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Ebola Update--CDC Issues New Protocols

Written By: Rachel Irving Pitts

Copyright 2014, American Health Lawyers Association, Washington, DC. Reprint permission granted.
This post was originally written for an email alert to the Regulation, Accreditation, and Payment (RAP) Practice Group of the American Health Lawyers Association. Our thanks to AHLA for permission to reprint here. 

The response to Ebola continues to evolve as additional resources for providers and the public have been made available over the last several days. The Joint Commission (TJC) launched an Ebola Preparedness Resources webpage, which hosts TJC's relevant internal resources and links to "credible, useful outside resources," including the Centers for Disease Control and Prevention (CDC). While stressing that the CDC remains a primary source of information regarding Ebola, TJC is providing these resources in response to providers' expectations for guidance, and asking providers to focus on infection prevention by performing a comprehensive evaluation of their practices and providing ongoing infection prevention education, training, and assessment. Non-compliance with infection prevention standards (hand hygiene, use of personal protective equipment (PPE), sterilization, and disinfection) is a persistent issue encountered by TJC when it surveys its accredited hospitals. The Ebola Preparedness Resources webpage includes educational podcasts, infographics, and articles on infection prevention and control and managing contagious patients, along with New England Journal of Medicine and Journal of the American Medical Association articles about Ebola, media coverage, and links to external resources--including the CDC's "Guidance on Personal Protective Equipment To Be Used by Healthcare Workers During Management of Patients with Ebola Virus Disease in U.S. Hospitals, Including Procedures for Putting On (Donning) and Removing (Doffing)."

The CDC has outlined more than 30 steps for donning and doffing (removing) PPE in its new protocols for Ebola caregivers. The guidance, issued on October 20, goes into great detail on correctly managing the process, physical environment, and equipment used while caring for Ebola patients, focusing on three identified principles:

  • Ebola caregivers must undergo rigorous training, practice, and competency demonstrations for proper PPE use;
  • There should be no skin exposure when donning the PPE used by Ebola caregivers; and
  • Ebola care must be overseen by an on-site manager, and a trained observer will supervise PPE donning and doffing by each health care worker caring for Ebola patients.

These new procedures are more stringent than the protocols previously followed, which required goggles, thereby permitting some skin exposure, as opposed to full face shields. The guidelines instruct providers to create separated, clearly labeled spaces for PPE storage and donning, including the patient area, the patient room, and the PPE removal area, which must be located so that the health workers are visible to the trained observer and can hear his or her spoken step-by-step instructions for doffing the PPE. The procedures are methodical and standardized, and include repeated disinfection. A hospital's PPE should allow health care workers to provide care safely and effectively--if a facility does not choose one of the two PPE options recommended by the CDC, they must properly adjust the donning and doffing protocol, and train their workers appropriately.

In another CDC Fact Sheet about Ebola, which can be accessed directly from the CDC, the CDC stresses that PPE is only one component of proper Ebola care and management, and reminds providers that there are other important aspects of infection prevention and control. TJC will continue to update its Ebola Preparedness Resources page, and urges providers to check back regularly. Providers should focus on continuous and rigorous training and practice of methodical, systematic procedures to ensure competence and safety in dealing with this (and any other) infectious disease.

 

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Author

Rachel Irving Pitts is an Associate at Mintz. Her practice involves transactional and regulatory matters, including mergers and acquisitions, regulatory compliance review, telemedicine issues, and provider and service contracting matters. Rachel's clients include health care providers and payors.