The introduction of infection control programs in healthcare has made a significant impact on patient outcomes, as well as improvements in employee safety. These improvements did not take place with the Infection Preventionist (IP) sitting in an office collecting or reporting data. For a reduction in HAI’s the IP’s need to be visible to patients, visitors, and employees and actively involved in process improvement efforts. The continued availability of the IP is imperative for these improvements which will decrease adverse patient and employee outcomes.

• Consider revising to only one additional inpatient ward as there are acute care facilities in Virginia who do not have separate medical and surgical wards.
• Consider deleting “wards should be those with longest length of stay....excluding cardiology, obstetrics, hospice, and step-down units”. This requirement limits the number of hospitals required to report.
• Why were step-down units excluded? Step-down medical and/or surgical units may in fact be the areas that have the most central lines therefore increasing patients who may be at risk for acquiring a CLABSI.

• Consider removing completely. This requirement does not take into consideration patients who may have received antibiotics in the outpatient setting and not had a previous hospital stay. By not including definitions of healthcare associated C-Diff infection what comparison will be made? Submission of this data without stratification would not provide hospital specific information regarding C.Diff and/or antibiotic stewardship. Where is the scientific evidence that this requirement would lead to prevention and a reduction in the number of C-Diff cases? How will gathering these numbers be used to change practice or prevention efforts?