Understanding F880 and Infection Control in Long-Term Care Facilities

Regulatory surveys are an obligation in all long-term care (LTC) settings. No matter where a health care worker is located, annual visits are conducted to verify adherence to state and federal regulations. Within the Veterans Health Administration (VHA), VHA’s Community Living Centers are evaluated by the Long-Term Care Institute. One advantage is that programs can access the most frequently cited deficiencies in the previous 3 months across the nation to assess their own competency. An FTag (F is for federal) is a clinical deficiency in infection prevention and control, which most infection control practitioners try to avoid.¹

FTags represent compliance areas assessed in a CMS Survey by the Centers for Medicare & Medicaid Services (CMS).² State agencies and CMS use FTags to identify deficiencies that indicate a community’s adherence to CMS standards and guidelines. Each tag links to a specific section of the Code of Federal Regulations, based on the regulations outlined in 42 CFR Part 483.60. Overall, the CMS State Operations Manual for Long-Term Care Communities outlines a total of 209 FTags.²

Senior living and LTC facilities must obtain CMS certification to receive Medicare and Medicaid payments.² This certification process involves the state's Department of Health & Human Services inspections. These surveys are performed annually and can also be prompted by complaints. State officials may arrive without prior notice, and the duration of these surveys can vary from 3 to 5 days based on the size of the facility. After the initial survey, follow-up inspections, reporting, or assessments might be necessary. A negative survey outcome can lead to substantial penalties, halted payments, and required corrective actions.

Case Study: Mr. Smith is a 78-year-old male who resides at an LTC facility. An LTC surveyor is sitting at his bedside discussing several care issues. An assistant comes into the room to take the resident’s blood sugar. When finished, the surveyor sees her cross the hall to the next resident and take his blood sugar with the same machine without it being cleaned.

A few minutes later, the surveyor sees a lab technician enter a contact isolation room across the hall with no isolation gown on. She proceeds down the hall to the next resident she needs to draw blood from. Next, a nurse enters the patient's room using contact precautions to perform care. She removes her gloves and exits the room without performing any hand hygiene before moving to the next patient. The facility now has multiple findings for infection control.

F880 (Infection Prevention and Control

An F880 (Infection Prevention and Control) is one of the most frequently cited deficiencies in the country in LTC facilities, according to CMS.³ The agency is looking for proof that infection control programs both prevent and control infections within the population of their facility. Speaking from personal experience, I have seen some programs often forget ancillary services and visitors who can become vectors for germs. When training direct care staff on infection control, also educating dietary, social services, chaplains’ services, environmental services, and visitors is essential. These individuals visit residents on a routine basis and often do not get assigned the infection prevention curriculum that skilled care staff are assigned.

Enhanced Barrier Precautions

F880 also addresses enhanced barrier precautions (EBPs).⁴ On March 20, 2024, CMS issued a new QSO Memo, "Enhanced Barrier Precautions in Nursing Homes," effective April 1, 2024.

EBPs are an infection control strategy to minimize the transmission of multidrug-resistant organisms (MDROs). This is achieved through targeted gown and glove usage during high-contact care activities between residents and staff, which could facilitate the transfer of multidrug-resistant organisms (MDROs) to staff hands or clothing.

According to this new QSO memo, EBPs should be implemented⁵ for residents with any of the following conditions: Infection or colonization with a CDC-targeted MDRO when contact precautions are not applicable or the presence of wounds or indwelling medical devices, even if the resident is not infected or colonized with an MDRO. Here, wounds refer to chronic wounds like pressure ulcers or unhealed surgical wounds, not temporary wounds such as skin breaks covered with a dressing. Indwelling medical devices include urinary catheters, tracheostomies, central lines, and feeding tubes.

How to Prepare for Survey With F880

During the past 90 days, 11 of 35 deficiencies were infection control findings in VHA LTC facility surveys⁶ (as of this writing). The 3 most common findings were hand hygiene, wound care, and personal protective equipment use. With these results in mind, ensure that the annual review of your infection control plan addresses the risks specific to the community and population being served. One size does not fit all in this case. Since facilities can range from assisted living to total care for spinal cord injury patients, the plan needs to reflect the population’s risks.

Ensure surveillance activities are analyzed, and gaps and repeat findings are thoroughly addressed. Are all partners who enter the resident’s area aware of infection prevention protocols? There should be action for immediately implementing corrective and preventive measures to result in improvement. Don’t wait for a write-up to be the reason to assess vulnerabilities in your infection control program.

References:

1. List of Revised FTags. US Department of Health & Human Services Guidance Portal. Accessed October 22, 2024.https://www.hhs.gov/guidance/document/list-revised-ftags
2. Understanding F-tags. Culinary Services Group. Accessed October 22, 2024. https://culinaryservicesgroup.com/f-tags/
3. Twenter P. Most frequent CMS citations in 2024. Becker's Hospital Review. September 19, 2024. Accessed October 21, 2024. https://www.beckershospitalreview.com/quality/most-frequent-cms-citations-in-2024.html
4. F-tag help -- f880 infection prevention and control. Accessed October 22, 2024. https://www.licamedman.com/ftag/761/f880-infection-prevention-and-control
5. Study highlights successes and challenges in implementing enhanced barrier precautions in nursing homes. Infection Control Today. Accessed October 22, 2024. https://www.infectioncontroltoday.com/view/study-highlights-successes-challenges-implementing-enhanced-barrier-precautions-nursing-homes
6. Phillips R. Ascellon Surveys of VA Community Living Centers, Quarterly Citation Trends for April-June 2024. Office of Geriatrics and Extended Care; 2024.