As Director of Infection Prevention & Control for the Sentara Healthcare System I appreciate the opportunity that you have provided for the Infection Prevention & Control Community to provide expert input to the current proposed state reporting “Regulations for Disease Reporting and Control”. 

Currently, Sentara facilities are partners with CDC/NHSN in the reporting of healthcare associated infections into a nationally recognized database and perform targeted surveillance based on their facility annual “risk assessment”, targeting those infections for continued surveillance and prevention activities for their patient population.  Additionally, Sentara facilities participate in the state requirement for reporting of CLA-BSIs within the adult intensive care units, and CMS requirement for reporting of surgical care improvement process measures pertaining to specific surgical procedures.  Sentara has a very robust Infection Prevention & Control Team that focuses on the safety of its complete environment inclusive of all patients, visitors, and healthcare providers.

In review of the proposed regulations, I have identified several areas of each component that I would like to focus on:

Measurement #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.”

a)      To reflect the Centers for Medicare and Medicaid Services requirement NICUs should be included in the verbiage;

b)     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”, should be removed as this requirement could be calculated in numerous ways and could lead to non-comparative data;

c)      Change the following statement to reflect the word “or” as many facilities have mixed units or only one type of patient population:  “Central line-associated bloodstream infections in one adult inpatient medical ward and/or one adult inpatient surgical ward”.

d)     Definition of “step-down units” would have to be better defined for specific comparative data.

Measurement #2: “Clostridium difficile infection, laboratory-identified events on inpatient units facility-wide - shall include patient days.”

a)      What epidemiological value or trending can be accomplished with this data program?  Data analysis does not accurately differentiate between community acquired, hospital acquired or other healthcare associated acquisition.  Infection Preventionists would simply be reporting the number of cases identified at a facility.  Perhaps focusing on hospital antibiotic stewardship programs or community education on CDI would serve the public better and addresses actions to reduce the potential for CDI.

Measurement #3: “Surgical Care Improvement Project (SCIP) 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.”

a)      SCIP data is already publicly reported through our facility Quality Departments – this would be a duplication of efforts by each facility and therefore would take time away from other prevention measures.  I would recommend the state investigate avenues to work with the Centers for Medicare and Medicaid Services and not have duplicate efforts and double reporting on these indicators.

In closing the proposed regulations do not speak to the validation or verification of data reporting and therefore can not verify standardization or accuracy for comparative value.  The State of Virginia needs to move from disease reporting to disease prevention; the proposed changes do not address prevention strategies and will not result in fewer infections or improve patient care by changing the focus of the Infection Preventionist from prevention to data reporting.  Public reporting of HAIs should promote evidence based practices and report meaningful and accurate data for the consumers and the healthcare industry.

Respectfully Submitted by:

Jacqueline P. Butler, CIC

Director, Infection Prevention & Control

Sentara Healthcare