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Infection Prevention and Control Lead Requirements: A Reminder for Residential Aged Care Providers
With COVID-19 cases on the rise around Australia, now is a good time to revisit last year’s changes to Infection Prevention and Control (IPC) lead requirements and ensure your policies and procedures are up to date.
What is an IPC lead and why do we need one?
According to the Department of Health, an IPC lead is a designated member of your nursing staff who has completed an identified IPC course. The role of the IPC lead is to observe, assess and report on IPC of your aged care home and assist with developing procedures and providing advice within the home.
By requiring all aged care homes to have an IPC lead, the government hopes to increase infection prevention and control expertise across the aged care sector. This comes in response to findings in the Independent Review into the Newmarch House COVID-19 Outbreak and the COVID-19 Special Report by the Royal Commission into Aged Care Quality and Safety. Both reports noted the need for stronger leadership in infection control in aged care.
IPC Lead Requirements
All aged care facilities must appoint a dedicated, onsite IPC lead. According to the Aged Care Quality and Safety Commission Factsheet, the IPC lead’s role is to “observe, assess and report on infection prevention and control, and to assist with developing procedures and providing best practice advice.”
The Aged Care Quality and Safety Commission (ACQSC) sets out key compliance requirements in its Guidance and resources for providers to support the Aged Care Quality Standards. In December 2020, the ACQSC updated its Guidance to incorporate the IPC lead requirements.
These are the key changes the ACQSC made to its Guidance:
Standard 3: Purpose and Scope of the Standard (p. 55) (changes indicated in green)
The organisation is expected to then have policies and procedures that support the workforce to deliver care and treatment in line with this approach.
This includes, for residential aged care services, a dedicated clinical staff member responsible to support the design, implementation and continuous improvement of infection prevention and control policies, procedures and practices.
Standard 3: Requirement 3(g) – Intent of this Requirement (p. 83)
Infection management, such as isolating infectious causes or consumers, and applying standards and precautions to prevent transmission, minimises the risk of transmission.
If community transmission starts to occur in your area, you must increase your vigilance and escalate your response, particularly around infection prevention and control.
It’s expected that organisations develop and implement an effective infection prevention and control program that is in line with national guidelines, including recommendations, advice or guidelines from the Infection Control Expert Group, which advises both the Communicable Disease Network Australia (CDNA) and the Australian Health Protection Principal Committee (AHPPC). It is further expected organisations will reference the Commission’s outbreak management document, Practical Guidance to support COVID-19 outbreak management planning in residential care, in development of effective infection prevention and control programs.
Infection prevention and control programs will vary in scope and complexity depending on the nature of the care and services the organisation provides.
Organisations must demonstrate infection prevention and control expertise, such as appointment of infection prevention control (IPC) lead(s), meeting (ongoing) training requirements around infection prevention and control, which should be available to all staff. Processes for routinely screening staff and visitors on entry to a residential care facility are important where there is any risk of infectious disease being introduced to the facility.
Residential aged care services are required to appoint at least one clinical staff member as infection prevention and control IPC lead(s). This ensures that these organisations are prepared to prevent and respond to infectious diseases, including coronavirus (COVID-19) and influenza. The IPC lead(s) must be a designated member of the nursing staff who has completed an identified IPC course.
Standard 3: Requirement 3(g) – Reflective Questions (p 84)
Four new Reflective Questions were added to Requirement 3(g):
- Who in the organisation provides advice and oversight as part of ongoing, day-to-day operations of infection prevention and control?
- How does the organisation demonstrate that it uses and references national accepted guidelines for infection control and prevention, including those provided during the coronavirus (COVID-19) pandemic, for example the CDNA guidelines and the Commission Outbreak Management Planning guidance?
- Can the organisation’s infection control processes be quickly escalated in line with the current situation?
- Does the organisation communicate regularly with staff regarding expectations around cohorting, physical distancing, staying home when unwell and the importance of infection prevention and control?
Standard 3: Requirement 3(g) – Examples of Actions and Evidence (pp 85-86)
Three new Examples of Actions and Evidence were added under “Workforce and Others”:
- Records show that the organisation has appointed an IPC lead(s) that must be engaged onsite and dedicated to a facility.
- Records show that the IPC lead(s)have completed at least the minimum requirements of the Department’s coronavirus COVID-19 focused and specified training modules.
- Records show that policies and procedures are contemporary and refer to best practice guidance, including those specific for outbreak prevention and management, that staff are aware of these policies and procedures, and supports and services have been planned and practised for a potential outbreak.
One new Example of Actions and Evidence was added under “Organisation”:
- Evidence of IPC training delivered to all staff when they begin employment at the facility and ongoing training annually or more frequently as required.
Standard 7: Requirement 3(c) – Reflective Questions (p 159)
Four new Reflective Questions were added to Requirement 3(c):
- Has the service appointed an infection prevention control (IPC) lead(s), which report to the approved provider? Has the IPC lead(s) completed an identified IPC course? Has ongoing infection control and prevention training occurred for all staff?
