CMS Publishes Updated Critical Element Pathways to Address Enhanced Barrier Precautions

Infection Prevention/Control; CMS; Safety
 

On April 1, 2024, the Centers for Medicare and Medicaid (CMS) updated the following survey critical element pathways (CEPs) due to the enforcement of enhanced barrier precautions (EBP) outlined in QSO-24-08-NH.  
 
  1. CMS-20054 Infection Prevention Control and Immunization  
  2. CMS-20068 Urinary Catheter or UTI  
  3. CMS-20070 Dental  
  4. CMS-20071 Dialysis  
  5. CMS-20078 Pressure Ulcer  
  6. CMS-20081 Respiratory Care  
  7. CMS-20093 Tube Feeding 

The largest change is noted in CMS-20054 Infection Prevention, Control and Immunization: 
 
“Enhanced Barrier Precautions (EBP):  
EBP use is evaluated when investigating specific care activities, such as wound care, enteral feeding, urinary catheter care, etc.  

EBP are indicated during high contact care activities for residents with infection or colonization with a CDC targeted MDRO (when contact precautions do not apply) or for any resident who has a chronic wound and/or indwelling medical device.  

High-contact resident care activities include dressing, bathing/showering, transferring, toileting, providing hygiene, changing linens or briefs, device care or use: central line, urinary catheter, feeding tube, tracheostomy/ventilator, or wound care: generally, for residents with a chronic wound(s), not skin breaks or tears covered with an adhesive bandage (e.g., Band-Aid) or similar dressing.  

  • Interview staff to determine if they are aware of which residents require the use of EBP prior to providing high-contact care activities.  
  • Is PPE readily available to staff?”  

 
The remaining CEPs have updates under “Observations” and “Critical Element Decisions” to incorporate EBP and when to cite F880 during survey. 

Questions regarding these updates may be sent to regulatory@ahca.org​.