Re: CLABSI reporting: The physcian management and administration of Doctors Surgery Center strongly propose the recommended changes to CLABSI reporting. First and foremost we do not trust that adding two more areas without proof that the reporting data will absolutely reduce actual infections will be beneficial to our center or to our patients.

In a busy ASC where efficiency is a key component of our success in providing quality surgical care this could be another time consuming step that is implemented without evidence that it will make a difference. The system that is in place currently at our surgery center is outstanding and we have no difficulty in the reporting structure and flow. We do not want nor do we need additional reporting steps that have not been verified to reduce actual infections.

In the for-profit setting we must keep expenses down and profit up. Failure to do this is a failure in our business model. We are certain additional costs would hit our botttom-line and if the return on investing time and money in something that has not been verified to work occurs it will be a huge disappointment to our ownership.  

Re: SCIP reporting to VDH: Why would be asked to duplicate efforts in reporting SCIP core measures when this is already being publically reported. It seems like another bureaucratic requirement that makes us working more efficiently doubly difficult.

Re: Cdiff: We do not have the capabilty to download denominator data directly to an outside source. Forcing our facility to invest thousands of dollars  to purchase external data mining resources to save this type of automation is an expense we can not bear and one our facility owners strongly object to.

Our 14 physician owners and our three administrators strongly vote against these proposed regulations.