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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3/30/11 11:14 am

Commenter: Barbara Stein, Children's Hospital of The King's Daughters

VDH proposed HAI reporting additions

While I appreciate what VDH is trying to achieve, i do not think that the past reporting measures added nor the proposed measures will acheive the real goal. ICPs value public health and their efforts and wish for their energies and monies be spent making a real impact.

Hospitals already report HAIs to agencies that accredit or have existing reporting requirements, such as Joint Commission and CMS-- whom inspect and require proof that successful efforts are being made to prevent infections. Reporting to one more agency will not improve the outcomes and will only take time, effort, and money away from the prevention efforts. As noted in the proposed regulations the incentives to perform better are already there.

C. diff is also already a target for prevention with The Joint Commission, etc. Instead of reporting, the state should spend money on efforts to prevent them. For example, fund antibiotic stewardship programs or research. Event reporting does not allow distinguishing community from that which was acquired in the hospital. This will not help the public form opinions on safe hospitals when it is based on possibly inaccurate data.

We all have concerns about not validating data. How will reporting help the public make informed decisions if the data isn't validated? Bad data is worse than no data at all and could be harmful to organizations. The cost of collecting and reporting this data may outweigh any benefit and even VDH admits this may be the case.

Financial impact is great for some facilities. This is and previous HAI reporting are unfunded mandates that cost hospitals precious resources at a time when increasing costs and decrease reimbursement are putting pressures on hospital budgets. For many ICPs this reporting will require it to be done through a venue that is time and labor intensive (NHSN) that weren't present before and will result in taking time and resources from the real work efforts. VDH acknowledges that there will be Increased labor demands and admits that there are likely limited and possibly no benefit to the reporting of this information. Reporting just to report really doesn’t help the public good..

For those hospitals that are small businesses, these requirements will have a greater financial impact. Many things are manually collected, information technology resources/software for auto data collection is not routinely available and this would increase the workload exponentially.

The money spent in setting up these requirements and more administrative costs on the VDH side takes more money that public health nor the Commonwealth of Virginia have to spend. Money would be better spent in other areas of public health that would truly show benefit for the greater good.

Reporting in itself makes no impact on prevention. The public would benefit more from VDH efforts to research prevention, support infrastructure or support implementation of interventions that make a difference.

Thank you for your time and opportunity to comment.

CommentID: 16315