The COVID-19 pandemic drew attention to infection prevention and control in assisted living and other types of senior care facilities, but not all of that attention was positive.
Regulators, including at the Center for Disease Control and Prevention (CDC), were updating infection prevention and control guidance with the skilled nursing model of care in mind – and they were applying it to the full long term care industry.
But it’s not that simple. For example, the CDC guidance called for nurses to play specific roles related to vaccination and administration of medications. Many assisted living facilities, unlike skilled nursing, don’t have nurses on staff. Also, in many states, assisted living operators are not permitted to administer vaccines and medications to residents.
“It might have been appropriate for skilled nursing, but there were things in there that didn’t work for our sector,” recalls John Schulte, a quality consultant who works with Argentum.
Other organizations with a stake in the guidelines agreed and quickly formed a group to develop IPC guidelines specifically for assisted living. They included the American Seniors Housing Association, LeadingAge, and the National Center for Assisted Living. Together with Argentum and the National Association for Regulatory Administration, the organizations formed the Quality in Assisted Living Collaborative (QALC). The group invited representatives from CDC, consumer advocates, a physician working in assisted living, and state regulators to participate and to review its work.
“It took us a year and a half of working with CDC to get them to realize we needed to make some changes, that we need guidance that’s a good fit for the resources we have, the limitations we work with, and the resident population we serve,” says Schulte, who led the QALC process.
This week, in tandem with the release of QALC Infection Prevention and Control Guidelines for Assisted Living Communities, Argentum has unveiled a companion resource, the Infection Prevention and Control Toolkit for Assisted Living Communities, specifically to help assisted living operators put the QALC IPC guidelines into action.
Self-Regulation
When the federal government or state governments step in to regulate an industry, Schulte observes, it is almost always because the industry sector is not doing a good job of self-regulating. “That’s generally not the best scenario for us,” he quips.
Instead, industry-led efforts such as the one stood up by the QALC, can ward off burdensome regulations by demonstrating that an industry sector is, in fact, providing the appropriate resources and guardrails to achieve regulators’ overall goals.
In the case of infection prevention and control, Schulte says assisted living already was doing a great job. “We don’t need to raise the bar. We don’t need to make up new things. We don’t need to retrain people. We don’t have to do all this extra burdensome stuff.”
The QALC Approach
The QALC focused its efforts on documenting current IPC processes and policies and identifying essential elements of an IPC plan. As a result of this approach, Schulte says most companies in assisted living are already doing what is recommended by the forthcoming QALC IPC guidelines.
QALC partners see a role for its guidelines to improve awareness of the sector’s commitment to infection prevention and control. “It will be free. It will be available to members, nonmembers, anybody who wants to look at it, they’ll be able to get a copy,” Schulte says.
Moreover, Schulte says the QALC IPC guidelines will enable self-evaluation. “If you have an issue, do a debriefing. Do we do the things that are called for? Are those things working? If not, what changes do we need to make?”
The QALC will consider feedback from users of its IPC plan guidelines and may issue updates in the future. “If we need to make changes, instead of waiting for somebody else to come in and regulate our industry, we’ll make those changes ourselves,” Schulte says, adding that the QALC will “probably work on about a five-year cycle” to evaluate the need for changes.
Finally, QALC partners anticipate a need to educate the industry about the guidelines. “We think we wrote something one way. Somebody’s going to read it a different way,” Schulte says. To promote clarity, QALC collaborators will present webinars and speak at industry conferences.
Argentum IPC Toolkit
Schulte says the Argentum resource, Infection Prevention and Control Toolkit for Assisted Living Communities is similar to a toolkit. “We took the QALC IPC guidelines and said, ‘Here’s what the guideline says. Here’s what you need to do as you develop your own policies and procedures and fine tune your own operations.’ If somebody doesn’t have an IPC plan already, this will give them a big head start.”
It provides explanations and offers sample language and templates to streamline first-time development of an IPC plan or to facilitate evaluation of an existing plan. In addition, it offers detailed guidance to support communities as they tailor an IPC plan to their operation and to satisfy federal, state and local requirements, with guidance on:
- The role of a designated IPC leader;
- Detailed plans for staff training and processes to document it;
- Policies and procedures to prevent and control infection;
- Surveillance processes and systems to collect and report surveillance data; and
- Disaster or emergency preparedness protocols and plans.
To learn more and to get started, download Argentum’s Infection Prevention and Control Toolkit for Assisted Living Communities.
