Tell CMS (Medicare/Medicaid) to protect us from COVID by June 10

Hospitals Must Report COVID Infections and Protect Patients from Hospital Acquired COVID Infections

Jun 06, 2024

We have until June 10, 2024, 11:59 pm EDT, to tell the Centers for Medicare and Medicaid (CMS) that hospitals must report COVID infections and they should give us care, not COVID. Join us in submitting public comments to CMS.

CMS is one of the primary funders of US hospitals. 94% of hospitals have at least half of their admissions paid for by Medicare or Medicaid. The CDC recently stopped mandating that healthcare systems report COVID hospitalizations. Since the end of the public health emergency in May 2023, COVID hospitalizations have remained one of the few remaining data indicators. Without this information, the public health and general community will not understand the severity of COVID infections in the US. To address this, CMS has proposed mandatory reporting of COVID infections among hospitalizations beginning October 1, 2024. They need to hear overwhelming public support for this measure.

SEE OUR GUIDE BELOW ⬇️ for submitting a public comment, with a sample template to help make your voice heard on this vital patient safety issue. Please submit your comment directly on the Federal Register.

In your comment, we recommend telling CMS to allocate financial resources to create capacity for collecting and reporting COVID infections among hospitalized patients. While we remain concerned with the gap in the current reporting period between now and October 1, this is a necessary proposed change to our public health system. We also are advocating for data reporting on demographic, socioeconomic, and disability status to better understand differences in population outcomes.

Further, we continue to urge CMS to adopt an approach that deters healthcare-acquired COVID infections. Currently, CMS penalizes hospitals that fail to keep patients safe from other hospital-acquired infections through the Hospital Acquired Condition Reduction (HAC) program. But COVID is not on the list of infections that CMS tries to get hospitals to prevent, unlike, for example, surgical site infections and MRSA blood infections. Hospital-acquired COVID-19 has a mortality rate of 5 to 10% — between a 1-in-10 and 1-in-20 chance of dying if you catch COVID in the hospital! Healthcare systems and other healthcare settings can and should prevent COVID. Join us in also telling CMS to add COVID to the list of infections in the Hospital Acquired Condition Reduction (HAC) program.

When the CDC stopped requiring hospitals to maintain crucial COVID-infection control measures like COVID testing upon hospital admission and before elective procedures, we saw hospital outbreaks as a result. Without COVID-19 infection control, hospitals have become high-risk zones for COVID transmission, where people getting care for COVID-19 are very likely to encounter vulnerable patients who could be harmed by COVID. You have nearly a 40% chance of catching COVID-19 if your hospital roommate has it. Who wants to go to the hospital for a heart attack, giving birth, or routine surgery and end up catching COVID? It is especially concerning that hospitals are incentivized to ignore positive COVID cases—which would reduce income from carrying out elective procedures—especially during a “crushing” financial crisis. CMS thus must make the hospitals put patient safety first.

Preventing hospital-acquired COVID is an equity issue. CMS says they want to hear from multiple stakeholders and they are concerned about equity.

Over the course of the pandemic, we have seen marginalized communities. like low-income communities, disabled people, and people of color continue to be disproportionately harmed. These harms continue to persist and are further compounded by the fact that these groups are less likely to have access to boosters and treatment.”

Together we can urge CMS to mandate reporting of COVID infections and protect us while making our hospitals safer!

SUBMIT YOUR COMMENT

How to Comment:

Unique comments in your own words have the greatest impact and are counted with more weight.
Select “Healthcare industry” in the “What is your comment about?” dropdown menu.
Begin your letter with something personal, stating a fact that informs your interest such as: “I am concerned about this issue because I have lost family members to COVID” or “I am at high risk for severe illness,” or “I am concerned about Long COVID.”
If you have a health condition or disability and you feel comfortable sharing, or if you’re a health worker or public health researcher, mention those.
Feel free to use and include our sample letter text, references, edited, in part or full, with your public comment, as you see fit.
If you prefer you can upload your comment as a PDF.
If you have the time and energy, please, upload any supporting references as PDFs. They are required to read every document uploaded! Here are a few suggestions.

