Dignity Alliance generally applauds the Department’s attention to infection control and believes this should be a priority for ALL skilled nursing facilities, not only in some new specialized facility.
The Department deserves commendation for requiring responsible infection prevention and control of any new or amended DON serving one of the specialized populations identified in the Memorandum dated October 6, 2020.
In addition to the conditions listed in the Memorandum, we believe that the applicant must be required to report infections as they occur to the Department of Public Health and to the Centers for Disease Control and Prevention through the CDC’s National Health Safety Network (NHSN).
All staff in a specialized facility must be trained in infection prevention and control and work toward certification through programs such as InfectionControlsTraining.com that offer training and certification on infection prevention and control for individuals as well as organizations. A wide range of infection prevention and control topics should be specified to be covered through training such as chain of infection, prevention and control, hand hygiene, personal protective equipment, environmental controls, sharps and injection safety, occupational health, sepsis, etc. Case studies are also important to apply principles learned to real world situations. The infection prevention and control program must be supervised by a full-time infection preventionist who is a registered nurse.
The specialized facility must commit to maintaining an adequate supply of PPE and testing materials and operationalize a policy of regular testing of staff and residents. In addition, all staff must be vaccinated for influenza, pneumonia, and – when available – COVID-19.