The Healthy Hospitals Act of 2007: A Good Start, but Not Enough

One piece of infection control legislation moving (slowly) through Congress is the Healthy Hospitals Act, H.R. 1174 (it's so slow that it's, erm, an act of 2007). H.R. 1174 would amend "the Social Security Act to require public reporting of health care-associated infections data by hospitals and ambulatory surgical centers and to permit the Secretary of Health and Human Services to establish a pilot program to provide incentives to hospitals and ambulatory surgical centers to eliminate the rate of occurrence of such infections."

There are many good provisions in this legislation:

  1. Hospitals will be required to report within 45 days of a calendar quarter the rates of infection as well as relevant risk factors (e.g., age, immunological status, hospital ward) to the Secretary of Health and Human Services.
  2. These data have to be posted on the HHS website.
  3. Annually, HHS has to present these data, along with what measures hospitals are taken to reduce these infections, to Congress.
  4. HHS must assess the economic cost of these infections. This is critical because once people realize just how these infections cost annually (around $50 billion--you used to be able to invade a country for that kind of money), there will be additional support for infection control.
  5. Every failure to report results in a $10,000 fine. This bill has teeth.
  6. The minimal list of infections is quite comprehensive, and includes "surgical site infections, ventilator associated pneumonia, central line related (IV) blood infections, urinary tract infections, methicillin-resistant Staphylococcus aureus (MRSA) infections, clostridium difficile [sic] infections, and any additional infections specified by the Secretary."

This is pretty good legislation. There are two problems with it, however. The first has to do with the funding. Initially, there is to be a pilot program whose cost is to be no more than "this section the aggregate financial incentives provided under the program for reduction in infections in a period shall not exceed 10 percent of the amount (estimated by the Secretary) by which Federal expenditures under title XVIII of the Social Security Act are reduced in such period as a result of such reduction in infections." I haven't quite figured out what that means (is it to apply only to those hospitals involved with the pilot?). Public health has a long, inglorious history of under-funded pilot programs that collapse from inadequate resources.

The second problem is that, on the epidemiological side, more extensive data collection is required. As best as I can tell, HHS will only be collecting aggregate data. In other words, we will know for each hospital the frequency of infections, as well as the associated 'metadata', such as patient characteristics. However, these data will not be linked.

The technology to tie an individual microbiological specimen to patient data in an electronic reporting system and outcomes (including economic cost) exists and is utterly feasible*. The only reason former colleagues and I could not get such a project off the ground is that we could not acquire funding and institutional support. This would not improve the quality of reporting, but we would be able to track every infection. But most importantly, we would be able to apply powerful statistical tools to untangle the various factors involved in sickness, mortality, and economic cost--including antibiotic resistance.

Having said that, this would legislation would be a vast improvement other what we have now, which is virtually nothing. Contact your representative and ask them to support this legislation, although if you think you're up to it, suggesting my two additions (funding and isolate-based reporting) would help improve this legislation. (It wouldn't to contact your Senator either, even though this is currently only House legislation).

*We even had HIPAA and IRB legal boilerplate, as well as privacy protections.

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Metrics are good but good interpretation of metrics is better. My worry is that with hospitals they will say more infections = bad! The reality is more complex with referral centers and more advanced academic medical centers taking on more complex cases and more difficult patients, thus their rates of iatrogenic or hospital-acquired infections tend to be higher. This is despite the fact that they are the best-trained, best-qualified docs in the country.

So, hopefully we'll get the data, and hopefully they'll make sure the evaluate hospitals and clinics based on peer groupings. Otherwise private hospitals that dump all their complications on referral centers and private clinics that have the ability to select their patient populations will look excessively good. And university medical centers, state-run medical centers and other major referral centers will look bad because they have to take everybody, they get the most difficult cases, and they get the screwups and complications from private hospitals.

Mark H,

I agree, and that's why we need an isolate-based surveillance system: so we can control for demographic parameters.

So, hopefully we'll get the data, and hopefully they'll make sure the evaluate hospitals and clinics based on peer groupings. Otherwise private hospitals that dump all their complications on referral centers and private clinics that have the ability to select their patient populations will look excessively good