Commenter:
Inova Health System, Infection Prevention & Control Department
Support for the APIC VA Recommendations
The most important question to consider when mandating public reporting of healthcare associated infections is,” will reporting result in fewer infections and improve patient care?”
VDH does not plan to conduct data validation on the accuracy of the data reported. In the absence of data validation, it is unclear how the proposed reporting requirements could be effectively enforced.
Additional reporting requirements will limit the Infection Preventionists (IP) ability to participate in other programs or to effectively implement prevention programs for items identified in hospital’s annual Risk Assessment (as required by the Joint Commission).
According to the Virginia Register, “because the proposed requirements do not channel additional resources to existing infection control programs the benefits are expected to be small. In fact, the introduction of the additional measures that must be reported may actually divert resources from infection control activities to reporting activities at the hospitals”.
In bold are the three proposed changes to the Regulations for Disease Reporting and Control followed by suggested comments:
1. Central line-associated bloodstream infections in one adult inpatient medical ward and one adult inpatient surgical ward are to be reported to NHSN. Wards selected should be those with longest length of stay during the previous calendar year, excluding cardiology, obstetrics, hospice, and step-down units. Data shall include the number of central-line days in each population at risk.
Revise the statement to include NICUs (to coincide with the Centers for Medicare and Medicaid Servicesrequirement).
Remove the statement: “wards selected should be those with the longest length of stay during the previous calendar year, excluding cardiology, obstetrics, psychiatry, hospice, and step-down units”.
Add the word “or” to the statement: “Central line-associated bloodstream infections in one adult inpatient medical ward and/or one adult inpatient surgical ward”.
Define “step-down units”.
2. Clostridium difficile infection, laboratory-identified events on inpatient units facility-wide - shall include patient days.
Data analysis does not accurately differentiate between community acquired, hospital acquired or other healthcare associated, i.e. non-acute care faculty. Rather than simply publicizing the number of cases identified at a facility, VDH should assist hospitals with the development of programs shown to reduce CDI, for example, antibiotic stewardships and public education.
3.SCIP (Surgical Care Improvement Project) core measures pertaining to hip arthroplasty, knee arthroplasty, and coronary artery bypass graft procedures are to be reported quarterly to the Virginia Department of Health.
SCIP data is currently publicly reported; reporting to VDH the same data will be a duplicated effort. Surgical site infection reporting should align with the Centers for Medicare and Medicaid Services indicators.
The information is already available on the Hospital Compare website. VDH should provide the Hospital Compare link on the VDH website, rather than require duplication of reporting.
Public reporting diverts the IPs attention from prevention. The State of Virginia needs to move from disease reporting to disease prevention; the proposed changed do not address prevention strategies.
Respectfully submitted,
Inova Health System, Infection Prevention & Control Department
