As a member of a VDH/VHHA task force on public reporting I do understand that the public desires (and has a right to access) data on HAIs. As a long time Infection Preventionist I also understand that, to be of value, these rates must be generated via the same process. Additionally, definitions to allow for the generation of these rates must be useful to exclude previously existing conditions. My organization trialed the C difficile lab ID module via NHSN during 2010. This trial allowed us to identify several issues towards generating useful data. This NHSN module does not capture the antibiotic exposure potential for a case of C difficile and does not allow for consideration of symptoms on admission or prior infection at home or at another healthcare facility. As a result, data generated from this NHSN module will not be useful in comparing horizontal transmission of C difficile within a healthcare facility. Each IPs time is valuable towards preventing infections therefore the addition of a non-value added data collection activity will detract from, rather than enhance, an infection prevention program.  I propose that this requirement by eliminated from the regulations.

I support the addition of NICU central line bloodstream infections to the current reporting requirement of adult ICU CLABSIs. This would bring Virginia reporting requirements in line with CMS reporting requirements. If CLABSI reporting outside of the ICU is selected to remain in the requirements I suggest that hospitals be required to report from either one surgical or one medical unit as some smaller facilities do not have both. The IPs dilemma in accurately reporting CLABSIs is in having access to an accurate denominator (central line days). This accuracy is increasingly difficult in a large, non ICU setting. I suggest that it would be advantageous to have accurate data from one non ICU than inaccurate data from multiple non ICUs.

I support the inclusion of the SCIP data for hip arthroplasty, knee arthroplasty and CABG procedures however I would strongly encourage the requirement read that this data be made available from the Hospital Compare website. To report from another source would be a duplication of efforts which always allows for some potential of error.    

Thank you to the opportunity to comment.