Infection control targeted in proposed Medicare rule

APIC supports rule for federal reimbursement

Infection control must be "an integral part" of quality improvement efforts to maintain participation in Medicare and Medicaid programs, according to a proposed rule by the Health Care Financing Administration (HCFA) in Baltimore.1

However, to allow local flexibility and emphasize patient outcomes over departmental processes, HCFA is dropping a previous requirement that a log be kept recording incidents related to infections and communicable diseases.

"In keeping with the outcome-oriented approach of this rule, we propose that the hospital must have a method of identifying problems in its infection control program and take appropriate actions that result in improvement," the proposed HCFA rule states. "Although use of a log may be one method to identify problems, we do not intend to prescribe how a hospital should identify problems."

HCFA is proposing to maintain infection control as a separate condition of participation (COP) because it is vital for protecting patient health and safety, the rule states.

"We propose to retain most of the standards under the current COP, but we would strengthen its focus by requiring hospitals to take appropriate actions that result in improvement when problems are identified in their infection control programs," HCFA states in the rule. "This is in concert with the proposed quality assessment and performance improvement COP, of which infection control must be an integral part."

Specific standards not required

The infection control rule was published in the Dec. 19, 1997, Federal Register. The Association for Professionals in Infection Control and Epidem-iology (APIC) supports the infection control aspects of the proposed rule and the emphasis on patient outcomes, according to the APIC governmental affairs office in Washington, DC.

The HCFA emphasis on outcomes and interventions is much in keeping with the infection control approach recommended by the Joint Commission on Accreditation of Healthcare Organizations. HCFA cites the Joint Commission as a resource, along with APIC, the Centers for Disease Control and Prevention (CDC), the Occupational Safety and Health Administration (OSHA), and the American Hospital Association (AHA).

"We considered requiring hospitals to meet CDC and OSHA standards for providing an environment to avoid sources of infections and communicable disease," HCFA states. "However, such a requirement would raise questions as to which CDC or OSHA standards must be met. Moreover, where alternative sets of professionally recognized standards exist, we do not wish to restrict hospital flexibility by mandating compliance with a particular body of standards. Therefore, we are not mandating that hospitals follow any specific set of infection control guidelines; however, such guidelines are published by several organizations and are available as resources on infection control practices." Guidelines are available from the following:

• the Centers for Disease Control and Prevention in Atlanta;

• the Association for Professionals in Infection Control and Epidemiology in Washington, DC;

• the American Hospital Association in Chicago;

• the Joint Commission on Accreditation of Healthcare Organizations in Oakbrook Terrace, IL.

In general, HCFA strongly endorses the importance of infection control in the proposed standard, additional highlights of which are summarized as follows:

• Nosocomial infections subject patients to significant additional pain and risk, prolong hospital stays, and lead to significant additional costs in health care spending.

• The proposed infection control COP places accountability on hospitals to prevent, control, and investigate infections and communicable diseases and take actions that result in improvements.

• The proposed COP allows flexibility for hospitals to determine how to meet these objectives. This includes the flexibility to determine how much training in infection control is necessary for the hospital’s personnel.

• HCFA also considered including specific requirements concerning employee health status issues. However, the agency decided the hospital’s obligation to protect patients from employees with communicable diseases is covered in the proposed language that states that the hospital maintains an effective infection control program that protects patients and hospital staff by preventing and controlling infections and communicable diseases.


1. Department of Health and Human Services. Health Care Financing Administration. Medicare and Medicaid programs; hospital condition of participation; provider agreements and supplier approval: Proposed rule. 62 Fed Reg 66,726-66,760 (Dec. 19, 1997).