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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.  Recommend removal of  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”.  Recommend 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”.  What is the VDH definition of a step-down unit? Why would you exclude these step-down units, as they are typically the “next step” from an ICU and will have more central lines than other units? ICU’s are already being reported, and this is where the majority of the central lines are used, why would you add another department with no basis for comparison.

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. The NHSN definitions are ambiguous at best and allows the facilty to determine their perception of where the CDI was originated. NHSN doesn't account for a history or symptoms of previous infection with no testing. What good is this? Does this actually help the patient or hospital with preventing CDI? No! I see no benefit to anyone, even the public, with this proposed regulation.

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 IP's attention from prevention. The State of Virginia needs to move from disease reporting to disease prevention; the proposed changed do not address prevention strategies. Hospitals are already overburdened with reporting requirements and loss of revenue due to budget cuts and reimbursement, these proposed changes will make more work for the IP's who are already at a loss to help keep patient safety the priority.

I do not believe any of these proposed regulations will result in fewer infections and improve patient care, therefore all should be voted against.