Signs It's Time to Turn to Infection Control Consultants

By Phenelle Segal, RN, CIC, FAPIC, Founder, Infection Control Consulting Services

Key Takeaways

• A risk assessment more than a year old, or one that's never been completed, is already a compliance issue on its own.

• Facilities that assign infection control to staff already covering other roles typically see slower surveillance and incomplete documentation.

• A survey citation or plan of correction is a lagging indicator. The warning signs are usually visible months earlier.

• Turnover in the infection preventionist role costs more than staffing continuity, in part because it resets institutional knowledge each time.

• Sterile processing and water management remain two of the most frequently cited areas across ambulatory and outpatient surveys.

• A recent outbreak or infection cluster, even a small or contained one, is one of the clearest signals it may be time to bring in specialized support.

• Infection control consultants can address any one of these issues and others directly, without the cost or timeline of a full-time hire.

Facilities rarely decide to bring in outside infection control help because everything is running smoothly. Usually what triggers the outreach is a problem that surfaces, such as a missed deadline, a survey finding, and a staff member who gave notice. Below are some of the signs we at Infection Control Consulting Services see most often across the facilities we serve, including ASCs, hospitals, FQHCs, imaging centers, and CAHs, before a facility reaches out for assistance from infection control consultants.

Quick self-check. If any of these describe your facility right now, it's worth a conversation:

• Your last infection prevention risk assessment was more than a year ago, or never happened.

• No one on staff is dedicated to infection control full time.

• Your infection preventionist left recently, or is planning to.

• You haven't run a mock survey against your accrediting body's current standards in the past year.

• You've received a citation or are struggling to work through a plan of correction.

• Sterile processing or your water management plan hasn't been reviewed recently.

• You've had a recent outbreak or infection cluster, however small.

Your Last Risk Assessment Was More Than a Year Ago

Annual infection prevention risk assessments are one of the most effective ways for a facility to identify where its actual exposure sits, from sterile processing to hand hygiene compliance to water management. When a risk assessment is overdue or was never completed with the depth surveyors expect, that oversight tends to surface at the worst possible time: during a survey.

A thorough risk assessment typically covers areas including, but not limited to:

• Sterile processing and reprocessing practices

• Hand hygiene compliance and observation data

• Water management and environmental controls

• Isolation precautions and PPE use

• Documentation and surveillance processes

If your facility can't point to a current risk assessment covering these areas, that's reason enough on its own to bring in outside support.

No One Owns Infection Control Full Time

Many facilities, particularly smaller hospitals, ASCs, and outpatient care sites, assign infection prevention to a nurse, quality manager, or administrator who is already covering other responsibilities. Surveillance, policy review, staff education, and reporting each take real time, and none of them get easier when the person responsible for them is also managing three other jobs. Inevitably, documentation and training slip, and trends in infection data can go unnoticed until they become outbreaks.

Infection control consultants often offer onboarding and mentoring support for facilities building this role from scratch, along with ongoing education for staff who have inherited infection control responsibilities without formal training.

You've Had Recent Turnover in Infection Control Leadership

When an infection preventionist leaves, their knowledge of your facility's specific processes, history, and open issues leaves with them. Rebuilding that institutional knowledge takes time your compliance timeline may not allow. Our look back at 2025's infection prevention challenges covered this directly: Facilities that lost dedicated infection preventionists to burnout or turnover saw gaps in oversight and inconsistent surveillance follow through in the months after.

Infection control consultants provide continuity a single hire can't guarantee. If the person leaves, the program doesn't leave with them.

You Haven't Conducted a Mock Survey Recently

Accreditation and CMS surveys are unannounced, whether your facility is surveyed by CMS directly, Joint Commission, AAAHC, ACHC, QUAD A, DNV or CIHQ. Facilities that wait until a survey letter arrives to assess their readiness are already behind. A mock survey is one of the most effective ways to identify problematic areas while there's still time to correct them, rather than after a surveyor has documented a deficiency.

A mock survey typically evaluates key areas like:

• Written infection prevention program documentation against current standards

• Sterile processing and reprocessing workflows

• Injection safety and medication handling practices

• Staff knowledge of policies during direct observation

• Prior survey findings, to confirm they were fully resolved and not just noted as closed

If it's been more than a year since your facility ran a mock assessment against your accrediting body's current standards, survey preparation support is worth scheduling now rather than after your next survey window opens.

