Tell CDC HICPAC to Establish Rigorous and Highest Levels of Protection in Healthcare by Nov 13th
CDC’s health care infection control committee meet Nov 14-15, submit a public comment asking for robust, science-based infection control guidelines, universal masking, with broad use of N95s or better
The CDC’s Healthcare Infection Control Practices Advisory Committee (HICPAC) will meet November 14 and 15 to consider revised infection control guidelines for healthcare settings. Our community and advocacy groups have continuously pressured HICPAC to strengthen CDC’s infection control recommendations, instead of weakening them, which resulted in CDC returning the committee’s approved draft guidelines back to the committee with four key questions that still need to be addressed by the committee. Based on the agenda for this November meeting, HICPAC is expected to address the four questions from the CDC and present further updates on their draft infection control guidelines for patients and healthcare workers presented by its Isolation Precautions Guidelines Workgroup and Healthcare Personnel Guideline Workgroup.
In a win for our collective movement earlier this year, HICPAC now includes a representative from the NY State Nurses Association and the Isolation Precautions workgroup includes a representative of National Nurses United.
Using the suggestions/template below, we urge you to submit comments to HICPAC by this Wednesday, November 13, in order to allow the committee to receive them ahead of the meeting. Per HICPAC’s updated notice in the Federal Register, the final deadline for comments related to this meeting’s agenda is Nov. 22. We provide additional supporting rationale below the template.
By November 13, we ask you to write to HICPAC and press them to protect patients, healthcare workers, and the public, by adopting guidance calling for universal masking in healthcare, and clear, strong protective protocols. You can either email them directly at HICPAC@CDC.gov or submit your demands through their website, by scrolling down to “Contact HICPAC Committee Management.” If you submit a written comment to HICPAC, please forward your message by bcc to People’s CDC at info@peoplescdc.org and National Nurses United at healthandsafety@nationalnursesunited.org as NNU plans to create a public record of these materials.
We provide a template letter below. You may borrow or modify it for your own comment to HICPAC. Please personalize your comments. If you were selected for oral comment at the HICPAC meeting, you may also use the letter below for talking points in preparing your statement (CDC notified speakers on November 1). We also highly recommend National Nurses United’s talking points to strengthen healthcare infection control broadly. Learn more about the history of NNU’s impact on HICPAC and a recent article about the work.
How to use the letter to HICPAC, (which should be a maximum of 1 single-spaced page):
Either email them directly at HICPAC@CDC.gov or submit a comment via their website. Edit the letter as you wish (or write your own using the letter for inspiration or talking points). Submit your comments by Nov. 13 in order for the committee to receive them prior to the meeting, and the final deadline for comments related to this meeting is Nov. 22.
If you submit a written comment to HICPAC, please forward your message by bcc to info@peoplescdc.org and healthandsafety@nationalnursesunited.org; National Nurses United plans to create a public record of materials.
Please personalize your letter/comment, ideally starting with a brief statement on why you value the highest infection control standards in healthcare (including the importance of N95 or higher respirators), and how lack of universal masking in healthcare or lack of a layered mitigation approach has impacted your life or your community. For example:
Delayed or missed medical appointments
Unsafe healthcare experiences, such as with workers or other patients who showed symptoms of COVID or other aerosol-transmitted infectious diseases
Infections or potential exposures that occurred in healthcare settings
Challenges faced in asking healthcare workers to mask
Disproportionate impacts of the lack of masking in healthcare on high-risk patients and marginalized communities.
Letter template (Use Subject Title: Nov 2024 HICPAC Meeting)
Dear HICPAC Members,
HICPAC must ensure the highest standards of protection and not weaken infection control guidelines for healthcare workers and patients. HICPAC must prioritize patient and healthcare worker health over short-term healthcare profits. Healthcare should not make us sick.
I urge you to strengthen CDC infection control guidance in line with scientific evidence. HICPAC must establish universal masking in healthcare as a new standard of infection control across all settings for the following reasons:
Many healthcare exposures to aerosol-transmitted infectious diseases (including COVID, measles, influenza including avian influenza, and TB) are preventable through multiple mitigation measures including isolation procedures, universal masking, ventilation, and air purification.
Many aerosol-transmitted pathogens are transmissible without symptoms and without predictable seasonality. Diagnosis and isolation may be delayed, leading to exposures that could have been prevented by universal masking.