Below is a sample template letter you can copy-paste all or in parts for your public comment (but please customize for achieving higher impact).

SUBMIT YOUR COMMENT

Sample template letter:

(The hyperlinks below will not transfer to the plain-text box. If you prefer to upload a fully cited version, please save everything below as a PDF and submit as an attachment).

To the Leadership of the Centers for Medicare and Medicaid:

To reduce the spread of COVID inside healthcare settings, the Centers for Medicare and Medicaid (CMS) must 1) mandate hospitals report COVID infections and 2) include healthcare-acquired COVID infections as part of the Hospital Acquired Condition Reduction Program, CMS-1808-P.

The following proposals and changes should be implemented:

Hospitals must separately report total COVID, Flu, and RSV infections in healthcare settings on a weekly basis as part of this proposal as part of routine reporting of “respiratory illnesses.” Financial support should be provided to healthcare systems to ensure robust reporting capability. I support the reporting of demographics including additional characteristics such as socioeconomics and disability data. These data should be reported separately by facility name and aggregated at the state level with public access through HealthData.gov.

CMS must include COVID in its Hospital-Acquired Condition (HAC) HAC Reduction Program and/or its Value-Based Purchasing Program, to create financial incentives for COVID prevention in inpatient care. CMS should require hospitals to report and decrease hospital-onset COVID, using layered protections, such as universal mask wearing, universal screening testing, and improved air quality to promote patient and staff safety and health equity.

Hospitals should be required to report all hospital-onset COVID cases to CMS and the CDC. These data should be made available through HealthData.gov.

Hospital-onset COVID should be defined as infections diagnosed after 5+ days of admission. The CDC currently defines hospital-onset COVID as only those cases diagnosed in people who are still in the hospital after 14 days of hospitalization. This vastly underestimates hospital-acquired COVID, as current variants of COVID only take 2-3 days from exposure to developing symptoms.^1,2 Since the average hospital stay is 5.4 days,³ the current criteria of 14-day hospitalization miscount most people.

Additional Information and References for the Comment Letter:

During the first three months of 2023, US hospitals reported an average of 1231 patients per week that had caught COVID during their stay, with a high of 2287 patients with hospital-acquired COVID in the first week of January 2023 (using the current CDC 14-day definition).⁴ The UK has documented even higher rates,⁵ but the UK defines hospital-onset COVID as cases diagnosed after 7 days of hospitalization. The Biden administration never released data showing how prevalent COVID spread has been inside individual hospitals,⁶ and the CDC stopped requiring hospitals to report hospital-onset COVID in April 2023.⁷

COVID remains a major cause of death in the US since 2020,^8,9 and many of those deaths were likely due to hospital-acquired COVID, which has a 5-10% mortality rate. ^10,11 This is significantly higher than several of the other infections CMS includes in its HAC Reduction Program. Catheter-Associated Urinary Tract Infection has a mortality rate of 2.3%,¹² Surgical Site Infections for Abdominal Hysterectomy and Colon Procedures have a mortality rate of 3%,¹³ and Clostridium-difficile infection has a mortality rate of 7.9%.¹⁴ Thus, hospital-onset COVID requires more preventive effort.

Nearly half of all US residents are concerned about COVID outbreaks.¹⁵ Preventing COVID in the hospital is an equity issue. People of color continue to suffer high rates of COVID deaths.¹⁶ Amid huge health worker shortages, half of health workers go to work with COVID symptoms.¹⁷ CMS needs to protect both patients and health workers.

Even when community transmission is low, healthcare settings are the most likely place where people receiving COVID care could encounter vulnerable patients who could be harmed by COVID. COVID outbreaks are already happening in hospitals that stopped requiring masks.¹⁸ If your hospital roommate has COVID, you have a 4 in 10 chance of catching it from them.¹⁹ No one should be endangered for going to the hospital for a heart attack, elective surgery, or delivering a baby.

