Virginia Regulatory Town Hall View Comments

Virginia Department of Health

State Board of Health

Regulations for Disease Reporting and Control [12 VAC 5 ‑ 90]

Action	Expanded Requirements for Reporting Healthcare-Associated Infections
Stage	Proposed
Comment Period	Ended on 4/1/2011

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3/28/11 10:27 am

Commenter: Bonita Allen RN CIC

Reporting should be consistent with National Reporting Requirements and be of value to VA citizens

Reporting of Hospital Associated Infections should be consistent with National Reporting Requirements and be of value to VA citizens. As hospitals are being tasked to report nationally to the NHSN, I suggest the VDH follow the lead of the national trends. In 2011 we began reporting CLABSI in ICU's and NICU's and it is forecasted hospitals will be reporting surgical site infections by procedure in 2012 (undetermined type of procedures). SCIP measures are being reported nationally at this time.

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.

Although VDH receives Central Line Associated BSI data by type of ICU unit, VDH does not report the comparison by type of unit on the website. The logic of adding specific types of non-ICU units to the data is

not consistent with the current reporting design
may not be of value to VA citizens.

Hospitals that have NICU's are now collecting and reporting data utilizing national guidelines to the NHSN. This information can easily be transferred from NHSN to VDH and compared.

2. Clostridium difficile infection, laboratory-identified events on inpatient units facility-wide - shall include patient days.

The reduction of C diff across the nation is one of the national goals. However the methodology of this request does not provide good surveillance methods. Just using test results and number of days past admission does not give a fair analysis to credit hospitals with a hospital associated infection.

This measure is almost like using coded data to measure quality.

I am opposed to this measure as written.

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.

This process measure may be of interest to Virginia residents. Hospital Compare website does a nice job of reporting the SCIP data and allowing comparison. Suggest this be adoped as a measure and provide the link with instructions on how to view the information.

CommentID: 16292