VDH should design this disease reporting requirment change in manner that it does not function as a disincentive for a hospital infection control person or the ID physican or laboratory  to pick up the phone and call their local health director when they think they really have something going on.  For outbreak management and infection control purposes timing can be everything.   Recommend that the regulations be written in a manner so that they do not limits the infectious disease reporting requirement and involvement of local public health officials, if needed,  to entering some data into an electronic database – especially outside VDH. 

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We have an excellent working relationship with our local health departments.  If there are questions on either end, we pick up the phone and call. I would hate to see that become automated. We are already following VDH reporting requirements in a timely manner.  I do not see the added value in allowing access to NHSN data. Organizations currently select components of participation in NHSN.  This may change in the future and requirements may increase. Would need clarity how this data would help VHD or how the data will be utilized.  The data is already public.

We have no issues granting rights to VDH to view hospital healthcare associated infection data mandated by CMS and  reported to NHSN.

The Association for Professionals in Infection Control and Epidemiology, Virginia Chapter (APIC-VA) is a non-profit, multidisciplinary, statewide organization consisting of 200 members, whose mission is to improve health and promote safety by reducing risks of infection and adverse outcomes to patients and healthcare personnel.  We applaud efforts to improve the quality of patient care, appreciate the opportunity to provide input to state reporting regulation proposals and shall continue to assist in these efforts through the sharing of our expertise in the prevention of healthcare acquired infections (HAI). 

The current reproposal by the VDH Board of Health to 12VAC5-90, Regulations for Disease Reporting and Control are defined in the Virginia Register of Regulations, Volume 30, Issue 6, 11/18/2013, pages 697-704.  The reproposal summary states, “The reproposed amendments provide that data reported into the Centers for Disease Control and Prevention’s National Healthcare Safety Network (NHSN) for the Centers for Medicare and Medicaid Services Hospital Inpatient Quality Reporting Program shall be shared, through the NHSN, with the department.”

Since the advent of mandatory reporting in Virginia, the Virginia Department of Health (VDH) has worked closely with APIC-VA to determine the most efficient means of measuring public safety in hospitals, while remaining sensitive to the ever-increasing demands made upon hospitals and Infection Control Preventionists (ICPs).  The reproposals provide VDH with additional measures related to HAIs from acute-care hospitals without increasing the reporting burden on hospitals and ICPs to submit the information.  

As the aforementioned reproposal supports our mission, APIC-VA supports the amendment as written.

Respectfully submitted,

APIC Virginia, Chapter 12

I applaud the efforts of VDH in seeking additional HAI information with which to keep Virginians safe and also for their cognizance of time constraints placed upon Infection Control Preventionists (ICP).  There have been many new reporting demands over the past several years, making it harder and harder to spend adequate time on the floors and units conducting rounds and educating patients, staff and family members.  This amendment will make it possible for VDH to acquire the information they need without further burdening ICPs.

As I see it, this reproposal does not impact the Virginia Reportable Disease List.  We will continue to report any and all pathogens on this list to our local health department.  We have developed a unique working relationship with the staff of our local health department and will continue to collaborate with them.  

For the reasons mentioned above, I support this reproposed amendment as written.

Thank you for the opportunity to comment.