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Moore testifies in support of regulations to require hospitals to publicly report their rates of Hospital Acquired Infections
December 12, 2007 ... Yesterday, Sen. Richard T. Moore, D-Uxbridge, delivered testimony before the Massachusetts Department of Public Health on proposed regulations to require hospitals to publicly report their rates of hospital acquired infections. "Hospital Acquired Infections (HAIs) cost the Commonwealth hundreds of millions of dollars in unnecessary medical expenses and exact an immeasurable human toll. Yet the real tragedy is that these infections are largely preventable," Moore said. "These regulations are an important first step in reducing these unnecessary infections and improving the quality of health care in Massachusetts." The text of Sen. Moore's testimony: Senator Richard T. Moore December 11, 2007 Commissioner Auerbach, members of the Public Health Council, I am here to testify on the Massachusetts Department of Public Health’s proposed regulations requiring hospitals to report certain hospital acquired infections (HAIs). I do not regularly appear before an administrative agency to comment on proposed regulations, however, I do so to emphasize the Legislature's strong interest in this matter and to underscore how important this effort is to improving health care quality and containing health care costs that are essential to health care reform. These regulations are a good first step in preventing HAIs. They will give patients some of the information they need to make informed decisions about their health care and, in so doing, will encourage hospitals to prevent HAIs in their establishments. However, they are but a first step in preventing HAIs and in enhancing the quality of our health care system. They do not negate the need for legislation making this reporting permanent nor should they comprise the extent of our HAI prevention strategy. Massachusetts needs a comprehensive approach to preventing HAIs and improving health care quality. This must include transparency in the rate of HAIs and other quality measures as well as incentives for good, efficient care, and an emphasis on the prevention of disease. THE COSTS OF HAIs The human toll of Medical Errors and HAIs is undeniable. • Nationally, the Centers for Disease Control estimates that annually over 2 million patients develop an HAI or suffer from a preventable medical error during their hospital stay. Of these, over 100,000 die. Financially, HAI and medical errors not only cost government and private health insurers billions of dollars, but also impact hospitals and other health care providers’ bottom lines. • In Massachusetts, the Department of Public Health estimates that HAI cost the state as much as $200 million per year. • The Institute of Medicine estimates the national cost of medical errors and HAIs is more than $30 billion a year. Though the payers of health care bills currently shoulder the majority of these costs, hospitals are not immune from them. • A December 2006 study in the American Journal of Medical Quality found that central line associated blood infections cost a Pennsylvania hospital over $26,000 per infection and a total loss from operations of $1,449,306 in the 54 cases studied. • Recent studies have shown that Massachusetts’s world renowned health care system has a higher patient mortality rate than other health care systems in our country, something that threatens our vaunted position as the Nation’s health care leader. While HAIs are not solely responsible for this rate, they certainly contribute to it. THE TIME TO ACT IS NOW With this growing body of medical and financial data surrounding medical errors and HAIs and Massachusetts commitment to offer affordable health insurance to all of its residents, we must act now. Reducing or eliminating preventable medical errors is possible and a key to controlling the cost and improving the quality of health care in Massachusetts. The Department of Public Health’s proposed regulations for the reporting of HAIs call for an incremental, measured and fair rollout of an HAI reporting system using an existing federal database. They are recommendations that, if implemented, regardless of legislation, will be solid steps toward creating a safer, more transparent health care system in Massachusetts. However, I would like to make a few recommendations that will strengthen these regulations and reinforce the Commonwealth’s attempts to prevent hospital acquired infections. 1. Clearly indicate the regulations’ desires to prevent HAIs. These regulations will require hospitals to report both the steps they take to prevent HAIs and their actual rates of HAIs. This is part of our strategy to prevent HAIs and the regulation’s title should reflect this by emphasizing the Commonwealth’s desire to prevent HAIs. 2. Ensure that reporting system works in cooperation with the Quality and Cost Council. Chapter 58 of the Acts of 2006 established the Quality and Cost Council (QCC) to “promote high-quality, safe, effective, timely, efficient, equitable and patient-centered health care”. As part of this requirement, the QCC must establish a consumer health information website. The Department must ensure that these regulations support the QCC’s mandate in Ch 58. It must ensure that the regulations require the transmittal of the HAI data to the QCC and allow the QCC to use this data in creating its centralized health care consumer website. 3. Ensure that Hospitals are held accountable for accurately reporting their HAIs. The regulations do not spell out an auditing process to ensure that hospitals are accurately reporting their HAIs. The department must be clear that it expects a certain standard of reporting and have a clear process for enforcing these standards. This auditing process should also indicate whether hospitals are using a "best practice" adapted from nationally accepted standards of care (CDC, HICPAC, APIC, SHEA and the American Thoraic Society), and if not, why not. 4. Periodically update the reporting requirements to reflect new infections of significance and new developments in infection reporting methods. The outcome measures the Department is proposing to initially release to the public represent a good first step in bringing more transparency to our health care system and giving consumers the information they need to make informed health care decisions. However, these should not be static requirements. Periodically, new infections will surface, such as our current battle with MRSA, that pose a significant threat to the public and new techniques for reporting infections will be developed. The Department should establish procedures for reconsidering and amending any reporting guidelines to incorporate new infections and reporting techniques. Finally, these regulations do not negate the need for strong infection reporting legislation. Though I am very pleased with the work of Commissioner Auerbach and his staff at DPH and that of the Quality and Cost Council, codifying a reporting program in statute will protect these regulations from a potential future less forward thinking administration. Again, I commend the Commissioner and his staff on their progressive proposal. I look forward to working with the Department during its implementation of these regulations and on legislation to codify them in statute.
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