Re: CLABSI reporting: Our facility currently reports CLABSIs in Critical Care and new this year is CMS requirement for entering data for NICU CLABSIs;  this proposal adds two more areas without any verification that reporting data will make a difference in reducing actual infections.  In fact , from the Regulation proposal itself, page 1135, the following statements are recorded, “ While the verification of data could be costly, VDH does not plan to conduct data validation on the accuracy of the data reported.  In the absence of data validation, it is unclear how the proposed reporting requirements could be effectively enforced.”  In essence, this regulation is being proposed without any measure to ensure that 1.  The information is correct 2. The reporting requirement can be enforced and 3. That it will make a difference to reducing infections.  We have joined the CUSP project which is a nationally recognized active program to reduce CLABSIs.

Re: Cdiff proposal: We are like many facilities in VA who do not currently have the capability to download denominator data directly to an outside source. In order to be able to have this type of automation, facilities will be forced to purchase external data mining resources which may cost anywhere from $60,000+ annually.  With many facilities throughout the state not even having a dedicated Infection Preventionist, the expectation that a facility will now purchase a separate program is not realistic.  In other words, this requirement is being proposed without any regard to the implication that hospitals do not have the resources to comply.

Re: SCIP reporting to VDH:  SCIP core measures are already being reported to a variety of validated sources and are publicly reported.  Why should a facility be required to also report this information again directly to the VDH?  Does the VDH question the validity of this information or expect that it would be reported in a different format to them?  It would make more sense to have the VDH provide links to this information in their website.

Unfortunately, the proposed regulations have no evidence base to signify that they actually can reduce infections; it is difficult to support any regulation which also states (page 1136 of Regulation) that “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 measures that must be reported may actually divert resources from infection control activities to reporting activities at the hospitals.”  In effect, reporting which is not validated may have little benefit and take the very individuals who can be instrumental in advocating improvements further from the patients we are supposed to protect.

I am writing to request that all of these proposed regulations be voted against.  I am in full support of any evidenced based measures which are known to reduce infections as well as researching Virginia facilities which have shown to effectively reduce infections.  Noteworthy is the fact that 60% of the facilities who participated in the VHQC MRSA reduction project showed a reduction in ICU MRSA rate infections of 28%. Our facility had a reduction of 70% as a voluntary participant and this was directly as a result of active involvement of the Infection Preventionist.  We have a proven track record that in the last three years, every project that the Infection Prevention department has become involved in has effectively reduced HAIs and I am very concerned that the prospect of removing this effective department further from the bedside will, in fact, create a situation of increased harm to our patients.  One final note is that if reimbursement is tied to infection rate reporting, this very measure could increase our infection rates (which could not be validated) and directly reduce our reimbursements.