The Centers for Medicare & Medicaid Services (CMS) released QSO-24-08-NH in March 2024, the Memorandum pertaining to Enhanced Barrier Precautions (EBP) in Nursing Homes. While many facilities already had these precautions in place in some form based on CDC guidelines prior to March, they, along with those who had not yet implemented this program, may not be fully aware of all that the requirements entail.
Due to the increased prevalence of Mulitdrug Resistant Organisms (MDROs) in healthcare settings, especially in long term care, the CDC introduced the Enhanced Barrier Precautions as a new approach to the use of PPE back in 2019. In 2022, the CDC released an updated version of these recommendations; therefore, CMS decided to update its infection prevention and control guidance accordingly under F880, Infection Control.
When are Enhanced Barrier Precautions Indicated?
The CMS guidance indicates that EBP are indicated for residents with any of the following:
- Infection or colonization with a CDC-targeted MDRO when Contact Precautions do not otherwise apply; or
- Wounds and/or indwelling medical devices even if the resident is not known to be infected or colonized with a MDRO.
CMS stipulated that EBP should be used for any residents who meet the above criteria, wherever they reside in the facility. However, they also indicated that facilities have discretion in using EBP for residents who do not have a chronic wound or indwelling medical device and are infected or colonized with an MDRO that is not currently targeted by CDC.
CMS outlined what they refer to as “high-contact resident care activities” noting that EBP should be followed during these types of activities:
- Dressing
- Bathing/showering
- Transferring
- Providing hygiene
- Changing linens
- Changing briefs or assisting with toileting
- Device care or use: central line, urinary catheter, feeding tube, tracheostomy/ventilator
- Wound care: any skin opening requiring a dressing
Consider these best practices to effectively implement EBP within your facility:
- Develop and implement your EBP policy. However, remember, that any policy is only as good as how it is being followed by your staff, therefore the next important practices is #2.
- Train your staff. Train on your policy, the CMS requirements outlined in the QSO and include demonstration/return demonstration of when to use EBP and which PPE will be needed.
- Assess your residents to determine who will need EBP put in place and implement this as per the CMS guidelines which can be found at: https://www.cms.gov/files/document/qso-24-08-nh.pdf
- Monitor staff compliance with your EBP policy. Perform care observations routinely and as part of your QAPI program.
While the circumstances are slightly different than when most transmission-based precautions are utilized, EBP is an important component in your Infection Prevention and Control program. When EBP is implemented successfully, you will have a strong defense against the spread of MDROs within your facility. Interested in improving your IPC program? Join us for the Proficient Infection Prevention Series currently underway through July with any missed sessions available on demand. Contact Proactive for expert nurse consultant support in implementing EBP and any other area of quality care and clinical regulatory compliance.
Written by Janine Lehman, RN, RAC-CT, CLNC
Director of Regulatory Services
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