 3. Interview on 5/22/24 at 4:13 p.m. with DQM E regarding proper handing, storage of wound care supplies, and monthly infection control rounds tool revealed she: *Stated the patient’s bed sheet would not have been considered a clean surface. *Confirmed a disposable pad or a clean towel should have been used as a barrier. *Would have expected the monthly infection control rounds tool as a policy. 4. Review of the provider’s monthly infection control rounds tool revised June 2022 revealed, “Clean/Sterile items are not stored within 3 ft of the sink.””

“INFECTION CONTROL SURVEILLANCE, PREVENTION CFR(s): The infection prevention and control program includes surveillance, prevention, and control of HAIs, including maintaining a clean and sanitary environment to avoid sources and transmission of infection, and addresses any infection control issues identified by public health authorities; and This Standard is not met as evidenced by: 42558 Based on observation, interview, record review, and policy review, the provider failed to ensure proper infection control practices were maintained for three of three observed patients (2, 3, and 4) during wound care dressing changes by one of one wound care registered nurse (RN)(D). Findings include: 1. Observation and interview on 3/13/24 at 8:30 a.m. of patient 4’s multiple dressing changes with RN D and an unidentified nursing student in the patient’s room revealed: *The patient had a recent surgery on her left hip. *RN D worked as the provider’s wound care nurse since August of 2023. *RN D removed the dressing supplies from a supply closet and from a treatment cart located outside of the patient’s room. -She entered the patient’s room and placed those unopened supplies directly onto the patient’s bedding. *She sanitized her hands, applied a clean pair of gloves, removed the patient’s socks, palpated her heels, and asked about her pain. -Using those same gloved hands, she: -Removed a gauze dressing from the patient’s left lateral knee area and palpated around and squeezed the edges of a small skin incision that contained approximately 4 staples. -Removed two large dressings from the patient’s left lateral hip and palpated around and directly on top of both suture sites that contained multiple staples with surrounding dark purple skin. *She then removed those gloves, sanitized her hands, applied a clean pair of gloves, and then lifted the patient’s abdominal and axillary skin folds and inspected underneath her breasts and armpits. -Using those same gloved hands, she removed a dressing from the patient’s right side of her neck, identified that the site was a previous central line access area, and palpated directly on the small scabbed area that remained. *She removed those gloves, sanitized her hands, and applied a clean pair of gloves. -With the assistance of the unidentified nursing student, she rolled the patient onto her right side and inspected her back and lifted her buttocks to view her perineal area. -Using those same gloved hands, she picked up a cellular phone and took pictures of all the above mentioned wounds by placing the same paper measuring tape directly onto the patient’s skin above each surgical area. *She removed those gloves, sanitized her hands, applied a clean pair of gloves, then she: -Removed the unopened packages of dressings from the patient’s bedding and opened the dressing packages. -Set the opened packages directly on the patient’s over-bed table, pulled a pen marker out of her uniform pocket and dated the new dressings. -Returned the opened dressings onto the patient’s bedding. -Using those same gloved hands, she applied the clean dressings to the two left hip surgical sites. -The sites above the left knee and the right neck remained uncovered. *None of the surgical sites were cleansed after the removal of the soiled dressings, after being touched by her gloved hands, or before the application of the clean dressings. *She disposed of the used dressing supplies, removed her gloves, and sanitized her hands. -Without wearing gloves, she picked up the unsanitized cell phone and marker pen, opened the patient’s door, and returned those items to the hallway treatment cart’s tabletop surface before those items were sanitized. Review of resident 4’s electronic medical chart revealed: *She was admitted on 3/6/24 with the following diagnoses: intertrochanteric (hip) fracture with open reduction and internal fixation (ORIF); acute exacerbation of chronic obstructive pulmonary disease (COPD); type 2 diabetes mellitus with hyperglycemia; acute kidney injury (AKI) due to sepsis; and mixed anxiety with depressive disorder. *A 3/6/24 physician’s order for her above-the-knee and left hip dressing changes included cleansing the sites with normal saline before the application of clean Telfa (non-adherent) dressings. -That process was not observed during the dressing changes. 2. Observation and interview on 3/13/24 at 8:55 a.m. of patient 3’s dressing change with RN D revealed: *RN D stated she had become certified in wound care in July of 2023. *She carried a cell phone and paper measuring tape into patient 3’s room and placed those items directly onto a treatment cart located in the patient’s room. -The patient’s clothing was piled on top of the treatment cart’s surface. *RN D sanitized her hands and applied a clean pair of gloves, she then: -Removed the dressing supplies from the treatment cart and placed the unopened dressing supplies on a washcloth that was placed on the patient’s bedding. -Removed a large absorbent dressing from the center of the patient’s abdomen which revealed a large surgical incision from the middle of his abdomen extending down to the lower abdomen. -The surgical incision contained multiple staples and had a light pink periphery which extended out approximately three centimeters around the incision site. -There was an ileostomy (part of the small bowel that was brought through the abdominal wall via a surgically-created opening called a stoma) collection