You've Received a Citation or Must Submit a Plan of Correction

We view citations as a "lagging indicator." By the time a deficiency is documented by a surveyor, the underlying issue has likely existed for months. This shows up across accreditors, not just one. In AAAHC's 2026 Quality Roadmap, for example, infection control practices ranked among the leading causes of Immediate Jeopardy findings in ambulatory and primary care surveys, second only to crash cart readiness. Similar patterns turn up in survey data from other accrediting bodies as well. While written policies may exist, the oversight and follow-through behind them often don't.

If your facility is working through a plan of correction, the priority is making sure the underlying process changes, not just your paperwork.

Sterile Processing or Water Management Hasn't Been Reviewed Recently

Sterile processing and water management are two of the areas surveyors scrutinize most closely, and two of the easiest to let slip when internal resources are stretched. Water management plans built to AAMI ST108 standards and regular observation of sterile processing workflows both require a level of specialized attention that's difficult to sustain internally at smaller and sometimes even larger facilities.

ICCS's infection control consultants provide direct sterile processing guidance and water management plan development for facilities that need both reviewed against current standards.

You've Had a Recent Outbreak or Cluster

A cluster of surgical site infections, a multidrug-resistant organism identified in more than one patient, or any pattern that looks like more than an isolated case calls for an outbreak investigation. Identifying the source, confirming whether transmission is ongoing, and implementing corrective action quickly all affect patient safety, public reputation, and how a subsequent survey or regulatory review goes.

An outbreak is often the most urgent sign on this list that a facility would benefit from an infection control consultant. It's also the one facilities are generally least prepared to handle internally, since outbreak investigation requires a specific skill set most facilities don't need often enough to keep in-house.

Final Thoughts

None of these signs alone points to a crisis. Together, they're the pattern we see most consistently right before a facility reaches out. Some clients bring ICCS in to support an infection preventionist who's already on staff. Others use our fractional infection control consultants to cover the role entirely, particularly at facilities where a full-time hire isn't realistic. Both are legitimate approaches, and the right one depends on your facility's size, resources, and current program.

The ICCS team of infection control consultants supports a wide range of facility types. Please schedule a complimentary consultation to talk through what your facility needs.

Frequently Asked Questions on Infection Control Consultants

How do I know if my facility needs infection control consultants or just more internal training?

If the issue is limited to staff knowledge, such as hand hygiene compliance or documentation practices, targeted training may be enough. If it involves program structure, regulatory readiness, or specialized areas like sterile processing and water management, that typically calls for outside infection control expertise with survey and accreditation experience.

Can infection control consultants help after a citation has already been issued?

Yes. This is one of the most common reasons facilities reach out to ICCS. Infection control consultants can help develop and implement a plan of correction, and more importantly, address the underlying process gaps so the same issue doesn't recur at the next survey.

Do infection control consultants replace the need for an infection preventionist on staff?

Not necessarily. Many facilities use consultants to support an existing infection preventionist, cover gaps during turnover or leave, or provide fractional oversight when a full-time hire isn't feasible. Others use consultants to build a program from the ground up before hiring internally.

What's the difference between an infection preventionist and infection control consultants?

An infection preventionist is typically an internal staff member responsible for day-to-day surveillance, education, and program management at a single facility. Infection control consultants work externally, often across multiple facilities, and bring broader survey and regulatory experience along with the flexibility to scale support up or down as a facility's needs change. Many facilities use both, with consultants supporting or mentoring the internal infection preventionist rather than replacing that role.

Do accreditation organizations like AAAHC, Joint Commission, or ACHC require facilities to use infection control consultants?

Typically, an agency or accrediting body does not require a facility to contract with an outside consultant. What they do require is a compliant infection prevention and control program, led by a qualified, designated professional, that meets current standards. Consultants are one way facilities meet that requirement when internal resources or expertise fall short, regardless of which accrediting body oversees the facility. However, depending on the type of survey and the accreditation organization or agency (particularly CMS), a certified consultant may be required.

How quickly can infection control consultants get started?

This depends on the scope of the engagement, but ICCS typically begins with a complimentary consultation to understand the facility's current state, followed by an on-site or remote assessment. Facilities preparing for an upcoming survey should reach out as early as possible to allow time for meaningful corrective action.

