The theory behind publicizing adverse events such as hospital acquired infection (HAI) rates is that by doing so, better prevention strategies will be implemented.  However, reporting via the National Healthcare Safety Network (NHSN) requires data entry of more than just the numbers of a particular infection, device days , and total patient days.  The data entry tasks can be cumbersome, especially without data mining programs.  Manual entry of data diverts the Infection Preventionist from developing and monitoring prevention and control strategies.  Furthermore, other than publicizing the infection rates on the VDH website, nothing is done with that data  once  VDH  receives the information.  The regulation/law does not specify that VDH is to assist hospitals with improvement processes.  This leaves one to question the value of reporting data other than number of cases.  The value of public reporting has even been questioned by the Healthcare Infection Control Practices Advisory Committee (HICPAC) who found that there is insufficient evidence to recommend public reporting of HAIs. 

Questions:

Will reporting numbers and rates in the Healthcare-Associated Infections Report (Virginia Department of Health website) be meaningful to the audience it was intended for – the consumer (is there evidence to demonstrate that the public has benefited from the central line-associated bloodstream infection (CLASBI) data that has been reported since 2009)?

How will reporting such data lead to evidence-based strategies to optimize patient safety and quality?

What tasks will the Infection Preventionist (IP) have to omit in order to fulfill the reporting requirements (most facilities allocate minimal resources to the Infection Control Department)?

Recommendations:

If additional HAI reporting must be required, align the measures/indicators with the Centers for Medicare and Medicaid Services (CMS) so that the Infection Preventionists are not collecting different indicators, for different time spans, and entering data in numerous data bases (for example, CLABSI and SCIP data) .  The State should either (1)obtain access rights to the data submitted to CMS or (2) include the link for CMS on the VDH website.  This will allow the public to obtain the information.  Omit the Clostridium Difficile Infection (CDI) measure.  Since this measure cannot accurately portray a facility specific CDI rate (does not take into account CDI from external facilities such as Long Term Care), rather than requiring time consuming data entry, add to Virginia Reportable Disease List and have it reported similar to Influenza (“report number only”). 

When conducting a business case analysis for a new project or proposal for change, IPs and other leaders are encouraged to consider the effect of such projects on operations, costs, others impacted, and  the ability to improve patient safety and care.  There is no indication in the proposed changes to the Regulations for Disease Reporting and Control of any of these considerations, in fact, the proposal states “because the proposed requirements do not channel additional resources to existing infection control programs the benefits are expected to be small.  In fact, the introduction of the additional measure that must be reported may actually divert resources from infection control activities to reporting activities at the hospital level.”

Please consider obtaining the CLABSI and SCIP data from existing sources rather than requiring duplication.  Revisit if and how CDI is to be reported.

Thank you for the opportunity to comment.