Chapter Legislative Representative Update

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• Chapter Legislative Representative Update

Lisa Tomlinson Sr. Director of Gov.
AffairsNancy HailpernAsst. Director of Gov.
Affairs Benjamin RogersGov. Affairs
Associate December 16, 2011
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• Federal Regulations Final

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• Accountable Care Organizations (ACOs) Final
  Rule
• Proposed rule areas of APIC concern
• 65 quality measures considered too burdensome
  for 1st year participation
• Measure 24 Health Care Acquired Conditions
  composite included 17 infection and
  non-infection related measures
• Final rule
• Did not include composite measure
• Number of quality measures reduced to 33

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• CY 2012 Outpatient Prospect Payment System (OPPS)
  and ASC Payment System Final Rule
• Hospital Outpatient
• SSI reporting through NHSN not included
• HCP influenza vaccination reporting
• Delayed pending NQF endorsement of updated NHSN
  HCP module
• Will address in future rule for CY 2016 payment
• ASCs
• SSI reporting through NHSN not included
• HCP vaccination reporting
• Data collection 1st year 10/1/2014 through
  3/31/2015 for CY 2016 payment. Future year
  reporting to follow flu season

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• FY 2012 ESRD Prospect Payment System Final Rule
• Vascular access infection reporting
• Measure not finalized
• NHSN dialysis event reporting
• Reporting to begin with payment year (PY) 2014.
• For the first year, this measure requires
  facilities to
• Submit three or more consecutive months of CY
  2012 dialysis event data to NHSN
• Data must be submitted to NHSN by March 31, 2013
  for PY 2014 payment determination

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• Hospital Value-Based Purchasing UPDATED Final
  Rule
• Quality measure added for FY 2014
• SCIP-Inf-9 Postoperative urinary catheter
  removal on postoperative day 1 or 2
• Quality measure removed for FY 2014
• Composite of 8 hospital-acquired conditions
  (including CAUTI and vascular catheter-associated
  infection)
• APIC supported both updates

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• Federal Regulations Proposed

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CMS Updates to Medicare/Medicaid Conditions of
Participation

• Long-Term Care and Medicare Advantage comments
  submitted 12/9/11
• APIC opposes extending the Medicare HAC policy to
  Medicare Advantage organizations
• Hospital and Critical Access Hospital comments
  to be submitted 12/19/11
• APIC supports
• Expansion of standing orders for immunization
• Elimination of requirement for infection control
  log
• Updating regulations to require compliance with
  LSC 2012

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• CMS Regulatory Efficiency, Transparency
• and Burden Reduction
• APIC Comments to be submitted 12/19/11
• APIC supports CMS review of existing regulations
  to identify and remove those that are
  unnecessary, obsolete, or excessively burdensome
• APIC supports proposal to remove one of two
  regulations requiring ASC infection control
  programs because of redundancy

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• Overview of HAI
• Reporting Requirements

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Overview of Reporting by Facility Type

• General acute care hospitals/inpatient
• January 2011
• CLABSI in ICUs
• January 2012
• CAUTI
• SSIs for colon surgeries and abdominal
  hysterectomies
• January 2013
• MRSA bacteremia
• C. difficile lab ID events
• HCP influenza vaccination

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Overview of Reporting by Facility Type (cont)

• Long-term acute care hospitals
• October 2012
• CAUTI
• CLABSI
• Ambulatory surgical centers
• October 2014 HCP influenza vaccination
• Hospital outpatient facilities
• Date TBD HCP influenza vaccination

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Overview of Reporting by Facility Type (cont)

• Inpatient rehabilitation facilities
• October 2012 CAUTI
• End-stage renal disease facilities
• By March 2013 NHSN dialysis events 3
  consecutive months of 2012 data

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• Other Agency Issues

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Possible Occupational Safety and Health
Administration (OSHA) Infectious Disease Standard

• Agency still reviewing data received as a result
  of their request for information (RFI) and public
  stakeholder meetings
• APIC response to the August 2010 RFI

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Contact Time for Surface Disinfectants

• APIC has raised this issue with federal agencies
  as a major concern of our membership
• Agencies working toward an interagency solution
  to this issue Environmental Protection Agency
  (EPA), Centers for Medicare and Medicaid Services
  (CMS), Centers for Disease Control and Prevention
  (CDC), Food and Drug Administration (FDA)

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• Enacted State Laws

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• Trends
• Greater efforts to align with CMS requirements
• Continued transparency for patients
• Continued effort to add to the types of
  facilities with HAI reporting requirements (pain
  managements facilities, skilled nursing
  facilities)
• Continued organism-specific reporting
• Requirement for increased expertise or planning
  around infection prevention in a wider range of
  facilities

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Greater Transparency

• Nevada (SB 209 Chapter 186)
• State must report HAI hospital and ASC data on
  public website in a manner that allows consumers
  to compare facilities
• HAI data is based on what facilities report to
  NHSN
• State health division to determine what is to be
  reported by facilities

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Greater TransparencyNon-Hospital Settings

• Nevada (SB 338 Chapter 366)
• State to place yearly report of HAI data on
  public website, allowing comparisons of SNFs
• Skilled nursing facilities to report HAIs to
  NHSN, with data available to state health
  division
• State health division to determine type of
  infections to be reported
• Maine Hospitals to report MRSA and C. Diff. data
  to NHSN (LD 1212 Chapter 316)

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Infection Prevention Requirements Hospital
Non-Hospital Settings

• Nevada (SB 339 Chapter 279)
• Hospitals and ASCs must introduce infection
  control program and assign infection control
  officer
• Nevada (SB 419 Chapter 362)
• Healthcare workers to be in compliance with safe
  injection practices
• Applies to physicians, physician assistants,
  professional nurses, practical nurses

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Government Affairs Features

• A Whats New section for quick access to recent
  public policy actions
• Revised and reorganized public policy resources
  page that includes subheadings to make it easier
  to find content
• Easier access to position statements

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Questions?