Hospital flu shot rates entering the public realm

CMS reporting in 2013, public access in 2014

Your influenza vaccination campaign is coming into the public spotlight, and that means more pressure than ever on the logistics of administering and tracking those vaccinations.

Think of this first season of reporting as a test. The Centers for Medicare & Medicaid Services (CMS) will not publicly report the health care worker flu vaccination rates until 2014.

But as of January 1, CMS is requiring hospitals to report the vaccination rates of employees, licensed independent practitioners (non-employee physicians, advance practice nurses and physician assistants) and adult students, trainees and volunteers who are at least 18 years old. (The Joint Commission recommends tracking vaccinations among all contracted workers, but that is not being reported by CMS.)

For many hospitals, calculating the numerator is the easy part. You must count and report the number of individuals who received the vaccine, said they received it elsewhere, declined the vaccine, or who have a medical contraindication of either a severe egg allergy or a history of Guillain-Barre Syndrome within six weeks of a previous influenza vaccination. There is also a category for “unknown.”

However, the denominator is causing some headaches. CMS asks you to include all individuals (employees, licensed independent practitioners, etc.) who were in your hospital for at least 30 days between October 1 and March 31. The measure counts a “day” as any part of a day in your facility. (You cannot use data on fulltime equivalent employees.)

Some hospitals plan to count their non-employees in the most liberal way.

“Most places cannot determine how many days their non-employed physicians and other licensed independent providers actually spend in the facility,” says Melanie Swift, MD, FACOEM, director of the Vanderbilt Occupational Health Clinic in Nashville. “The safest course of action is probably to assume everyone with access and credentials to be in the facility are spending 30 or more days there.”

How to count on NHSN

Although for this first year the reporting begins on January 1, you can begin counting from October. The reporting occurs through the National Healthcare Safety Network (NHSN), a surveillance system maintained by the Centers for Disease Control and Prevention.

You can report monthly cumulative totals through NHSN, but CMS will receive the data only once — on May 13, 2013.

Some hospitals are struggling with the logistics of tracking non-employees. Harbor-UCLA Medical Center in Los Angeles can expect to report a high vaccination rate, no matter how it is counted. With a policy that requires those not receiving the flu vaccine to wear a mask during the flu season, Harbor-UCLA vaccinated 89% of employees last year and expects to reach 90% or above this year.

But gathering the data for the denominator will be a challenge, says Erika Sweet, RN, MSN, NP, with Harbor-UCLA Employee Health Services.

“Medical students may come in for two weeks rotation, they’re off for two weeks, then they come back for another two weeks. We have residents that do the same,” she says. They also have students cycling into the hospital from nursing schools and other programs. “The non-employee category is very difficult because nobody except their instructor knows exactly what time period they’re going to be here during any specific rotation.”

Some employee health professionals plan to count employees and non-employees who have spent even a day in the hospital, despite the 30-day instruction. Bruce Cunha, RN, MS, COHN-S, manager of employee health and safety at the Marshfield (WI) Clinic, notes that hospitals have various types of providers who rotate through or who work in temporary positions. “The best they’re going to get out of this is some kind of general ballpark figure,” he says.

And some employee health professionals wonder why they shouldn’t count people who worked fewer than 30 days during the flu season. “Should it matter how many days they’re in your hospital if they’re not vaccinated? Aren’t they just as much of a risk on any one day they’re there?” says Cunha.

Measure may be tweaked

Comments from employee health professionals actually might prompt some minor changes in the measure for future reporting.

“We realize that facilities may have feedback on some issues and difficulties they encounter in meeting the reporting guidelines during this first year of reporting,” says Megan Lindley, MPH, epidemiologist with the CDC’s National Center for Immunization & Respiratory Diseases in an email to HEH. “We will take all of the input that is offered and will reevaluate the specifics of the protocol and measure after this first reporting period to see if there are changes we can make in order to improve the reporting experience for users and the accuracy and reliability of the data.”

Some concessions have already been made to make it easier for facilities to comply. For example, employees and non-employees can report in writing (online or on paper) that they have received the flu vaccine outside the facility. They are not required to produce documentation.

Swift called that “the saving grace of the CMS measure ... so an electronic survey sent to all licensed independent practitioners is a viable way to ascertain their vaccination status.”

[Editor’s note: More information about the influenza immunization reporting criteria is available at