Virginia Regulatory Town Hall
Agency
Virginia Department of Health
 
Board
State Board of Health
 
chapter
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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2/14/11  3:58 pm
Commenter: Patrick G. Haggerty, M.D. , Hospital Epidemiologist, RRMC

Increased public reporting without validation makes no sense
 

1.  Central Line Blood Steam infections - The state has been collecting this data from the ICUs for the last several years.  Recently we had a visit from the State Epidemiologist's office to validate our data.  I applaud this effort to make sure that data reported from each of the hospitals is accurate.  Expanding this to reporting data from Med/Surg units is useful only if it can be validated.  If the state does not have resources to do this it should not be mandated.  Incorrect data is far worse than no data at all, especially if institutions are being judged by external regulatory bodies or the public, based on this information. It only makes sense that the best institutions with the most resources can afford the personel to collect this information accurately.  I question the purpose of sending this data to the state.  If there is an important reason that will actually improve patient care, then invest the resources at the state level to validate it.

2.  C-difficile infection, laboratory-identified on inpatient units.  I assume this is to identify hospital acquired CDAD.  Again without validation, these case can be mislabeled as community acquired, or in some cases not identified at all.   We cannot compare hospital to hospital without the state providing those resources.  I think it is more important to utilize the infection prevention (IP)nurses' time in developing strategies  to prevent these from occuring with all the stakeholders involved (including nursing, environmental services, and other services that interact with the patient).  That is what we have done successfully at Riverside.  It is critical that we move from disease recording and reporting to disease prevention.  Internal surveillance is important so that we can see how successful our prevention stategies have been.  External reporting does not provide that opportunity to involve the true stakeholders in the solutions and may provide data that is misleading to the public.   Rather than reporting numbers to the state, the state should ask questions like "what has your IP team done to prevent CDAD and what success have you had?".  Comparing data from before to after intervention is much more valid since it is done using the same personel using the same methods.

 

3.  SCIP - reporting.  This data is already being reported to CMS and the Joint Commission  from our Process Improvement team.  Having the infection prevention team report this too would be a duplication of services and again take their time away from important prevention activities.

 

In summary:

We need to be cautious in mandating reporting.  This activity is time consuming and again inaccurate if not validated by the state.  We need to focus on infection prevention activities and share successes with each other so developed strategies can be duplicated.  Collecting data that is not validated may lead to misinformation getting to the public arena, and may increase regulation based on faulty information.

CommentID: 15089