SENT VIA VIRGINIA TOWNHALL (townhall.virginia.gov)

March 10, 2022

Commissioner Gary G. Pan

Department of Labor and Industry

Main Street Center

600 East Main Street, Suite 207

Richmond, Virginia 23219

Re:      Proposed Revocation of the Virginia Standard for Infectious Disease Prevention of the SARS-CoV-2 Virus That Causes COVID-19, 16VAC25-220

Dear Commissioner Pan:

On behalf of the Virginia Hospital & Healthcare Association’s (“VHHA”) 26 member health systems, with more than 104,000 employees, thank you for the opportunity to comment on the Department of Labor and Industry’s (the “Department”) Proposed Revocation of the Virginia Standard for Infectious Disease Prevention of the SARS-CoV-2 Virus That Causes COVID-19, 16VAC25-220 (hereafter referred to as the “DOLI Regulations”). We strongly support the proposed revocation of the DOLI Regulations.

Infection prevention and control is a daily, ongoing focus within Virginia hospitals and health systems. Operating under the oversight of the Centers for Disease Control and Prevention (CDC), the Centers for Medicare & Medicaid Services (CMS), the Virginia Department of Health (VDH), and various other accreditation and regulatory authorities, hospitals and our ancillary facilities are required to consistently demonstrate that their patients and staff receive and provide care in a safe environment. This includes development and implementation of comprehensive infection control plans, quality improvement programs, managing supply chain, training employees and caregivers, ensuring employees have the resources they need, planning for future health emergencies, and working with congregate care settings to institute strong infection control practices, among other activities.

The DOLI Regulations were a duplicative regulatory scheme that introduced contradiction and uncertainty to an already highly regulated industry that has a moral obligation to ensure the safety of its patients and employees, regardless of any regulatory requirement. By repealing the DOLI Regulations, the Department will afford hospitals and health systems the opportunity to once again focus on the safety of their patients and employees rather than compliance with burdensome and duplicative regulations.

Sincerely,

Sean T. Connaughton

President & CEO