bag located on the right mid-abdomen next to the surgical incision. -There was an approximate one-centimeter circular, deep, drainage-type skin opening just below the lower abdominal incision that had drained a moderate amount of yellow-colored drainage onto the removed dressing. *RN D removed her gloves and without sanitizing her hands she then: -Removed one clean glove from a glove container, then returned that glove into that same container of clean gloves. -Sanitized her hands and applied a pair of gloves from that same container. -She placed the measuring tape on the patient’s skin next to the surgical site and used her cellular phone to take a picture of the site. -She placed the phone back on the treatment cart next to the patient’s clothing. *Using those same gloved hands, she irrigated the surgical sites with a needleless syringe of sterile saline and dabbed the moistened sites with a sterile gauze pad. *After cleansing those surgical sites, and using those same gloved hands, she then: -Palpated the entire periphery of the incision and then pushed down lightly on the stapled incision along the entire length of the abdomen. -Picked off a small piece of loose skin from one of the staples. *She removed her gloves, sanitized her hands, applied a clean pair of gloves, and then she: -Removed scissors and more dressing supplies from the treatment cart, opened packages of dressings, cut a piece of absorbent foam dressing, then placed the scissors on top of the treatment cart next to the cellular phone and the patient’s clothing. -Removed a marker from her uniform pocket and dated the dressings. -Returned the unsanitized scissors into a drawer on the treatment cart. *Using those same gloved hands, she: -Applied the dressings onto the patient’s surgical site. -She disposed of the soiled dressing supplies, removed her gloves, and sanitized her hands. *Without wearing gloves, she then picked up the unsanitized cell phone and marker pen, opened the patient’s door, and returned those items to the hallway treatment cart’s tabletop surface. -She opened the treatment cart’s drawer and removed a sanitizing cloth, then applied a pair of clean gloves. -She sanitized the cell phone and the marker, then placed them back onto the same unsanitized surface of the cart. -She wiped the surrounding cart surfaces with the sanitizing cloth. Review of resident 3’s electronic medical chart revealed: *He was admitted on 2/24/24 with the following diagnoses: small bowel obstruction; Crohn’s disease of both small and large intestine with intestinal obstruction; moderate protein-calorie malnutrition; hypoalbuminemia due to protein-calorie malnutrition; essential hypertension; and bipolar disorder. *A 3/5/24 physician’s order for the patient’s surgical site to have been cleansed with normal saline and covered with absorbent dressings when the dressings were no longer intact or when damp, moist, or saturated. -That process was observed during the dressing change. 3. Observation on 3/13/24 at 9:45 a.m. of patient 2’s dressing change with RN D revealed: *RN D removed the dressing supplies and an unopened bottle of normal saline from the treatment cart located in the hallway and set them on top of a closed laptop computer on the cart’s surface. -She then carried those supplies, a cellular phone, and a measuring tape, into the patient’s room and placed them, unopened, on a disposable barrier pad. *The patient had a large abscessed wound located on her abdomen and a recent right sided above-the-knee amputation surgical site. *She sanitized her hands, and applied a clean pair of gloves. -She inspected and directly touched dried scabs that were located on the patient’s above-the-knee amputation surgical site. -Using those same gloved hands she: -Removed several large absorbent dressings from the patient’s mid-abdomen exposing layered gauze in a wound bed. -Removed the dried gauze that was layered into an abscessed cavity exposing a large, meaty-appearing, full-thickness abdominal abscess with the approximate circumference of a basketball. -Covered the patient’s abdominal abscess using the hospital gown the patient was wearing. *She then removed her gloves, sanitized her hands, and applied a clean pair of gloves. -Using one of her gloved hands, she pulled the hospital gown up and off the abdominal abscess site and tucked the gown along the patient’s breast line. *Using those same gloved hands, she: -Opened a package of gauze and opened the normal saline bottle. -Poured the normal saline onto the gauze pad and cleansed the abscessed site using a wiping motion in a right-to-left, top-to-bottom fashion. -Reached over to the room’s garbage can and pulled it closer to the bed to dispose the used gauze dressing. -Opened another package of gauze and sporadically patted the wound bed with that gauze until the abscess was mostly dry. *She removed her gloves, sanitized her hands, applied a clean pair of gloves, she then: -Picked up the cellular phone and measuring tape, applied the measuring tape directly onto the patient’s skin next to the abscess, and took pictures of the abdominal abscess. -Placed the cellular phone back on the disposable barrier pad and discarded the measuring tape. -Opened a package of rolled gauze, held the gauze over the garbage can, and poured the sterile normal saline onto the gauze. *Using those same gloved hands, she then: -Unrolled and layered that wet gauze into the abscess’s wound bed, covering the majority of the abscessed site. -Removed several large absorbent pads from the packaging. -Removed a marker pen from her uniform pocket, and dated the absorbent pads. *She removed her gloves, and without sanitizing her hands, she applied a clean pair of gloves and applied those large dressings over the layered, wet gauze. -She left an approximate two-inch section of abscessed wound exposed on the lower right side of the patient’s abdomen. *She removed her gloves and sanitized her hands. -With her bare hands she removed a roll of tape from the