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An Update on CAH Safe Medication Practices

A recently CMS-rewritten infection control standard for CAHs addresses safe medication practices, which are currently being hit very hard during surveys.

If the medication is available as a single dose, it should be purchased. If the medication is only available in a multi-dose vial, then the nurse should use the multi-dose vial on one patient and never take it into the patient’s room. The expiration date should be marked on the vial.

CMS also has a section in the infection control worksheet on safe injection practices. Even though surveyors are using the worksheets in CAHs, hospitals should still carefully review this worksheet to ensure compliance. It’s an important self-assessment tool that should not be overlooked.

Safe medication preparation starts at tag 278. Medications should be prepared in clean areas. Proper hand hygiene should be performed before handling any medication. The rubber septum should be disinfected with alcohol before piecing it. Standard practice is to disinfect it with alcohol for 15 seconds and allow to dry. Aseptic technique should be used when preparing medications and administering injections. Never administer medication from the same syringe to more than one patient, even if the needle is changed. Never enter a vial or IV with a used syringe or needle. Single-dose vials and IV bags can be used only on one patient. A mask must be worn when placing a catheter in the epidural, spinal or subdural area.

The 10 CDC safe practices can be found in the Guidelines for Isolation Precautions: Preventing Transmission of Infectious Agents in Healthcare Settings.

All CMS memos can be found here.

Rehabilitation Therapy Updated for Consistency

The rehab standards were omitted from the CAH in June 2013 when several changes were made to the manual. The revised manual contains a section on rehab beginning at tag 299. Rehab services must be provided by qualified staff, including physical therapy, occupational therapy, and speech-language pathology. Hospitals are allowed to have up to a 10-bed separate unit for both rehab and behavioral health and the standards in Appendix A must be followed. The rehab standards are consistent between the two manuals.

Rehab is on optional services so a hospital does not have to provide it. It can be provided directly or through contracted services. Hospitals that contract this out should make sure the contracted service is assessed through the contract management standards.

There must be an order for the rehab. The hospital must have a rehab policy and procedure and the requirements in this section should be part of the rehab policy. The care must be consistent with the standard of care so hospitals should be familiar with positions statement promulgated by organizations like the American Physical Therapy Association and the American Occupational Therapy Association.

The patient must have a plan of care, which must be outlined before treatment begins. It can be done by an MD/DO, physical therapist, occupational therapist, or speech-language pathologist. The plan of care must prescribe the type, amount, frequency, and duration.