CMS recently shared survey guidance relating to handwashing while assisting residents at meal time and to eye drop expiration dating. CMS shared it with state survey agencies last week.
Handwashing (F880)
Q: Must nursing assistants wash their hands with soap and water or use hand sanitizer between feeding residents?
A: Alcohol-based hand rub (ABHR) can be used between the touching of residents or after removal of gloves (if using gloves and there is contact with the resident, gloves should be removed and hand hygiene performed) instead of soap and water unless hands are visibly soiled.
Q: If you are assisting a resident at meal times, must you wash hands before and after touching their silverware?
A: Ideally staff should feed only one resident at a time however, they can assist multiple residents if they sanitize their hands between residents (e.g., handling silverware) with either soap and water or ABHR (soap and water if visibly soiled, and ABHR is allowed if not visibly soiled).
Q: Where in the regulation is this addressed?
A: §483.80(a)(2) Written standards, policies, and procedures for the program, which must include, but are not limited to:
(i) A system of surveillance designed to identify possible communicable diseases or infections before they can spread to other persons in the facility;
(ii) When and to whom possible incidents of communicable disease or infections should be reported;
(iii) Standard and transmission-based precautions to be followed to prevent spread of infections;
(iv)When and how isolation should be used for a resident; including but not limited to:
(A) The type and duration of the isolation, depending upon the infectious agent or organism involved, and
(B) A requirement that the isolation should be the least restrictive possible for the resident under the circumstances.
(v) The circumstances under which the facility must prohibit employees with a communicable disease or infected skin lesions from direct contact with residents or their food, if direct contact will transmit the disease; and
(vi)The hand hygiene procedures to be followed by staff involved in direct resident contact.
The regulation and section on hand hygiene can be found on page 679 of the State Operations Manual, Appendix PP.
Eye Drop Expiration Dating (F761)
You asked for help in directing you to the proper protocol for eye drop expiration dating that is required of nursing homes. The nursing home regulations and interpretive guidance expect nursing home staff to adhere to accepted professional standards of practice related to medication administration and use of multi-dose containers such as eye drops.
First, we want to clarify that a manufacturer expiration date is the point at which a manufacturer can no longer guarantee the strength and effectiveness of a medication. Because the expiration date is established by testing a drug in specific conditions such as specific storage containers, lighting, and temperature, effectiveness of the medication is compromised by changing any of these conditions. Manufacturer expiration dates only apply when the drug product is stored in the manufacturer’s original, unopened container under defined conditions.
Eye drops in multi-dose packaging contain preservatives to ensure the sealed product remains sterile. After opening however, the preservative can only ensure the drops are safe for the eye for a period of 28 days. Beyond 28 days, using the drops may cause serious damage to the eye as bacteria may have been introduced.
Therefore, the standard of practice is that nursing home staff should record the date eye drops are opened and should not use them after 28 days unless the manufacturer provides a longer period for which the drops can be used after opening (Note: This site works best on Google Chrome).
We recommend checking the package insert for manufacturer recommendations. If the manufacturer does not provide a time frame for discarding the eye drops after opening, then the 28-day standard of practice is recommended.