resident’s closet. -She placed the tape on the resident’s blanket laying on the bed. *Without sanitizing her hands, she applied a clean pair of gloves and taped the edges of the dressings to the patient’s skin. *She placed tape directly onto the small section of the exposed abscess on the lower right side of the patient’s abdomen. *She removed her gloves and sanitized her hands. -With her bare hands, she opened the patient’s closet door and placed the tape inside. *Without sanitizing her hands, she: -Applied a clean pair of gloves, removed the barrier pad, and placed it into the garbage. -Removed those gloves, opened the patient’s door, and carried her unsanitized cellular phone and pen back to the treatment cart in the hallway. -Applied a clean pair of gloves, opened the treatment cart drawer, and removed a sanitizing cloth from the treatment cart. -Sanitized the cellular phone and the pen, then placed them onto the back side of a clipboard that was lying face down on the treatment cart. Review of resident 2’s electronic medical record revealed: *She was admitted on 2/15/24 with the following diagnoses: peripheral artery disease (PAD) with gangrene of the right lower extremity, status-post right above-the-knee amputation (AKA), obesity, deep vein thrombosis, acute respiratory failure with hypoxia, hypertension, encephalopathy, sleep apnea, seizure disorder, bipolar disorder, and covid related pneumonia. *A current 3/5/24 physician’s order for “7 o’clock of abdominal wound apply Ag rope drsg [dressing] and cover with duoderm. Dressing change weekly and as needed.” -That dressing application was not observed during the dressing change. *A 3/8/24 physician’s order to “Cleanse the abdominal wound with normal saline and apply moist-to-moist kerlix to wound bed, cover with ABD [abdominal dressing], and secure with tape.” -That order had not indicated if the dressing change was to have been a clean procedure or a sterile procedure. Interview on 3/13/24 at 12:45 p.m. with RN D regarding the above wound care observations revealed: *Regarding patient 4’s observation: -She confirmed dressing removal was considered a dirty procedure. -She stated she had not felt that touching scabbed or approximated skin areas using the same gloved hands as the dressing removal was considered a potential for contamination, and was not concerned about using the same gloves for the dressing removal. -She could not remember if she had touched the hip incisions with those same gloved hands. *Regarding patient 3’s observation: -She stated the only wound she had been concerned with was the drain hole opening below the incision, and she had only touched around that site. -She could not remember touching the staples following the cleansing of the stapled incision. -She stated, “The top of the wound, for me, is already healed and the skin is intact. I was pulling off dead skin. I was not worried about touching it (with the gloves she had used during dressing removal).” -She confirmed patient 3’s abdominal incision still had staples remaining in his skin. *Regarding patient 2’s observation: -She could not remember pulling the garbage can closer to the bed during her cleansing of the patient’s abscess. -She stated if she had done that, she would normally have removed her gloves and sanitized her hands. -She had cleansed the marker after each use and before she placed it into her uniform pocket. -She agreed that she had placed her bare hands in her uniform pocket multiple times a day and that could have been considered an unclean environment. A dressing change policy had been requested on 3/13/24 following the above observations and interview of RN D. Director of nursing services (DNS)(B) stated there was not a specific dressing change policy. She stated those subjects were covered in the dressing change competency audits of wound care staff. Interview on 3/14/23 at 12:46 a.m. with the director of quality management (C) and DNS (B) regarding the above dressing change observations revealed: *The expectation was for hand hygiene and application of clean gloves following the removal of used dressings. *They expected a barrier pad to be used for a sterile dressing change, but it was not expected for a clean dressing change. *Confirmed palpating directly over or around multiple surgical sites with the same gloves used in a dressing change was not a clean procedure and not their expectation. *They confirmed there were multiple missed opportunities for RN D to have performed proper hand hygiene and glove use. *RN D had been audited for wound care competency and had passed. Review of RN D’s 9/6/23 competency audits for: Sterile dressing; Non-sterile dressing; and Applying gauze and elastic bandages, revealed she had met all the audit criteria expectations. The non-sterile dressing audit had not included hand hygiene and changing gloves following cleansing of the wound and before the application of clean dressings. Review of the provider’s April 2023 Hand Hygiene policy revealed: *Hand hygiene was to be performed: -“2. Before and after every patient contact[.]” -“3. Between patient care activities within the same episode of care[.]” -“4. When moving from high contamination patient care activities/if moving from a contaminated body site to a less contaminated body site (peri-care to trach care)[.]” -“9. Between glove changes and after removing gloves[.] After any contact with body fluids, dressings, patient linen[.]” -“11. Before going into a patient room and before leaving a patient room[.]” Review of the provider’s April 2023 Standard Precautions policy revealed: -“4. Gloves will be changed after every patient contact, when moving from dirty to clean task...” -“10. Hand hygiene must be performed prior to putting on gloves[,] after removing gloves. Gloves do not replace the need for hand hygiene.” -“Patient Care Equipment: 1. Patient care equipment known to be contaminated with infective material should be cleaned with a disinfectant-germicidal solution at the point of use...””