Well-fitting N95 or better respirators provide both protection for the wearer and source control. One-way masking offers limited protection; respirator masks should ideally be worn by all to reduce transmission. Hospitals should distribute N95 grade masks to visitors and staff, and also to patients for use when feasible.
Universal masking protects patients when they cannot mask (such as infants, people with specific medical conditions and during procedures involving the nose or mouth).
When masking is only on request, people are unprotected in many shared spaces such as lobbies and waiting rooms.
In addition to universal masking, HICPAC must recommend layered mitigations in all types of healthcare facilities: higher HVAC standards including air filtration and ventilation, clear and robust isolation protocols to separate infectious people from others – including by routinely testing staff and patients for COVID and other infectious diseases, isolating and cohorting infectious patients, and keeping staff with an active infection away from healthcare facilities and in-person patient contact.
Though legally obliged to accept public comment, the written comments submitted for the August 2024 meeting have not been made publicly available. HICPAC has also, as of November 9, not made publicly available any updated materials on the Isolation Precaution draft guidance that will be discussed at the November 14-15 meeting. Such materials made available well before the meeting would allow both written and oral commenters to be better prepared with comments relevant to the current work of the committee and working group. HICPAC must ensure a transparent process and allow sufficient time for the public to review any draft guidelines and provide comments after the upcoming November 2024 meeting, and time for HICPAC to consider those comments, before any vote on whether to approve the drafts.
End of Template Letter
Additional points you could make, in place of some points above, to help convey that CDC guidance for infection control in healthcare must be strengthened in multiple ways:
With documented avian influenza cases in humans continuing to rise, CDC must act vigorously to prevent its spread and the spread of other emerging pathogens in healthcare. CDC guidance on this – and in general – must follow the precautionary principle, promoting strong protective measures against potential risks, rather than waiting to react to outbreaks.
HICPAC recommendations for updated CDC guidance must fully recognize the science on aerosols and inhalation transmission of infectious diseases, including that distance alone is not sufficiently protective.
The science is clear: for healthcare workers, patients, and others, loose-fitting surgical masks are not sufficient to prevent transmission of infectious aerosols.
CDC guidance must establish clear obligations for employers to provide protections; CDC must not allow early pandemic crisis standards of personal protective equipment (PPE) use to become permanent. Allowing the “flexibility” for healthcare systems to provide inadequate PPE puts both patients and healthcare workers at risk for the benefit of healthcare system profits.
Many problems arise from a narrow composition of the committee and its workgroups and the failure to consult appropriate sources, experts, and representatives from affected communities. As National Nurses United recently urged the CDC, “expand the perspectives represented on HICPAC and its IPG Workgroup, including by adding direct care health care workers, patients, their families, unions, and experts in other fields such as respiratory protection, aerosol science, occupational health, and industrial hygiene.”
HICPAC’s current approach overlooks the public. Most similar committees solicit public comment through the federal government’s regulations.gov portal, which makes them publicly viewable, while HICPAC has instead asked the public to send comments either through their website or via email. Meanwhile, some organizations have received reports that individuals who submitted written comments did not see those comments included in HICPAC’s official records.
Additional rationale for strengthening CDC’s infection control guidance
For at least the last year and a half, public health advocates have been trying to stop HICPAC from weakening healthcare infection control guidelines and putting healthcare systems costs above worker and patient safety. Our path forward is clear: To protect patients and healthcare workers, we must speak up to demand effective, scientifically-supported standards in infection control for aerosol-transmitted infectious diseases in healthcare settings.
HICPAC’s current approach overlooks the scientific evidence in many ways that increase infection risks across multiple infectious diseases. CDC’s Isolation Precautions guidance must recognize that many infectious diseases, including COVID, pose year-round risks. Healthcare Personnel guidelines must recommend science-based isolation periods for healthcare workers infected with COVID as well as other infectious diseases that pose a risk to patients, coworkers, and the community.
Despite the demonstrated benefits of universal masking in healthcare settings in the ongoing COVID pandemic, HICPAC’s most recent public draft guidance has failed to integrate this lesson to prevent avoidable healthcare-acquired infections. In order to properly protect patients and healthcare workers from these preventable infections, HICPAC must recommend consistent use of N95 or higher quality respirators for aerosol-transmitted pathogens in its infection control guidance and protective isolation protocols. In addition to implementing universal masking and expanding the use of N95 respirators, CDC guidance must address the full range of measures to control aerosol infectious disease transmission broadly throughout all healthcare settings, including enhanced ventilation, air filtration, isolation, and routine testing.