Reusable Lead Aprons and Thyroid Collars: A Disinfection Gap Hiding in Plain Sight

By Phenelle Segal, RN, CIC, FAPIC, Founder, Infection Control Consulting Services

Key Takeaways

• A recent Infection Control Today roundtable found that reusable lead aprons and thyroid collars worn in operating rooms, cath labs, and interventional suites routinely fall outside formal cleaning and disinfection protocols.

• We have flagged this same gap across ambulatory surgery centers (ASC), freestanding radiology centers, and other facilities for years. The roundtable confirms what our own facility assessments have already shown.

• No single federal regulation or accrediting body standard specifically dictates how often lead garments must be cleaned, which leaves facilities relying on manufacturer instructions that are often inconsistent or missing.

• Storage location sets the bar. Aprons kept in the OR or procedure room are expected to be wiped down between cases, though that expectation isn't consistently met.

• Facilities that assign clear ownership of lead garment cleaning across infection prevention, perioperative leadership, and radiology tend to close this gap faster than those that leave it undefined.

An Overlooked Corner of the Perioperative Environment

Lead aprons and thyroid collars protect staff from radiation exposure during fluoroscopy, cardiac catheterization, interventional radiology, and other procedures that use ionizing radiation. They are worn daily in operating rooms, cath labs, interventional suites, and imaging departments, and they are reused case after case, often by different staff members. Despite that level of contact, they frequently escape the routine cleaning and disinfection protocols applied to other reusable equipment in the same rooms.

A recent Infection Control Today roundtable brought infection prevention and perioperative experts together to discuss exactly this problem. Several panelists noted that lead garments stay in the room throughout a case, yet routinely get skipped when that room is cleaned between cases. One panelist cited ATP testing that measured OR lead garments at roughly nine times the contamination level of a public gas pump handle, a comparison meant to make the scale of the problem concrete for leadership. Another panelist pointed to a lack of standardized guidance as a central obstacle. Hospitals may keep records confirming aprons were cleaned, but what that cleaning actually involved is rarely consistent from one facility to the next.

This Isn't New to ICCS

At Infection Control Consulting Services (ICCS), we have considered lead apron and thyroid collar disinfection one of the most overlooked low-level disinfection items in the perioperative and procedural space for years, and this roundtable confirms it from a national stage. We have been flagging this gap since entering the ASC space in the mid-2000s.

Surveyors who concentrate heavily on environmental cleaning and disinfection may cite facilities for failing to disinfect these garments after each use. When aprons are hung in the operating or procedure room rather than stored elsewhere, the expectation is a wipe-down between every case, but in our experience that standard isn't applied consistently across facilities, regardless of size or setting.

Why the Gap Persists

A few factors combine to keep lead garment disinfection off the radar in many facilities:

• No device-specific cleaning mandate. Radiation protective clothing is regulated by the FDA as a Class I medical device under 21 CFR 892.6500, the lightest level of premarket oversight. That classification covers construction and labeling. Cleaning frequency is left to facility policy and manufacturer guidance.

• Inconsistent or missing manufacturer instructions for use. Some manufacturers specify wiping down garments after every use; others say little or nothing about cleaning frequency at all. Staff who rely on the instructions for use as their reference point end up with different expectations depending on which garment they are wearing.

• Unclear ownership. Lead garment care touches infection prevention, perioperative or procedural leadership, and radiology or radiation safety, but it belongs fully to none of them. When no single department is accountable for cleaning, inspection, and documentation, the task is easy to lose track of.

AORN's Guideline for Radiation Safety does address care of these garments, recommending that facilities involve an interdisciplinary team, including infection prevention and the radiation safety officer, in selecting an appropriate disinfectant, allowing it to dry completely before storage, and storing garments without folding or creasing to preserve both the shielding material and the surface that is being disinfected. That guidance exists. The gap is in how consistently it gets translated into a documented, facility-specific protocol.

Closing the Gap

A few practical steps bring lead garment disinfection in line with the rest of your environmental cleaning program:

• Assign clear ownership across infection prevention, perioperative or procedural leadership, and radiology, so the routine doesn't fall through the cracks between departments.

• Establish a written wipe-down protocol between cases for garments that stay in the room, using a disinfectant appropriate for the garment's outer material.

• Confirm manufacturer instructions for use are on file for every garment in circulation, and reconcile any inconsistencies across vendors into a single facility policy.

