OIG Reports on Home Health Agency Infection Control Audit
WASHINGTON, D.C. (October 5, 2021)—An audit of eight home health agencies (HHAs) by the Department of Health and Human Services Office of the Inspector General (OIG) found that most had infection control policies and procedures that met the standards set by the Centers for Medicare & Medicaid Services (CMS) and followed CMS COVID-19 guidance to safeguard Medicare beneficiaries, caregivers, and staff during the coronavirus pandemic, according to a report issued last week.
The policies and procedures at the eight HHAs were specifically reviewed to determine whether they included:
(1) guidance for following standards of practice,
(2) a coordinated agencywide infection control program, and
(3) infection control education for HHA staff, Medicare beneficiaries and caregivers.
Agencies were also reviewed to determine whether they followed CMS COVID-19 guidance for:
(1) screening patients,
(2) screening staff, and
(3) treating patients with known or suspected COVID-19.
The eight HHAs chosen for the audit were also given a questionnaire about their policies and procedures. The eight providers consisted of three of the largest HHAs in the country and five other HHAs that were chosen because they were cited for infection prevention and control deficiencies during surveys conducted in 2019 and 2020 for review.
The results were that:
• seven of the eight HHAs had infection prevention and control activities that met CMS requirements;
• six of the eight HHAs had policies and procedures that met the CMS COVID-19 specific guidance;
• one provider did not meet either the CMS infection prevention and control activities or the CMS COVID-19 guidance.
The OIG did not determine whether these HHA providers had infection prevention and control issues related to the implementation of the policies and procedures. However, state survey agencies identified issues with implementation at several of these HHA providers, as indicated by infection prevention and control deficiencies found during surveys conducted in 2019 and 2020.
Because the audit is based on a judgmental sample of HHA providers, results cannot be projected to HHA providers not included in the sample. However, the OIG did provide some potential best practices identified as part of the audit. They are summarized below.
Screening Staff for COVID-19
• Policies and procedures that required daily COVID-19 screenings for staff conducted and documented prior to starting the workday to assess for symptoms, possible exposure, and recent travel.
• Using a variety of methods to instruct staff on the appropriate actions to take if they develop symptoms or are exposed to a person with known or suspected COVID-19. Seven of the HHAs audited developed policies and procedures, COVID-19 exposure decision trees, and reporting systems to record symptoms and infections and track actions taken by staff and management. These HHA providers required staff to self-isolate immediately and notify the supervisor for exposure tracking. They required staff to remain out of work until they met appropriate return-to-work criteria set by CMS and CDC.
Caring for Patients With Known or Suspected COVID-19
• Having policies and procedures for using PPE while treating Medicare patients during the COVID-19 pandemic
• Using a variety of tools to instruct staff on using PPE properly. These HHA providers developed policies and procedures, PPE flow charts, and diagrams to clarify the appropriate PPE for staff. These policies and procedures included instructions for properly using, reusing, and disposing of PPE and the protocol for PPE when supplies are low.
• Updating infection control education for staff, patients, and caregivers to be consistent with the latest guidance from CMS and CDC. The compliant providers provided infection control education through onsite supervision, online training, inservices, and posters and handouts for patients and caregivers.
Screening Patients for COVID-19
• Having policies and procedures that require COVID-19 screening for patients and caregivers to assess for symptoms, possible exposure, and recent travel. These policies and procedures required patients to be screened via a telephone call prior to the HHA visit, if possible. Screening tools included online reporting systems, questionnaires, and checklists.
• Utilizing a variety of tools to document patient screening – policies and procedures, COVID-19 exposure decision trees, and reporting systems to record symptoms and infections and track actions taken by staff to safeguard the patient. Compliant HHAs used patient exposure decision trees and guidance to clarify the appropriate actions staff should take if patients report symptoms or are exposed to a person with known or suspected COVID-19.
CMS concurred with the OIG’s recommendation for CMS to develop and share with the home health industry information on COVID-19 infection prevention and control best practices that HHA providers can use to comply with CMS requirements and follow CMS guidance. CMS stated that it has provided education and outreach to HHAs on CMS quality and safety standards to support their infection prevention and control efforts and will continue to share information on best practices with the home health industry.
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