March 29, 2006
The Honorable Edward Whitfield
Subcommittee on Oversight and Investigations
Committee on Energy and Commerce
U. S. House of Representatives
Washington, DC 20515
Dear Mr. Chairman:
Consumers Union commends the Subcommittee for looking into the serious problem of hospital-acquired infections, and particularly for considering the important role of public reporting as part of the solution.
Our www.StopHospitalInfections.org project has been actively advocating for healthcare consumers – both individuals and businesses – to have access to information about how effectively their local hospitals are at preventing infections. We have heard from over 1300 people whose lives have been changed by a hospital-acquired infection. While many have survived multiple hospitalizations and surgeries, others have lost loved ones or become permanently disabled. The statistics nationally are dramatic: 90,000 dead, two million infected each year.
Clinical studies have repeatedly demonstrated that these infections can be prevented, yet an acceptance of the inevitability of hospital-acquired infections has prevailed in our healthcare system for decades. The standard of practice has been to treat infections after they appear, rather than prevent them. And now antibiotic-resistant superbugs that cannot be cured or eradicated with existing medications make prevention an even higher priority. It is clear that hospitals can do so much more to stop these infections.
Public reporting laws will ensure that information is available about all hospitals, not just those that voluntarily come forward to reveal their record. All hospitals will be required to identify their infections in the same way and reports will show how they compare to their competitors. Consumers will have information to make wiser healthcare choices based on quality of care and when the information is published, hospitals will have an incentive to improve their performance.
So far, the focus of our work and most of the debate on public reporting has been at the state level. Currently, six states (Illinois, Pennsylvania, Missouri, Florida, Virginia, and New York) have hospital infection disclosure laws and 30 states have introduced similar legislation this year.
The actions in these states will provide valuable lessons for any national system that might be considered in the future. When a national system is established, it should allow States to enact additional, even stronger laws to protect their citizens. Any national legislation should be a strong floor—not a ceiling—that will provide immediate, life-saving help. While all of the states are following similar paths, each state has developed its own unique method for collecting and publishing hospital infection information. We believe this variation will help to identify the best methods.
In July, 2005, the Pennsylvania Healthcare Cost Containment Council (PHC4) published the first report in the U.S. on incidences of hospital-acquired infections in that state. Although the agency found that hospitals underreported the infections occurring at their facilities, hospitals identified almost 12,000 of these infections that caused over 1700 deaths in 2004. The estimated charges for these 12,000 infections totaled $2 billion, 76% of which was paid by Medicare and Medicaid. The agency also asked third party payers about the average cost to treat a patient with an infection – the cost was more than $29,000, compared to the average cost of $8300 for a patient without an infection. Today you will hear of a new report with updated figures from PHC4. Florida has also produced a statewide hospital infection report that compares each hospital in that state. This report shows significant variation among hospitals.
We believe a strong hospital infection reporting system must include, at a minimum, the following elements:
• The reports should be publicly available in a timely manner so the information is relevant to consumers making healthcare choices.
• The reports should include outcome measures such as the rate of infection and these rates should be risk-adjusted to make the information comparable among hospitals that have different patient populations. “Process measures,” such as those now being collected on a voluntary basis by CMS , measure practices that have been clinically proven to prevent infections. Reporting on these can educate the public on what hospitals should be doing but should not be the sole measure of a hospital’s record of infection control. Focusing only on selected process measures, without including outcomes, might lead to neglecting overall comprehensive infection control efforts.
• The reports should include at a minimum the four most common infections, which have been collected by the Centers for Disease Control and Prevention (CDC) over the past 30 years in their National Nosocomial Infection Surveillance (NNIS) System. These are central-line blood stream infections, surgical site infections, ventilator associated pneumonia, and urinary tract infections. The ability to add measures should be included as we learn more from prevention and reporting efforts.
• The reporting system should be enforceable, with the ability to validate data to ensure accurate reporting by hospitals and meaningful reporting to the public.
• The system must establish uniform, standardized definitions and protocols for collecting data. These should build on already established systems, such as CDC’s.
• The system should identify hospitals and other facilities, if included , but should not contain information identifying a patient, employee, or licensed healthcare professional in connection with a specific infection incident.
• The system should include advisory committees, with experts and consumer and healthcare payer representatives.
Consumers Union looks forward to working with the Subcommittee on this urgent healthcare problem. A hospital’s ability to prevent the spread of infections is a basic measure of the quality of care provided there and public disclosure of the hospitals’ efforts will save lives and reduce healthcare costs.