Chris McMenemy, vice president for administration at Ortmann Healthcare Consultants in Columbia, S.C., addresses a question from a reader at an ambulatory surgery center regarding whether CMS requires ASC staff members to undergo tuberculosis testing.
Q: Does CMS require annual TB testing for ASC staff members? Our hospital partner went to a "target TB" testing policy based on a risk assessment established by the CDC. Our state Department of Public Health and Infectious Disease physicians. This also was based on the CDC document "Guidelines for preventing the Transmission of Mycobacterium tuberculosis in Health-Care Settings, 2006," which defines TB screening risk classifications and screening guidelines.
Chris McMenemy: The regulation, "416.51(b) Infection Control Program," is somewhat vague. It doesn't mention TB but does state that:
"The ASC must maintain an ongoing program designed to prevent, control, and investigate infections and communicable diseases. In addition, the infection control and prevent program must include documentation that the ASC has considered, selected, and implemented nationally recognized infection control guidelines."
However, ASCs have been cited for not providing TB tests at least once a year. In a survey conducted of one ASC in June 2010, the ASC administrator told the surveyors: "The physicians' TB screening is completed when they are re-credentialed every two years." In the survey report, however, the surveyor noted, "The ASC failed to annually screen 10 of 18 ASC health care workers," adding, "there was no documented evidence of annual or current tuberculosis (TB) screening for 10 of 18 files reviewed."
The degree of enforcement appears to have something to do with the degree of the risk of contracting TB. The Communicable Disease Center Guidelines for Preventing the Transmission of Mycobacterium tuberculosis in Health-Care Setting, 2005, states on p. 10 that "the classification of medium risk should be applied to settings in which the risk assessment has determined that health care workers (HCW) will or will possibly be exposed to persons with TB disease or to clinical specimens that might contain M. tuberculosis." Low risk, on the other hand, is applied to settings where exposure to TB was not expected to be encountered. If the ASC is uncertain about whether the risk is low or medium, medium should be adopted, it stated. The recommendations for medium risk included, "All HCWs should receive baseline TB screening upon hire, using two-step TST (skin test) or a single BAMT (alternate test) to test for infection," and "after baseline testing for infection, HCWs should receive TB screening annually."
Review of the CDC Morbidity and Mortality World Report (MMWR Volume 46, Number RR-18, December 26, 1997) documented on page 24: Persons who work within medical facilities should be immune to measles and rubella. Immunity to mumps is highly desirable for all HCWs. Because any HCW (i.e., medical or nonmedical, paid or volunteer, full time or part time, student or non-student, with or without patient-care responsibilities) who is susceptible can, if exposed, contract and transmit measles or rubella, all medical institutions (e.g., inpatient and outpatient, public and private) should ensure that those who work within their facilities* are immune to measles and rubella. Likewise, HCWs have a responsibility to avoid causing harm to patients by preventing transmission of these diseases.
On page 25, the MMWR documented: All HCWs should ensure that they are immune to varicella. Review of the Association for peri-Operative Registered Nurses Recommended Practices for Prevention of Transmissible Infections in the Perioperative Practice Setting (page 281), Recommendation VIII.1. addressed the immunization and/or screening of health care workers for hepatitis B virus. Recommendation VIII.2. read "Health care workers should be immunized against other communicable and infectious agents," with a footnote reference to the CDC MMWR above.
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Read more from Chris McMenemy:
- 4 Common Medicare Violations Found by Inspectors of Surgery Centers
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