In spite of these facts, hospital administrators lobbied public health departments to end COVID protections in healthcare.²⁰ Vulnerable patients can still become severely ill or die from COVID. Anyone can get Long COVID with up to 18% of all US adults have experienced this condition and nearly 4 million people in the US are unable to work after being disabled from this condition.^21,22 Hospitals should be protecting patients under their care from COVID. But since hospitals previously faced a financial crisis²³ and positive COVID cases mean loss of income from elective procedures, we are concerned that hospitals are placing priority over profits over patient safety.

Please protect vulnerable patients, prevent health worker shortages, and promote health equity by requiring hospitals to report COVID infections and protect patients from hospital-acquired COVID.

References:

1. Lumley SF, Constantinides B, Sanderson N, et al. Epidemiological data and genome sequencing reveals that nosocomial transmission of SARS-CoV-2 is underestimated and mostly mediated by a small number of highly infectious individuals. J Infect. 2021;83(4):473-482. doi:10.1016/j.jinf.2021.07.034

2. Wu Y, Kang L, Guo Z, Liu J, Liu M, Liang W. Incubation Period of COVID-19 Caused by Unique SARS-CoV-2 Strains: A Systematic Review and Meta-analysis. JAMA Netw Open. 2022;5(8):e2228008. doi:10.1001/jamanetworkopen.2022.28008

3. National Center for Health Statistics. Hospital admission, average length of stay, outpatient visits, and outpatient surgery, by type of ownership and size of hospital: United States, selected years 1980–2019. Published online 2021. https://www.cdc.gov/nchs/hus/data-finder.htm

4. U.S. Department of Health and Human Services. COVID-19 Reported Patient Impact and Hospital Capacity by State Timeseries (RAW). HealthData.gov. https://healthdata.gov/Hospital/COVID-19-Reported-Patient-Impact-and-Hospital-Capa/g62h-syeh

5. Campbell D, Barr C. 40,600 people likely caught Covid while hospital inpatients in England. The Guardian. https://www.theguardian.com/society/2021/mar/26/40600-people-likely-caught-covid-while-hospital-inpatients-in-england. Published March 26, 2021. Accessed June 3, 2023.

6. Biden officials to keep private the names of hospitals where patients contracted Covid. POLITICO. Published June 25, 2022. Accessed April 18, 2023. https://www.politico.com/news/2022/06/25/biden-officials-to-keep-private-the-names-of-hospitals-where-patients-contracted-covid-00042378

7. American Hospital Association. CDC to Streamline Hospital COVID-19 Data Reporting Requirements. Published April 27, 2023. Accessed June 2, 2023. https://www.aha.org/special-bulletin/2023-04-27-cdc-streamline-hospital-covid-19-data-reporting-requirements

8. COVID-19 was third leading cause of death in the United States in both 2020 and 2021. National Institutes of Health (NIH). Published July 5, 2022. Accessed October 13, 2022. https://www.nih.gov/news-events/news-releases/covid-19-was-third-leading-cause-death-united-states-both-2020-2021

9. McPhillips D. Covid-19 was the fourth leading cause of death in 2022, CDC data shows. CNN. https://www.cnn.com/2023/05/04/health/covid-fourth-leading-cause-of-death/index.html. Published May 4, 2023.

10. Otter JA, Newsholme W, Snell LB, et al. Evaluation of clinical harm associated with Omicron hospital-onset COVID-19 infection. J Infect. 2023;86(1):66-117. doi:10.1016/j.jinf.2022.10.029

11. Cook AD Henrietta. Hundreds die of COVID after catching virus while in hospital. The Age. https://12ft.io/proxy?q=https%3A%2F%2Fwww.theage.com.au%2Fnational%2Fvictoria%2Fhundreds-die-of-covid-after-catching-virus-while-in-hospital-20230330-p5cwjx.html. Published March 30, 2023.