• Build periodic deeper cleaning into your environmental services or biomedical schedule, separate from the between-case wipe-down.

• Consider objective data, such as ATP testing, to demonstrate contamination levels and build leadership support for the protocol.

You do not need a new federal standard to fix this. Treat lead garments the way you already treat every other piece of reusable equipment in your procedural areas: a documented protocol, a clear owner, and routine verification that the protocol is being followed.

How ICCS Can Help

We work with ambulatory surgery centers, freestanding radiology centers, and other facilities to close gaps like this one — the kind that doesn't surface until a surveyor asks the right question. If lead apron and thyroid collar disinfection isn't currently part of your written environmental cleaning protocol, we can help you build one and make sure your staff, your documentation, and your survey readiness are aligned.

Frequently Asked Questions About Lead Apron Disinfection

Do Joint Commission, AAAHC, or other accrediting bodies specifically require disinfection of lead aprons between uses?

No accrediting body that we are aware of names lead aprons or thyroid collars specifically in its standards. Their environmental cleaning and disinfection standards apply broadly to reusable equipment and high-touch surfaces in procedural areas, and surveyors who focus closely on environmental cleaning have cited facilities for gaps in disinfecting these garments as part of that broader review.

How often should lead aprons and thyroid collars be cleaned?

At minimum, garments that stay in the room between cases should be wiped down after each use. Facilities should also build in periodic deeper cleaning on a schedule consistent with manufacturer instructions for use, since a daily wipe-down alone does not replace more thorough cleaning.

Is there a specific federal or industry standard that governs lead garment disinfection?

Not one specific to these garments. Lead aprons and thyroid collars are regulated by the FDA as Class I medical devices under 21 CFR 892.6500, a classification focused on construction and labeling rather than cleaning protocols. AORN's Guideline for Radiation Safety offers recommendations on disinfectant selection, drying, and storage, and general CDC environmental hygiene principles apply, but no single standard sets a required cleaning frequency the way it does for some other categories of reusable equipment.

Should You Hire an Infection Preventionist or Contract with a Consulting Firm?

By Phenelle Segal, RN, CIC, FAPIC, Founder, Infection Control Consulting Services

Key Takeaways

• Healthcare facilities do not have to choose between hiring a full-time infection preventionist and contracting with a consulting firm. In many cases, the two work best together.

• A full-time infection preventionist hire costs more than salary alone. Recruiting, benefits, credentialing, and ramp-up time all add to the real cost.

• Contracting with a consulting firm gives a facility access to a full team's combined experience, not just one person's knowledge.

• The right approach depends on facility size, survey timing, current staffing, and budget.

I hear this question from facility leaders regularly: Should we hire a full-time infection preventionist, or do we bring in outside support? Having worked with facilities ranging from small ambulatory surgery centers (ASCs) and imaging centers to multi-site hospital systems, I can tell you there is no single right answer. It depends on the facility. But there are some things leadership should carefully weigh before deciding.

The Real Cost of Hiring a Full-Time Infection Preventionist

A salary is only part of what a facility pays for a full-time infection preventionist. Benefits, paid time off, and ongoing education add up quickly. Certification through a program like CIC, with more specialized credentials like CAIP available for ASC-focused practice, takes time and money, and it needs to be maintained year after year.

Then there is the hiring process itself. Recruiting for infection prevention roles can take months or longer, especially in smaller markets. Once someone is hired, they need time to learn a facility's specific policies, history, and culture before they can work at full capacity. They may even need to fit in knowledge gaps about the type of facility, depending on their background.

Turnover, which is high within the field of infection prevention, makes this worse. If an infection preventionist leaves, a facility can be left without dedicated coverage right when a survey is approaching. I have seen this exact gap put facilities at real risk more than once.

Even after a new infection preventionist is hired, they need onboarding and mentoring to get up to speed on a facility's specific history, policies, and survey findings. That transition period takes time no matter how experienced the new hire is.

Many facilities also run into a more basic problem: Infection prevention responsibilities get added to someone's existing clinical or administrative role. That person is doing their best, but infection prevention was never meant to be a side project. It requires focused time and specialized knowledge.

What Contracting an Infection Control Consultant Looks Like

Bringing in an infection control consulting firm can solve several of these problems at once. Instead of relying on one person's training and experience, a facility gains access to an entire team. At ICCS, our consultants come with extensive backgrounds, covering areas including sterile processing, water management plan development, and antimicrobial stewardship, and they receive ongoing support from other infection prevention experts. A single new hire cannot offer that same breadth on day one.

