On a recent survey, I was chatting with the staff member who was responsible for cleaning and disinfecting the rental medical equipment. This particular organization had traditional DME patients, but also serviced a Hospice contract, so the equipment flowed mightily through the warehouse’s clean, dirty, and waiting to be repaired areas. As I was asking him about the cleaners and disinfectants he used, I noticed a poster above his workbench. It was one of those pithy and ubiquitous “keep calm” sayings: “KEEP CALM & MAINTAIN CLEANLINESS.” He smiled and shrugged when he saw me eyeing the poster. This staff member took his responsibility very seriously and was doing an excellent job. His paperwork and technique were both very good, his workspace was orderly and clean, and he understood the underlying reasons it was so important to clean equipment properly for staff safety as well as patient safety.
He commented on how important equipment cleaning was and that he was glad and relieved to see that the survey process actually included verification that a company is –as he put it, “doing it right.” He was absolutely correct that it is an important part of survey process. When you go through survey, expect to spend a significant amount of time reviewing this important aspect of patient care.
ICS 2 and ICS 3 are two HQAA standards that address requirements for equipment cleaning and disinfecting. First of all, equipment cleaning should be addressed in policy & procedure. Policy & procedure should address:
- How equipment is received and cleaned/disinfected. What cleaners are used for equipment and where is the cleaning process performed.
- How items are stored to prevent contamination. How does a company separate clean and dirty equipment? Is there signage to reflect the separation?
- A description of cleaning methods used.
- Documentation that personal protective equipment (PPE) is available to all appropriate staff.
- How equipment cleaning is documented (log book, computer file, tagging system).
During the survey process, a surveyor will need to verify that these policies are being followed and that they are appropriate. During the tour of the warehouse or later in the survey, staff should expect to explain to the surveyor how various pieces of equipment are processed and cleaned. A good way for a surveyor to assess your processes is to actually observe staff performing equipment cleaning. Absent actual equipment cleaning, the surveyor may ask staff to describe the process verbally or even perform a “mock cleaning.”
Be sure staff knows where their personal protective equipment (PPE) is located and when and how to use it. Staff should also be aware of when and how to use the various cleaners and disinfectants and have a thorough understanding of the cleaning procedures. Watch for the following:
- Use the right cleaners/disinfectants for a given piece of equipment. Pay special attention to bedding and upholstered equipment, which often have their own requirements.
- Ensure equipment disinfecting includes appropriate “contact time.” This is how long a disinfectant must remain on a piece of equipment to kill germs. Mycobacterium tuberculosis is a particularly strong germ and many of the disinfectants require a ten-minute contact time to work on it.
- Make sure all equipment is in the correct storage areas. If it’s dirty, it goes in the dirty equipment area. If it’s clean, it goes in the clean equipment area. Seeing a trend here?
- PPE needs to be available and staff should follow the organization’s policies regarding its use. This includes masks, gloves, and gowns. Staff should be able to describe when to use the PPE to the surveyor.
- Safety Data Sheets (SDS) should be available for any and all cleaners and disinfectants your organization uses and staff should be aware of where the information is stored and how to access it.
- Finally, make sure documentation of the cleaning/disinfecting process is thorough and complete. The surveyor will most likely check the log for pieces of equipment he or she sees in the warehouse or even in a home. Keep the log up to date.
The surveyor validates these cleaning processes and wants assurances that staff are aware and cognizant of the policy and competent of performing the procedures. HQAA has standards that address these issues because the Medicare Quality Standards mandate it. But more importantly, they do this because it’s an important aspect of patient care and an important safety issue. Knowledge, proficiency, and competence in these areas are absolute expectations in the DME world. As my new friend’s poster proclaimed: “KEEP CALM AND MAINTAIN CLEANLINESS”!