03/29/2017
You Asked....We Answered
This week's You Asked..We Answered question asks "If a nursing home does the assessment referenced in the CDC document, and they self-assess that they are low-risk (using the guidelines), are they able to have a TB control plan where residents are not then given the admission 2 step TB and annual TB? How would a nursing home having an adult day on-site implement this, if the adult day is deemed low risk as well?"
You Asked:
If a nursing home does the assessment referenced in the CDC document, and they self-assess that they are low-risk (using the guidelines), are they able to have a TB control plan where residents are not then given the admission 2 step TB and annual TB? How would a nursing home having an adult day on-site implement this, if the adult day is deemed low risk as well?
We Answered:
LeadingAge Ohio reached out to staff at the Ohio Department of Health, who confirmed that changes pertaining to TB testing occurred in December 2014. Prior to Dec 2014, long term care facilities needed to do the annual ppd for staff and residents. Since the law changed, the burden of performing the annual test has been removed. There is still an expectation on the completion of a 2-step Mantoux on all new employees and residents. It is required of all new hires in a healthcare field, including adult day. However, the participants of adult day do not need to be tested because they are not there as a resident.
Below is guidance that ODH shared:
Ohio does not have a specific law for TB testing of health care workers or residents of health care facilities. If your agency is licensed by an organization, such as MRDD, please check with your surveyor or point of contact for minimum requirements that must be contained in your TB Policy. Keep in mind, each agency is different, and requirements depend on setting, legal requirements set forth by the regulatory agency, and policy that is in place by your agency’s legal department.
There were changes to the Ohio Administrative code in December 2014 that gives health care facilities, including long term care, the power to create their own policy as long as it is in accordance to the Centers for Disease Control’s guidelines. These are the most current recommendations available from the Center for Disease Control and the Ohio Department of Health.
The rule references “Guidelines for Preventing the Transmission of Mycobacterium tuberculosis in Health-Care Settings, 2005” published by the CDC, which offers the following:
- In low-risk facilities, annual testing or symptom assessment is not required for all staff or residents as it is for medium-risk facilities. For low-risk settings the guidelines provide a vague reference for medical evaluation if symptoms occur, but they do not explicitly give the timeline for symptom assessment or how to monitor.
- When the rules changed some providers where concerned about the ambiguity of the guidelines. In response, ODH TB Program suggested annual symptom assessments only for individuals (residents and staff) with a history of latent TB infection (LTBI) or TB disease. The rationale being residents are likely to have at least one medical condition that increases the risk for progression from LTBI to active disease, and staff have the potential for exposing many vulnerable people should they become ill.
- A healthcare institution can amend their policy to test upon hire (for staff) or admission (for residents) and then assess infected individuals annually or choose another method and timeframe to monitor for symptoms. The key piece being the establishment and compliance with the organizational policy.
The CDC’s recommendations for employment are outlined in the document entitled “Upon Hire”. Additionally, this screening tool may be helpful for monitoring employees’ exposure after initial hire. The attached 2005 CDC guidance document, Preventing TB Transmission in Health Care Settings, will be quite useful. Health care facilities in Ohio are encouraged to perform an annual risk assessment to determine the risk of transmission of TB specific to the setting. The risk assessment worksheet gives health care facilities a format to evaluate different aspects of TB control. The risk assessment process begins on page 8 of the document. If fewer than 3 TB patients have been diagnosed with active TB in the past year, the facility’s classification is low risk. Recommendations for screening in low and medium risk agencies are detailed on page 9.
In the You Asked...We Answered section, LeadingAge Ohio staff share technical questions and advice that have been asked of them by members.
If you have a question you would like to see featured in You Asked..We Answered, email Nisha Hammel, Director of Advocacy at nhammel@leadingageohio.org , or Anne Shelley, Director of Professional Development & HH/Hospice Regulatory Relations, at ashelley@leadingageohio.org.
