Practicing control and prevention of infections in the acute care setting has been my lot in life for more than 22 years. Public awareness including those in public service is certainly at an all time high. I embrace the interest with an open mind and enthusiastically work toward transparency both within the acute care setting and public sector. I have read the proposed changes to the Regulations for Disease Reporting and Control (12 VAC 5-90). I am grateful for the opportunity to comment on the proposed regulations.  

Excellent points already outline support, weaknesses in the proposed regulations, or recommended alternatives with their comments.  I have one concern or comment not already discussed.

Infection prevention answers to many regulatory agencies. Not all agencies have the same focus or requirements as has already been stated. Collecting accurate data and applying the indicators or definitions accurately is key to any surveillance program. Others have outlined concerns about validation and I definitely share those concerns but from a different angle. Surveillance has to be accurate.

In 1974 the Centers for Disease Control conducted a nationwide project, the Study on the Efficacy of Nosocomial Infection Control (SENIC project). The three main objectives of this study: 1. clarify the scope  and level of effectiveness  the establishment of an infection surveillance and control program had  on decreasing the rate of nosocomial infections; 2.. Describe the current status of the infection control and surveillance program and reported infection rates; and 3. Demonstrate the relationships among characteristics of hospital and patients components of the programs, and changes in the infection rate. That study set the gold standard for infection control departments across the nation. The importance of such a department was outlined as the determination that one Infection Control Practitioner (ICP) for each 250 beds would satisfy the need to conduct surveillance with the goal of reducing infections. But that was in 1974. Since that time the ICP has now become the Infection Preventionist or IP’s. We have moved from data collectors to infection preventionists or interventionists. We have not stop data collection just increased the amount of data collected and are now key leaders in implementing measures to prevent those infections.

Trundle et al. in 2001 showed ICP’s were working at 130 percent, during a normal day. That was 10 years ago.  

Dr. Carol O’Boyle et al., in 2002, published her study on “Staffing requirements for infection control departments in US health care facilities: Delphi project. Surveys were conducted with representation from 20 states. The study concluded: the IC responsibilities have expanded beyond the traditional acute care setting. Staffing recommendations must consider the number of occupied hospital beds, scope of program, the complexity of the health care facility, the characteristics of the patient population, and the unique or urgent needs of the facility and community. The suggested ratio for IP staffing was 1 ICP for each 100 occupied beds. That study significantly moved the ratio from the original 1974 study and today is almost 10 years old.

Stevenson et al. in 2004 reported an average of 1.58 ICP/250 beds, not much of an improvement from 1974.

A recent survey of Virginia IP’s showed implementation of the proposed regulations would add anywhere from a few hours to weeks of time to their more than 40 hour week. Most IP’s reported working 45 to 60 hours per week. .

Countless studies have been published on the impact increased hours worked has on health care workers. Critical thinking and medical decisions are negatively affected by overwork and fatigue for Residents, nursing, and emergency workers. I know the physical workload may not be the same but the critical thinking is definitely involved and impacted by the IP’s stretched workload

I support the use of additional measures, meaningful measures, but would ask for further investigation into proposed mandatory requirements for infection prevention staffing. We are not revenue generators but we have shown positive fiscal impact with decreasing infection rates.  Additional data requires additional hours to manage and analyze. To date, I am not aware of any discussion around this topic. With out additional resources we will not have valid/accurate data. I don’t think this is what the public or government would want. Support the intelligent look at the added indicators; support the need appropriate resources within the IC departments across the state in conjunction with any increased public reporting. Let us be secure in the information we provide to the public, while having time to prevent and implement measures to reduce the infections. Let us follow Dr. O’Boyle’s recommendation of 1 IP for each 100 beds as a minimum then add additional measures.  While we would like to be a trend setter, we would not be the first state to understand this need and follow the direction of our colleagues and make sensible IP requirements with the goal of the most accurate reporting  for selected meaningful measures