Safe Injection Practices and IV Push Guidelines- Compliance with CMS and CDC Safe Injection Standards

Every hospital or ambulatory surgery center that accepts Medicare or Medicaid reimbursement should listen to this important program! Imagine a CMS (Center for Medicare and Medicaid Services) surveyor who shows up to do a CMS survey such as a complaint, certification, or validation survey. The surveyor pulls out the final infection control worksheet which has a section on safe injection practices. Now compliance with safe injection practices will be assessed heavily by the surveyors and non-compliance has been used in the courtroom against healthcare providers.

This is especially important in light of a number of cases where patients have died or suffered an adverse event in the past year. CMS has issued many important survey memos related to safe injection practices and infection control. Healthcare facilities are expected to comply with the CDC's ten standards on safe injection practices. CMS issued another survey memo on four unsafe injection practices that can end up with a second knock at the hospital’s door from the state epidemiologist. Many healthcare facilities have been found to be out of compliance.

Do you know what the ten CDC safe injection requirements are and how do you ensure you are in compliance? Does your ED physician wear a mask when doing an LP or your anesthesiologist or CRNA when they insert an epidural for pain relief? Recent CDC resources will be discussed.

If they make it in a single dose then the healthcare facility needs to purchase it. Do you know what the rules are now for multi-dose vials? Does your staff know these cannot be taken into patient rooms including the OR with exception? Do you know what the beyond use data is as to when medication must be given when drawn up?

Every hospital should have a policy on this. All staff, including physicians, should be trained on this. Staff needs to be educated on the ten CDC standards for safe injection practices and assessment with compliance should be done?

This program will also cover the guidelines issued by ISMP on IV push medication for adults. CMS requires hospitals to follow standards of care such as those issued by ISMP. The policy should be amended to include these standards in addition to the education of the staff.

Injected medicines are common in healthcare today. Injection safety or safe injection practices are measures taken to perform injections in an optimally safe manner for patients. Many hospitals, ASCs, dental offices, and other facilities have just taken for granted that this was being performed appropriately but recent studies show this to be untrue. A physician in Nevada was sent to prison for being out of compliance with these standards. State boards have taken away the licenses of nurses and physicians and pharmacists for violating safe injection practices.

• Discuss that the infection control worksheets contain a list of items that will be assessed during the on-site survey in order to determine compliance with safe injection practices for hospitals and ASCs
• Describe that the CDC has ten standards on safe injection practices that all hospitals and healthcare facilities should be following
• Recall that every healthcare facility should have a policy on safe injection practices and staff be educated on this
• Discuss that ISMP has published a 26-page guideline on IV push medication for adults

Safe Injection Practices

• All staff should be trained
• Hospitals, ASCs, and healthcare facilities should have safe injections practices P&P
• CMS Memo on Safe Injection Practices 
• CMS Memo on 4 Infection Control Breaches
• CDC Memo on Insulin Pens
• ISMP IV Push Guidelines for Adults
• CMS  IC Worksheet section on Safe Injection Practices
• ISMP guidelines on IV push medication for adults
• Ten cases MRSA 
• Fungal meningitis cases
• EMPSF free memo on safe injection practices
• Single and multi-dose vials
• Hospital and ASCs infection control violations
• Masks must be worn when doing LP or epidural for pain relief
• CDC Guidelines on Safe Injection Practices
  • CDC’s 10 recommendations for Safe Injection Practice
• CDC Guidelines for Isolation Practices
• Nevada ASC violations of Safe Injection Practices
  • Reuse of syringes
• CDC Resources on Safe Injection Practices
  • Contamination of multidose vials
  • 5 cases failure to wear a mask when inserting the epidural line
  • Catheter flushing in oncology clinic and 99 cases HCV
  • Nebraska hematology/oncology clinic outbreak irrigating IVs from 500 cc IV bag HCV
  • Accucheck/glucometer contamination
• Joint Commission standard 
• CMS Infection Control Standards
• Unsafe injection practices as a never event
• WHO Guidelines for Safe Injection Practices
• Infusion Nursing Standard of Practice
• ASC Quality Collaborative Toolkit
• APIC and other recommendations to include in the policy
• Cleaning of glucascan and blood glucose testing equipment
• All hospitals, ASCs, and dental facilities should have a policy on safe injection practices

• Infection Preventionist
• Infection Control Committee Members
• Pharmacists including the Director of Pharmacy
• All Nurses and Physicians
• Chief Nursing Officer
• Chief Operating Officer
• All Nursing Supervisors and Department Directors
• Anesthesiologist and CRNAs
• OR Director and OR Nurses
• Emergency Department Physicians and Nurses
• Nurse Educator
• Joint Commission Coordinator
• Performance Improvement Director and PI Staff
• Chief Medical Officer
• ASC Staff
• Compliance Officer
• Regulatory Compliance Director
• Anyone involved with Safe Injection Practices
• Chief Medical Officer
• Physicians
• Ambulatory Clinic Directors and Staff
• Hospital owned Physician Office Staff
• OR Nurses
• Radiology and Clinic Professional Staff
• All Department Directors
• Anyone involved in Safe Injection Practices