Many valid comments have already been made, so I will limit my comments to areas not previously addressed. 

• For each proposed metric, VDH should provide an analysis of:  value added, utility for consumers, validity, potential adverse unintended consequences, and opportunity cost.
• It is unclear to me how having hospitals report CLABSI from 1 surgical and 1 medical ward is of value. Since the goal of public reporting is for consumers to be able to compare hospitals, the variability in types of patients and wards will greatly limit its utility. The proposed regulation asks hospitals to choose the ward with the longest length of stay; however, this may not be the ward with the greatest utilization of central lines. Moreover, without some type of risk adjustment, interhospital comparisions will be fraught with peril.
• C. difficile infection is a problematic metric since it can be difficult to know whether the infections were community- or hospital-acquired. In addition, the testing used by hospitals varies and the tests have different sensitivity. Mandating reporting of C. difficile cases provides hospitals an incentive to employ tests of lower sensitivity, which is not in the best interest of patient care. 
• For every new publicly reported metric proposed, VDH should report its plan for measuring the validity of the metric. The resources devoted to infection prevention, the training and expertise of personnel, and the IT infrastructures vary widely across hospitals in Virginia, all of which have a significant impact on validity.