- How does the organisation demonstrate that training for all staff in infection management and control is contemporary and in line with best practice, including those specific requirements for IPC lead(s)?
- How do staff access information about and understand their individual role(s) in the Outbreak Management Plan?
- Has the service consulted and prepared with their workforce a plan to respond effectively to an outbreak?
Standard 7: Requirement 3(c) – Examples of Actions and Evidence (p 160)
One new Example of Actions and Evidence was added under “Consumers”:
- Consumers say the workforce has communicated their outbreak management plan and it is available upon request.
Three new Examples of Actions and Evidence were added under “Workforce and others”:
- The IPC lead(s) can describe how they meet the requirements of their role to support design, implementation and continuous improvement of infection prevention policies, procedures and practices within the service.
- Staff, including the IPC lead(s) can describe how outbreak management planning and preparedness occurs within the service, including implementation and quality improvement policies, processes and practices are managed within the service.
- The workforce feels safe to come to work and confirm that they are supported to undertake their role, particularly in the context of a pandemic.
Standard 8: Purpose and Scope of the Standard (p 169)
Organisations are expected to plan for, and manage internal and external emergencies and disasters and have effective infection prevention and control procedures in place.
Standard 8: Requirement 3(c) – Intent of this Requirement (p 180)
(iv) Workforce governance – including assigning clear responsibilities and accountabilities
Workforce governance systems and process make sure workforce arrangements are consistent with regulatory requirements. They also need to make sure the organisation has enough skilled and qualified members of the workforce, including a designated member of the nursing staff who has completed an identified IPC course.
Standard 8: Requirement 3(c) – Reflective Questions (p 180-181)
Six new Reflective Questions were added:
- What measures are in place for the organisation to effectively monitor IPC practices to determine where shortfalls may exist? What processes are in place to ensure changes are made when a shortfall is identified?
- How does the organisation demonstrate that policies and procedures are contemporary and in line with best practice documents, including those which outlines requirements for IPC lead(s) and outbreak management?
- How does the organisation demonstrate that an outbreak management plan is in place, and that staff are aware of their roles and responsibilities as part of that plan, including when any changes are made?
- What systems are in place to manage communications and engagement with families of residents and community?
- Does the organisation undertake audits of all key aspects of their outbreak management plan, including testing organisational processes, staff knowledge and practices, consumer outcomes and regulatory compliance?
- Are there effective organisation-wide systems for preventing, managing and controlling infections is critical to the delivery of safe and quality care?
Standard 8: Requirement 3(c) – Examples of Actions and Evidence (p 182)
Two new Examples of Actions and Evidence were added under “Workforce”:
- Demonstrate that the IPC lead(s) has the level of clinical expertise and influence at a service.
- Members of the workforce can describe different channels of communication and providing updates to staff from the organisation and governing body.
Three new Examples of Actions and Evidence were added under “Organisation”:
- Evidence the IPC lead(s) reports to the organisation, which retains overall responsibility for compliance with IPC requirements.
- Evidence that the organisation has systems in place to support outbreak management planning and practices, including it remains aligned with contemporary best practice, and is practiced within the service environment.
- Evidence that the organisation is mindful of the key risks associated with the service and the individual people receiving care at the service and can demonstrate how this has influenced their outbreak management planning and response.
Now is the Time to Review Your IPC Lead Policies and Processes
Do your records show that your IPC policies and procedures are contemporary and refer to best practice guidance? Can your IPC Lead describe how they meet the requirements of their role to support design, implementation and continuous improvement of infection prevention policies? Do you have evidence that your organisation was mindful of risks to individual consumers when you made your outbreak management plan?
These are just some of the actions and evidence that you now have to take into account when complying with IPC Lead requirements in the context of the Aged Care Quality Standards. Now may be the time to look over these Examples of Actions and Evidence, along with the Reflective Questions to test your readiness to deal with an outbreak and pass an ACQSC Assessment.
Supporting the IPC Lead Role – Ongoing Training and Resources
Further guidance resources are available on both the Department of Health and the Aged Care Quality and Safety Commission’s websites, including:
- ACQSC – Infection Prevention and Control Leads – Updates for Providers
- Department of Health: Infection Prevention and Control Leads
Here are some suggested support resources for your Aged Care Facility’s nominated IPC Lead:
- Aged Care IPC Update Webinar (3/6/21) - this Department of Health webinar provides an update on the importance of maintaining IPC practices to protect aged care residents and encouraging aged care workers to get vaccinated.
- A range of IPC Lead resources are available on the VICNISS site including:
- short training sessions and linked PowerPoint presentation
- Infection control toolbox
- links to a monthly Q&A forum for IPC Leads.
About the Author
Mark Bryan
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