As an active member of APIC Virginia I concur with the proposed recommendations posted on this website.  And since these recommendations have been thoroughly discussed by APIC Virginia and others, I will focus my response on a slightly different arena; that of the ultimate goal – infection prevention.

It is inarguable that healthcare acquired infections (HAIs) are a major problem worldwide.  HAIs have moved into the national spotlight and today’s focus is on infection prevention.  The goal of the Virginia Department of Health (VDH) and our legislators is the same as Virginia Infection Preventionists (IPs); to protect patients from preventable infections.  If mandatory public reporting were proven to help us do a better job protecting our patients, this would be a good thing!

However, the question remains; does public reporting actually prevent HAIs?  This query has been debated extensively, yet it is still unknown what impact, if any, public reporting will ultimately have on health care quality.  Reporting data simply for the sake of reporting will divert already slim infection prevention resources away from patient care and infection prevention. 

The Healthcare Infection Control Practices Advisory Committee (HICPAC), a federal advisory committee established in 1991 to provide guidance to the Department of Health and Human Services and CDC, conducted a scientific literature review to evaluate the merits and limitations of HAI reporting systems and found no published information on the effectiveness of public reporting systems in reducing HAIs.

Hospitals are currently required by The Joint Commission (TJC) to conduct annual and as-needed Infection Risk Assessments, utilizing in-house surveillance data to identify potential problem areas and then targeting these areas for performance improvement interventions.  TJC evaluates to determine whether infection control has put plans, processes, procedures and programs in place to address, eliminate or counteract the effects of these risks.

Risk assessments are the cornerstones upon which each hospital’s infection control program is built and help to ensure that data collection is concentrated in populations where HAIs are most frequent and that rates are calculated that are useful for targeting prevention.  IPs should be spending a majority of their time on the floors and units with staff and patients, applying epidemiologic principles to truly prevent infections – not collecting and reporting data that may have no infection relevance to their hospital.

As a non-revenue-producing department, Infection Prevention and Control has a history of being able to generate much with little.  It is common for hospitals with under 250 beds to have an infection preventionist who also serves in other capacities; Employee Health Nurse, Emergency Response, staff nurse, etc.  The proposed regulation forewarns, The disadvantage to the regulated community (hospitals) is increased workload that would be created.  Given the current economic climate in health care, additional staffing to monitor and publicly report HAIs, especially those not on, or pertinent to, a hospital’s Risk Assessment, is not going to happen unless legislated.

The Virginia Department of Planning and Budget Economic Impact Analysis imparts the following:

1. Reporting of three additional measures is expected to demand more administrative resources from VDH.  VDH believes that the current staffing level made possible by the temporary federal stimulus funding would be able to absorb the increased workload in terms of the retrieval of data reported to NHSN and dissemination of the same data to public if requested. 
2. While the verification of data could be costly, VDH does not plan to conduct data validation of the accuracy of the data reported.
3. In the absence of data validation, it is unclear how the proposed reporting requirements could be effectively enforced.  
4. Due to litigation concerns, hospitals already have strong incentives to minimize the number of infections occurring at their facilities. Given already existing strong incentives to minimize infections, it is unclear whether reporting would be an effective way to reduce infections at the margin.  
5. Furthermore, because the proposed requirements do not channel additional resources to existing infection control programs the benefits are expected to be small.
6. In fact, the introduction of the additional measures that must be reported may actually divert staff resources from infection control activities to reporting activities at the hospitals.

The VDH has federal funds to support this effort through December 2011, after which time the requirement could place a financial hardship on the Agency.  IPs will be required to absorb the additional reporting responsibilities on a permanent basis, with no foreseen additional assistance.

A method to validate data is essential in any credible mandatory reporting system in order to ensure that HAIs are being accurately and completely reported and that rates are comparable among all hospitals in the reporting system.  Publicly reported data must convey scientific meaning that is interpretable to a diverse audience and must highlight its potential limitations.  HAI rates could mislead stakeholders if innaccurate or misleading information is disseminated.  The importance of data validation was emphasized by a CDC study of the accuracy of reporting to the NNIS system.  It was determined that, although hospitals identified and reported most of the HAIs that occurred, the accuracy varied by infection site.  

As expressed by many of my fellow colleagues this data is currently reported through CMS, Joint Commission and other payer sources, i.e. QHIP.  For IPs to be required to report this data to NHSN is duplicitous.  If these proposals are approved, this data should be made available to the public through an already reported to entity.

The infection control and epidemiological community in Virginia will continue to work diligently to reduce infection rates.  When health care providers join forces to reduce the risk of infection and improve adherence to infection-prevention protocols, infection rates can be reduced and lives saved.  Success requires collaboration between health care providers, government agencies, legislators, administrators, patients, professional and consumer organizations and payers.  However, I am not convinced that reducing infections will happen simply by publicly reporting HAIs.

Without verification that reporting data will make a difference in reducing actual infections, we should be very careful that we are not reporting simply for “reporting sake” and ultimately creating analysis paralysis for the very people at the forefront of prevention – the Infection Preventionists.

Thank you for the opportunity to comment.