Preparing for Updated F880 Guidance on Enhanced Barrier Precautions (EBP)

Key Requirements of Updated EBP Guidance (F880)

Enhanced Barrier Precautions (EBP) are an infection control strategy used in conjunction with Standard Precautions. They involve the targeted use of gown and gloves during specific high-contact care activities to reduce MDRO transmission.

Who Requires EBP?

EBP must be implemented for residents meeting either of the following criteria:

1. Infection or Colonization with a CDC-Targeted MDRO: This applies only when Contact Precautions are not otherwise indicated (e.g., the resident does not have uncontained secretions or excretions). (Refer to the CDC link below for the current list of targeted MDROs).

2. Presence of Wounds and/or Indwelling Medical Devices: This applies even if the resident is not known to be infected or colonized with an MDRO.

o Wounds: Focus is on chronic wounds (e.g., pressure ulcers, diabetic foot ulcers, unhealed surgical wounds, venous stasis ulcers). Does not typically include short-term minor wounds like skin tears covered by an adhesive bandage.

o Indwelling Devices: Includes central lines, urinary catheters, feeding tubes, tracheostomies. Does not include peripheral IV lines.

EBP vs. Contact Precautions:

• Contact Precautions: Use for any resident (regardless of MDRO status, wound, or device) who has secretions or excretions that cannot be covered or contained (e.g., uncontained wound drainage, diarrhea, fecal incontinence). Also use for residents infected/colonized with specific MDROs requiring Contact Precautions per CDC guidance, even if secretions are contained.

• EBP: Use for the specific indications listed above when Contact Precautions do not apply. For example, a resident with a urinary catheter but no known MDRO and no uncontained secretions would use EBP, not Contact Precautions.

• Facility Discretion: Facilities may choose to use EBP for residents infected/colonized with non-CDC targeted MDROs who do not otherwise meet EBP criteria (no wound/device/uncontained secretions).

When to Use Gown and Gloves for EBP:

For residents requiring EBP, staff must don gown and gloves when performing these high-contact resident care activities:

• Dressing

• Bathing/showering

• Transferring

• Providing hygiene

• Changing linens

• Changing briefs or assisting with toileting

• Device care or use (central line, urinary catheter, feeding tube, tracheostomy/ventilator)

• Wound care (any skin opening needing a dressing)

Important Considerations:

• Location: EBP applies wherever the resident is located in the facility when high-contact care occurs.

o Exception: Gown/gloves generally not needed for brief transfers in common areas (e.g., dining room).

o Requirement: EBP is needed during transfers/assistance in shared shower rooms or close-contact assistance in therapy gyms.

• Resident Rights: EBP does not restrict residents to their rooms or limit participation in group activities.

• Duration: EBP remains in place for the duration of the resident's stay or until the qualifying condition (wound resolution, device removal) is no longer present.

• Communication: Facilities must have a system to alert staff before high-contact care which residents require EBP. This system can be discreet (e.g., non-obvious cues) to maintain a home-like environment, but it must be effective.

• Supplies: Gowns, gloves, and alcohol-based hand rub (ABHR) must be readily accessible. Placement can be near/outside the room. PPE is donned for the activity, not necessarily upon room entry for non-high-contact interactions (e.g., conversation, medication pass without contact).

• Surveyor Focus: Evaluation will focus on EBP use for sampled residents meeting criteria, particularly concerning CDC-targeted MDROs.

Reference: CDC Implementation of PPE Use in Nursing Homes to Prevent Spread of MDROs: Implementation of Personal Protective Equipment (PPE) Use in Nursing Homes to Prevent Spread of Multidrug-resistant Organisms (MDROs) | LTCFs | CDC

Compliance Probes for Administrators

Use these questions and checks to verify your facility's readiness and compliance with the updated EBP guidance under F880:

1. Policy & Procedure Review:

o Is our facility's Infection Prevention & Control policy updated to reflect the specific requirements of EBP as outlined in CMS Memo QSO-24-08-NH?

o Does the policy clearly define EBP, its indications (CDC-targeted MDROs, wounds, devices), and the specific high-contact activities requiring gown and glove use?

o Does the policy accurately differentiate between when EBP is required versus when Contact Precautions are required (especially regarding uncontained secretions/excretions)?

2. Resident Identification & Assessment:

o What is our process for identifying residents who meet the criteria for EBP (presence of specific MDROs, chronic wounds, indwelling devices)? Is this process reliable and integrated into admission/routine assessments?

o Are assessments accurately distinguishing between chronic wounds requiring EBP and minor wounds that do not?

o Are we correctly identifying applicable indwelling medical devices (and excluding peripheral IVs)?

o Is the EBP status clearly documented and readily accessible in the resident's record/care plan?

3. Staff Communication & Training:

o How do we communicate to all relevant staff (nursing, CNAs, therapy, etc.) which residents require EBP? Is this communication method effective before staff initiate high-contact care?

o Have staff received training on the updated EBP guidance, including:

 Who needs EBP?

 Which specific activities require gown and gloves under EBP?

 Proper donning/doffing procedures for gown and gloves used for EBP?

 The difference between EBP and Contact Precautions?

 The fact that EBP does not restrict resident movement/activities?

o Can staff articulate when and how to use EBP correctly?

4. Supply Accessibility:

o Are gowns, gloves, and ABHR readily accessible near the point of care for residents requiring EBP?

o Does the placement facilitate easy access before initiating high-contact care activities?

5. Observation & Auditing:

o Are we conducting observations or audits to verify staff are correctly implementing EBP (using gown/gloves) during the specified high-contact activities for residents who require it?

o Do observations confirm staff are not unnecessarily restricting residents on EBP from activities or movement outside their rooms?

o Are audits confirming appropriate use (i.e., not using EBP when Contact Precautions are actually warranted, or vice-versa)?

6. Resource Check:

o Have we reviewed the linked CDC page for the most current list of CDC-targeted MDROs and implementation details?

Proactively addressing these areas will help ensure your facility meets the updated F880 requirements for Enhanced Barrier Precautions and promotes resident safety by preventing MDRO transmission.

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