1. Maintain a documented, agency-wide infection-control program
42 CFR §484.70 requires the HHA to maintain and document an infection-control program. Your survey-ready evidence should identify the program's responsible leaders, policies, surveillance process, education approach, escalation path, and how findings move into corrective action.
2. Show how accepted standards and standard precautions are used
The federal standard requires accepted standards of practice, including standard precautions, to prevent transmission of infections and communicable diseases. Policies should match what staff are actually trained to do in the home, and observations or competency checks should support that practice.
3. Make surveillance and investigation visible
The agency must maintain a coordinated program for surveillance, identification, prevention, control, and investigation of infectious and communicable diseases. A useful internal audit asks whether infection concerns are consistently captured, trended, investigated when appropriate, and closed with documented action.
4. Connect infection control directly to QAPI
CMS explicitly requires the infection-control program to be an integral part of the HHA's QAPI program. Infection trends should therefore be able to travel from surveillance into QAPI review, performance-improvement activity, and follow-up measurement when the data show a problem.
5. Verify education for staff, patients, and caregivers
The rule requires infection-control education for staff, patients, and caregivers. Keep evidence that education is delivered in a way appropriate to each audience and that required staff education is retrievable during a survey.
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