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MEMORANDUM TO: Senator Joseph Brannigan, Chair FROM: Mary Mayhew, Vice President DATE: January 23, 2008 RE: Testimony in Opposition to LD 1939 - Resolve to Establish a Method for Reporting the Statistics of Diseases
Before I elaborate on infection control practices in hospitals, I want to highlight the amount of data collection and analysis currently conducted through the Maine Quality Forum. The Maine Quality Forum already has broad authority to require data submission by hospitals on quality measures to compare and evaluate providers. For example, in 2006, a major substantive rule (Rule Chapter 270) was approved by the Legislature and adopted by the MHDO that included Healthcare Associated Infection Quality Data. This rule includes infection rates for central line catheter-associated blood stream infection rates for ICU and for high risk nursery patients. The rule also requires submission of health care associated infection quality metrics related to compliance with evidenced-based interventions proven to reduce infection rates. The MHA and organizations of infection control practitioners worked closely with the MQF on the development of this rule and continue to work together on additional infection control initiatives. MHA has also worked on these issues collaboratively with the MQF, payers, and employers. In 2007, the MHDO and the MQF submitted another major substantive rule on health care associated infections focused on surgical patients and evidenced-based interventions again proven to reduce the incidence of infections. These are all metrics identified by the National Quality Forum as it relates to hospital infection rates and more importantly on processes of care proven to reduce infection rates. Maine is currently ahead of CMS as it relates to mandatory reporting of these measures. This is an ongoing process at the state and national level with additional rates and evidenced-based interventions continually identified. It is important to emphasize that the process occurring both here in Maine and nationally is incredibly important as it relates to which rates and measures are reported and how they are to be reported given that this is intended for public release and public accountability. The Hospital Associated Infection and the Surgical Care Improvement Project metrics are also endorsed by the National Quality Forum. These metrics measure compliance with national standards for infection control that were publicized and supported by the Institute for Healthcare Improvement's 100,000 Lives Campaign and their 5 Million Lives Campaign. The Maine Hospital Association Board of Directors endorsed both the IHI National Campaigns. Informing all of these efforts at the national level and correspondingly at the state level is a group known as the Healthcare Infection Control Practices Advisory Committee (HICPAC). This is a federal advisory committee which provides advice and guidance to the U.S. CDC and the U.S. DHHS. In 2005 this federal advisory committee released a guidance report for states on public reporting systems for health care associated infections (HAIs). In their report they identified five process or outcome measures appropriate for state public reporting systems. Maine is already doing four of these. HICPAC will update their recommendations as more research and experience become available. Additionally in their report they make the following recommendations: the reporting system should collect and report health care data that are useful not only to the public, but also to the facility for its quality improvement; process measures as opposed to rates are desirable for inclusion in a public reporting system because the target adherence rate of 100% to these researched-based measures is unambiguous - and process measures do not require adjustment for the patient's underlying risk of infection as rates do; outcome measures should be chosen for reporting based on the frequency, severity and preventability of the outcomes and the likelihood that they can be detected and reported accurately-this is one of the biggest challenges in the identification of infection rates for public reporting purposes. I want to emphasize that the lead national agencies on infection control do not advocate for across the board reporting of all infection rates. Again while certain rates have been identified by the experts as important for public reporting, the emphasis has been on implementing critical processes that through research have been proven to reduce infections. So, publicly reporting on compliance with those processes provides valuable data for both the consumer and the providers. I wanted to share all of this about HICPAC because their work is critically important in advancing these efforts around the reduction of health care associated infections and the public reporting of this information. The MQF's work has been consistent with these national recommendations. Again, when we supported the initial creation of the MQF, we did so because we felt strongly about not only the need for this data at a statewide level but the opportunity to work in concert with national efforts and importantly to reduce multiple and different data submissions at the state and federal level. Given all of this, we believe the proposed resolve is unnecessary. Additionally, if the intent of the Resolve is to more aggressively require the submission of all infection rates or to utilize administrative claims data for the public reporting of hospital specific infection rates we would have grave concerns about moving in either direction. Again, we wholeheartedly support the work of the Maine Quality Forum and the thoughtful collaboration that is ongoing with all of the stakeholders and infectious disease experts throughout Maine. We would be opposed to a legislative directive that usurps that process. In terms of the use of administrative claims data to establish hospital-specific infection rates, we would like to register strong concerns about this approach. First, unless we test every patient upon admission, the claims data only indicates whether a patient had an infection not whether the patient already had the infection when they were admitted or whether the infection was acquired at the hospital. Publishing these rates would be inaccurate and incredibly misleading for the public. Again, the U.S. CDC and other advisory organizations do not recommend wholesale testing for all patients. Nor do they advocate for the collection of all rates. The various recommendations that have been made and continue to be made to advance efforts on infection control are intended to focus hospital efforts and resources in the most productive manner possible; i.e. implementation of processes intended to reduce infection rates for the most prevalent hospital infections. The use of administrative claims data (data that is submitted for billing purposes - not clinical data) would likely divert resources away from these critical clinical efforts and on patient testing and hospital claims coding. Hospital infection control efforts can be categorized as follows:
Each of these areas is multifaceted and includes research-based efforts
within hospitals to reduce infections. These efforts are also the product
of statewide collaborative efforts with infectious disease specialists
and the Maine Quality Forum and the Maine CDC. At the same time there
remains a commitment to fulfill the public's need for meaningful data.
We are proud of the partnerships we have with the state and other key
stakeholders in our efforts to reduce infections and we are supportive
of the ongoing efforts to collect research-based measures for meaningful
public reporting. For all of these reasons, we do not believe that LD
1939 is necessary. I appreciate the opportunity to present our concerns
to you. I would be happy to respond to any questions you may have. Shaping the Future of Health
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