APIC cites a few caveats, concerns about HAI targets
Comments to HHS on proposed HAI Plan
While expressing overall support with proposed federal reduction targets for health care associated infections, the Association for Professionals in Infection Control and Epidemiology (APIC) raised several concerns in comments to the Department of Health and Human Services (HHS). The HHS has proposed a new set targets for infection reduction in acute care hospitals for 2020.
"Our comments primarily reflect the views of our members who rely on sound targets and measures as they take steps to prevent HAIs in the populations they serve," APIC stated. "In general we support the proposed acute care targets for 2020; however we bring the following comments and concerns to your attention."
Again, the following HHS targets and HAI reductions are all proposed to be achieved by 2020.
HHS: Reduce central line-associated bloodstream infections (CLABSI) in intensive care units and ward-located patients by 50% from 2015 baseline. Data Source: Centers for Disease Control and Prevention (CDC)/National Healthcare Safety Network (NHSN)
APIC: We support this target; however, we suggest that the target not only reflect aggregate data, but that interim assessments of the rate also be stratified by ICUs and non-ICUs. This methodology will help to better understand the areas needed for improvement and is also currently proposed for the CAUTI metric. We applaud the CDC for their efforts in working with oncologists, infection preventionists, and hospital epidemiologists to develop and evaluate a Mucosal Barrier Injury (MBI) bloodstream infection definition and for excluding MBI from the target. However, because this is a new designation, it is difficult to predict how using the new definition and excluding those cases will impact the 2015 baseline.
HHS: Reduce catheter-associated urinary tract infections (CAUTIs) in intensive care units and ward-located patients by 25% from 2015 baseline. Data Source: CDC/NHSN.
APIC: We support this target, but with reservations. We are concerned about the existing NHSN definition and the influence of the fever criteria. Further, we believe flaws in the definition may impede accurate measurement. We urge the development and testing of an electronic definition incorporating data that most facilities would have electronically available.
HHS: Reduce the incidence of invasive health care-associated methicillinresistant Staphylococcus aureus (MRSA) infections by 75% from 2007-2008 baseline (Healthy People 2020 Goal). Data Source: CDC’s Emerging Infections Program Network (EIP) Active Bacterial Core Surveillance (ABCs).
APIC: We generally support this target, and note its inclusion as a Healthy People 2020 goal. However, we want to point out that it is particularly aggressive given the prevalence of the community-onset MRSA strain in the general population. We believe that, in order to assist with achieving this target HHS should more widely disseminate information such as lessons learned from the CDC’s EIP/ABC network.
HHS: Reduce facility-onset methicillin-resistant MRSA in facility-wide health care by 50% reduction from 2015 baseline. Data Source: CDC/NHSN.
APIC: We support this target, but recommend that the title indicate that it only includes bloodstream infection and is a proxy measure for infection, using lab identification.
HHS: Reduce facility-onset Clostridium difficile infections in facility-wide health care by 30% from 2015 baseline Data Source: CDC/NHSN.
APIC: We support this target, but recommend that the title indicate that it is a proxy measure for infection.
HHS: Reduce the rate of C. diff hospitalizations by 30% from 2015 baseline. Data Source: Agency for Healthcare Research and Quality (AHRQ) Healthcare Cost and Utilization Project (HCUP).
APIC: We appreciate the value of understanding both hospital-onset and community-onset C. diff infection (CDI). However, since community-onset C. diff is, by definition, not an HAI, we believe that including both hospital-onset and community-onset C. diff as a measure in a plan intended to eliminate healthcare-associated infection is misleading. We also believe that consumers would be better served by the use of more precise data to identify HAIs.
HHS: Reduce Surgical Site Infection (SSI) admission and readmission by 30% from 2015 baseline. Data Source: CDC/NHSN.
APIC: We support this target and encourage CDC to continue with efforts to more adequately adjust for risk in certain specialty populations such as pediatrics where current risk adjustment criteria are primarily adult focused
