June 18, 2010
to Disclose Infection Rates and Tie Payments to Performance
WASHINGTON, D.C. – National and state patient safety organizations are urging the Department of Health and Human Services to adopt a set of proposed regulations that will require all U.S. hospitals to disclose how many patients develop certain infections during treatment. The groups also support the proposal to tie Medicare payments to how well hospitals protect patients from these infections. The regulations are required under the landmark healthcare reform law and are being developed as part of the Department’s five-year action plan to reduce hospital acquired infections.
In a letter sent today, the groups, many of which were instrumental in helping to pass hospital infection reporting laws at the state level, urged HHS to strengthen the proposal by expanding the number of infections covered by the regulations to measure progress toward all targets set by the Agency’s Action plan, including MRSA and C. Difficile infections.
“If we fail to change the course of this epidemic, ten million hospital patients will get an infection over the next five years and a half a million of them will die,” said Lisa McGiffert, Director of Consumers Union’s Safe Patient Project (www.SafePatientProject.org). “It is time to make eliminating hospital acquired infections a top priority. Public reporting of infection rates can serve as a powerful tool for holding hospitals accountable for reducing infection risks and keeping patients safe.”
A copy of the patient safety group letter to HHS follows:
June 18, 2010
Centers for Medicare and Medicaid Services
Department of Health and Human Services
200 Independence Avenue, SW
Washington, DC 20201
RE: 42 CFR Parts 412, 413, 440, 441, 482, 485, and 489; CMS-1498-P (Proposed Changes to the Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long Term Care Hospital Prospective Payment System and Proposed Fiscal Year 2011 Rates)
Comments on Proposed New Healthcare Associated Infection (HAI) Measures for the FY2013 Payment Determination and other changes to public reporting of and payment policies for hospital quality and safety measures in the Reporting Hospital Quality Data for Annual Payment Update (RHQDAPU) Program
Dear Ms. Tavenner:
As consumers and consumer organizations who have worked throughout the country to pass and implement state hospital infection reporting laws, we strongly support the proposed regulations to include public reporting of hospital-acquired infections in the Reporting Hospital Quality Data for Annual Payment Update (RHQDAPU) Program and to tie Medicare payments to how well hospitals protect patients from these infections. This will protect patients and give them important healthcare safety information, regardless of which state they live in.
Our goal is to eliminate hospital-acquired infections as rapidly as possible. We have witnessed the influence that public reporting can have in stimulating more prevention activities in hospitals. The proposed regulations are intended to measure the progress of the HHS “Action Plan to Prevent Healthcare-Associated Infections” – a 5-year plan to reduce infections. If we fail to change the course of this epidemic, over the next five years ten million hospital patients will get an infection and half a million of them will die. Many other diseases and healthcare problems that affect a fraction of patients get much more attention from our nation’s healthcare leaders. It is past time to make this our highest hospital safety priority. We agree with the statements in the proposed rules expressing a concern “about the lack of progress in reducing the rates of healthcare associated infections” and indicating that “more attention needs to be paid to ensure healthcare does not result in avoidable harm and that patients are informed about hospitals’ performance.”
A major component of the Action Plan referenced above must be to assess whether the Plan’s Metrics and Targets have been met and to reveal these results to the public in a meaningful way, i.e., at the hospital level. This proposed federal regulation to report central line bloodstream infections in ICU patients and surgical infections is a first step toward this accountability, but it does not go far enough. If HHS is serious about meeting these goals (which are quite conservative – see Comments), all of the targets should be included in the public reporting proposal, especially measures relating to MRSA, c.difficile and urinary tract infections. The Plan failed to set reduction goals for one of the most deadly infections among hospital patients – ventilator associated pneumonia. We urge you to work toward including these infections in your efforts to connect outcomes with the Medicare payment system. The first step toward this is to demand that CDC immediately develop a workable guideline for identifying hospital-acquired VAP infections. Further, it is time to move surveillance and reporting of central line associated bloodstream infections beyond the ICU; the Action Plan should be modified to do so.
As we have worked collectively in the states over the past six years on infection prevention, including public reporting, several trends have emerged. First, states required to devise a way to report infection rates have independently gravitated toward using the Centers for Disease Control and Prevention’s National Healthcare Safety Network (NHSN) as their data collector, essentially establishing a national standard for reporting. So, it is important that this current federal proposal builds on the work that has been done in the states by also using the NHSN for the IPPS system reporting. Second, because reporting is mandated by states’ laws, all hospitals in each state must participate in a standardized way. This has created a stronger, more robust and representative database for CDC to analyze the problems, develop prevention strategies and track progress. We also recommend the hospital infection information gathered through NHSN be publicly available so researchers and others can use the data to do further analyses and studies.
In addition to the hospital infection reporting, we generally support this proposed expansion of measures to be publicly reported and used to align payment with performance. Specifically:
We support including Medicare’s hospital-acquired conditions in the RHQDAPU payment and public reporting program using Medicare claims data.
Because we strongly support reporting of outcome measures rather than process measures, we agree with the proposal to retire process measures that have generally reached 100% compliance.
While the National Quality Forum plays an important role in endorsing measures for public reporting, we recommend not to rely only on this process to adopt measures. Reporting on hospital infections provides a good illustration of why other methods of moving measures forward should also be considered. By the time NQF endorsed the hospital-acquired infection measures included in this current proposal, many states had already passed laws to require such reporting and the CDC had issued a guidance to states recommending that public reporting include these measures. Consumers and patients have been the driving force behind public reporting of hospital-acquired infections, not NQF.
If you have any questions regarding these comments, please contact Lisa McGiffert, Consumers Union Safe Patient Project at 512-477-4431, ext. 115 or firstname.lastname@example.org
Consumers Union Safe Patient Project
Maryland Coalition for Patients Rights
Jerry Carswell Foundation
Alicia Cole, HAI Survivor
Alliance for Safety Awareness for Patients
Sherman Oaks, CA
Kathy Day RN,
McCleary MRSA Prevention
Author, The Treatment Trap and Wall of Silence
The Empowered Patient Coalition
San Francisco, CA
Julia Hallisy email@example.com
Holly S. Harris, M.S., CRC
CA Safe Patient Network
Mothers Against Medical Error
Health Watch USA
Roberta Mikles BA RN
(Hospital) Patient Safety Advocate
(Dialysis Facility) Patient Safety Advocate
Rancho Bernardo, San Diego, CA
Californians for Patients Rights
Carole and Ty Moss
Lori Nerbonne, RN
NH Patient Voices
Bow, NH 03304
Advocates in Action for Patient Safety
CA Safe Patient Network
Connecticut Center for Patient Safety
Suzan Shinazy, RN
Citizens for Patient Safety
Tom and DeeDee Vallier
Hood River, OR
Deborah W. Wachenheim
Health Quality Manager
Healthcare For All
Boston, MA 02108
Contact: David Butler or Kristina Edmunson – 202-462-6262; Michael McCauley – 415-431-6747