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Gary Evans writes Hospital Infection Control & Prevention (HIC), Hospital Employee Health (HEH) and contributes to IRB Advisor (IRB). As senior writer at AHC, Evans has written numerous articles on infectious disease threats to both patients and health care workers, including pandemic influenza, MERS and Ebola. He has been honored for excellence in analytical reporting five times by the National Press Club in Washington, DC.
Two leading federal agencies are warning hospitals and other facilities that they can be fined, denied Medicare funds or civilly prosecuted if they are caught intentionally underreporting healthcare associated infections (HAIs).
As Centers for Medicare & Medicaid pay-for-performance penalties and incentives target infection control, there are “anecdotal reports” of hospitals attempting to skirt the rules and not report all HAIs to the Centers for Disease Control Prevention. In response, the CDC and CMS issued a joint statement today Oct. 7 reminding all participating facilities that it is critical to report all HAIs to the CDC’s National Healthcare Safety Network (NHSN). The gold standard surveillance system has expanded in recent years as the CMS began linking infection rates to reimbursement. Many had predicted that pay for performance would inevitably lead to such a situation, as fiscally strapped hospitals may succumb to the temptation of under-reporting.
“CDC has received reports from NHSN users indicating that in some healthcare facilities, some of the decisions about what infections should be reported to NHSN are made by individuals who may choose to disregard CDC’s protocol, definitions, and criteria or who are not thoroughly familiar with the NHSN specifications,” the statement read. “While there is no evidence of a widespread problem, CDC and CMS take any deviation from NHSN protocols seriously.”
In some cases, the decisions may be made through a review process that “overrules the decision of an infection preventionist or hospital epidemiologist” to report an infection to NHSN, the CDC and CMS reported. Other issues of concern are reports that some facilities are ordering diagnostic tests in absence of clinical symptoms.
“It has been reported that in some instances, when patients are admitted to a hospital, diagnostic microbiology tests are ordered even in the absence of clinical indications for testing, such as obtaining urine specimens for culture and sensitivity testing from patients who have no symptoms of a urinary tract infection,” the agencies stated. “Many negative culture results are generated by this practice subjecting the patient to potentially unnecessary tests. On the occasion that a culture result is positive, the results are then used to assert that infections that first manifested themselves clinically many days later during hospitalization were present on admission and hence not reportable to NHSN.”
Again, there were clear warnings by IPs and other clinicians that these types of strategies may be adopted as the CMS declined full reimbursement for certain hospital acquired conditions that could be perceived as preventable. However, few probably anticipated the most serious allegation -- reports that some facilities are “discouraging the ordering of diagnostic tests in the presence of clinical symptoms. It has been reported that in some instances clinicians responsible for inpatient care in some hospitals may be discouraged from ordering diagnostic microbiology tests recommended by best medical practices (or standards of care) to avoid test results that would make infections reportable to NHSN,” the CDC and CMS reported.
If true, that could be tantamount to denying treatment in the name of the bottomline, a practice that crosses ethical and possibly legal lines. Thus the agencies warned of serious consequences and called out for whistleblowers to call a tip line.
“CMS reminds hospitals that intentionally reporting incorrect data, or deliberately failing to report data that are required to be reported, may violate applicable Medicare laws and regulations," the joint statement read. “The Department of Health and Human Services’ Office of Inspector General (OIG) protects the integrity of HHS programs, including Medicare and Medicaid. The Inspector General has the authority to exclude individuals and entities from participation in the Medicare, Medicaid, and other Federal healthcare programs and to impose Civil Monetary Penalties for certain misconduct related to Federal healthcare care programs. Hospital staff who become aware of intentional deviations from NHSN reporting protocols are encouraged to report their concerns to the OIG hotline.”
OIG reporting can be done via any of the following:
Phone: 1-800-HHS-TIPS (1-800-447-8477)
Contacts: For questions about the content of the notice, contact: CDC Division of Healthcare Quality Promotion Policy Office Phone: 404-639-4000 E-mail: DHQP_Policy@cdc.gov