Contracting is also flexible. A facility can bring in support for a one-time risk assessment, request ongoing survey preparation, or set up a hybrid model that combines both. This lets a facility scale support up or down as needs change, rather than committing to a fixed headcount regardless of workload.

And if a consultant ever needs to step away, the facility is not left without support. A team-based model does not depend on a single individual staying in place indefinitely.

When Hiring In-House Still Makes Sense, and How Consulting Fits Alongside It

Larger health systems with high daily patient volume and multiple sites often do need a dedicated, full-time infection preventionist. The day-to-day workload at that scale calls for someone embedded in the organization full time, and I would never tell a facility otherwise.

Even in that case, a consulting partnership still has real, measurable value. A newer infection preventionist can benefit from mentoring and onboarding support from someone who has done this job for decades. An experienced infection preventionist can benefit from a second set of eyes on a risk assessment or a mock survey. And even a strong internal program can run into gaps in specialized areas like outbreak investigations or remote HAI surveillance and NHSN reporting support, areas that often fall outside what a generalist infection preventionist handles day to day.

Coverage during leave is another common use case. When an infection preventionist takes parental leave, medical leave, or simply moves on to a new role, a consulting firm can step in and keep the program running without a lapse.

The choice, in other words, is not always hire or contract. Many facilities get the most value from doing both.

How to Decide: Hire, Contract, or Both?

A few questions can help guide the decision of whether to recruit an infection preventionist or partner with an infection control consulting firm:

• Where does the facility stand in its survey cycle right now?

• Does current staff have the bandwidth to take on infection prevention responsibilities, or is it already being absorbed into another role?

• Would the facility rather budget for a fixed salary or scale spending based on actual need?

• Is the facility large enough, and complex enough, to justify a full-time hire, or would flexible support serve it better?

• If there is already an infection preventionist on staff, are there specific gaps where outside expertise would help?

Facility type matters here too. ASCs and imaging centers often feel the "added to someone else's job" problem the most, since they tend to run leaner staffing models. Hospitals and critical access hospitals are more likely to already have an infection preventionist on staff, but they can still run into specialized gaps that outside support fills well. In my experience, federally qualified health centers (FQHCs) often face some of the tightest staffing constraints of any facility type we work with, which makes flexible support especially valuable.

Final Thoughts

I have worked with facilities of every size on this exact question, and the right call always comes down to the same things: current staffing, budget, and where the real gaps sit. For some facilities, a full-time hire is the right call. For others, contracting gets them where they need to be without the overhead. And for many, the best answer is a combination of both.

Infection prevention is too important to leave understaffed or under-supported, whichever direction a facility chooses.

If you are weighing this decision for your facility, I invite you to contact us for a complimentary consultation. My team and I can help you think through what makes sense for your specific situation.

Frequently Asked Questions About Hiring vs. Contracting for Infection Prevention Support

Can a contracted infection control consultant meet CMS and accreditor requirements the same way an in-house infection preventionist does?

Yes. CMS, AAAHC, the Joint Commission, ACHC, QUAD A, and DNV all evaluate whether a facility's infection prevention program meets requirements, not whether that program is run by an employee or a consultant. A qualified consulting firm can build, run, and document a program that satisfies the same standards.

How quickly can a contracted consultant get up to speed on our facility?

This depends on the facility's size and complexity, but an experienced consulting team can typically begin meaningful work within the first few weeks of an engagement, starting with a review of current policies and an initial risk assessment.

Can ICCS support a facility that already has a full-time infection preventionist on staff?

Yes. We regularly work alongside existing infection preventionists, providing mentorship, second-opinion risk assessments, specialized program development, and coverage during leave or transitions.

What does a hybrid engagement, combining internal staff with outside consulting, typically look like?

A hybrid model often means an internal staff member handles day-to-day infection prevention tasks, while a consulting firm provides periodic risk assessments, survey preparation, specialized plan development, or backup coverage as needed.

Is contracting more cost-effective for smaller facilities than larger ones?

Smaller facilities often see the clearest cost advantage, since they may not have the patient volume to justify a full-time salaried position. Larger facilities can still benefit from contracting, typically alongside an internal hire rather than instead of one.