COVID-19: Infection Prevention & Control Efforts Start at the Top

I am writing based on my experiences as a registered nurse surveyor. In this role, the registered nurse is tasked with visiting Skilled Nursing Facilities to review facility practice to ensure compliance with state and federal regulations and laws. Inherently, our work processes are confrontational. And unfortunately surveyors have realized increased confrontation during COVID-19. Whether it is because emotion and burnout are high, or because facilities find compliance with CDC and state guidance too challenging, costly or difficult, or for some other reason, HFENs are experiencing more confrontation.

This past weekend, I observed a facility administrator terminate a COVID-19 state monitoring visit. The administrator terminated the visit after being asked about the role of the administrator and/or Infection Preventionist when determining where to place a person under suspicion for COVID-19. The facility was not compliant with CDC recommendations, and the Infection Preventionist stated the administrator helped the facility make infection prevention decision. Moreover, the state in which the facility operated required the facility to consider the infection implications of residents’ bed placement.

SNFs operate in an industry regulated 24 hours a day, seven day a week, 365 days a year. To demonstrate compliance, SNFs should be required to demonstrate equal, of not greater importance toward infection prevention and control compliance than their GACH (e.g., acute care hospitals) counterparts. Unlike GACHs, SNFs care for residents in a congregate living environment. Also, Administrators of SNFs perform licensed work, for their licensed facility and pursuant to an administrator license. Honest, candid discussion with state regulators should be a requirement for each administrator’s license. That an administrator can terminate a visit by asserting the subjective feeling of being “bull[ied]” by a surveyor seeking information germane to the quality of care is disingenuous.

State regulatory agencies guide SNF leadership toward developing quality, person-centered processes. When communication between a facility and state agency breaks down, the most vulnerable may lose support as well as the strength of their voice. It is never appropriate to gamble on the lives of the frail and elderly, especially during the COVID-19 Pandemic.


James Shannon

Nursing Leader | Quality Leader | Healthcare Attorney

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