Wednesday at 7.30 ET on zoom: Tell Medicare/Medicaid: Hospitals should protect us from COVID-19
Plus a video guide to comment process
Tomorrow, Wednesday, at 7.30 ET we’ll have a coworking session to help trouble shoot the public comment process to CMS. Register here for June 7 7.30 ET public comment trouble shooting session.
If you can’t make it, we’ve also made a video which describes the process as best we can (please turn on auto captioning for you tube, we apologize in advance that we weren’t able to caption this one ourselves). Watch the video here! And then see our guide below for submitting comments to Centers for Medicare and Medicaid (CMS). Let’s overwhelm the federal register with public comments!
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. We will also hold online zoom sessions on June 7 at 7.30 ET (register here), to help people troubleshoot the comment process.
We have until June 9, 2023 to tell the Centers for Medicare and Medicaid Services (CMS) that hospitals should give us care, not COVID. CMS has a huge influence on hospitals. CMS already penalizes hospitals, which fail to keep patients safe from other hospital-acquired infections, but not COVID. CMS is now asking for comments about: “What measures should be introduced in the Hospital Acquired Condition (HAC) Reduction Program to address emerging high priority patient harm events and healthcare-associated infections?” We should tell CMS to include COVID in its Hospital-Acquired Condition (HAC) Reduction Program and/or its Value-Based Purchasing Program, to create financial incentives to prevent the spread of COVID in hospitals.
Hospital-acquired COVID-19 has a 5-10% mortality rate. That’s between a 1-in-10 and 1-in-20 chance of dying if you catch COVID in the hospital! It can and should be prevented.
Register here to attend our next public comment-submission zoom session on Wednesday, June 7, 2023 at 7.30 PM ET
With hospitals in a “crushing” budget crisis, we need to tell CMS to make the hospitals put patient safety first. Hospitals around the country have stopped screening patients for COVID on hospital admission and before elective procedures. Hospitals lose money rescheduling elective procedures when patients test positive. You have a 40% chance of catching COVID-19, if your hospital roommate has it. Who wants to go to the hospital for a heart attack, to have a baby or routine surgery and catch COVID?
COVID is not on the list of infections that CMS tries to get hospitals to prevent, such as surgical site infections and MRSA blood infections. Now hospitals have ended many crucial COVID-infection control measures around the country, and we have already seen hospital outbreaks as a result. Without COVID-19 infection control, hospitals 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.
Preventing hospital acquired COVID is an equity issue. CMS says they want to hear from multiple stakeholders and they are concerned about equity. Communities who have experienced the most harm due to the COVID pandemic, like low-income communities and people of color, are still being disproportionately harmed by COVID, and less likely to access boosters and treatment.
Just last month, the DEA extended telemedicine flexibilities after receiving thousands of public comments. Together we can urge CMS to protect us and make our hospitals safer!
➡️ How to Comment:
Unique comments in your own words have the greatest impact and are counted with more weight.
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 healthcare worker or public health researcher, mention that.
Feel free to copy and paste our sample letter text into the “Comment Section”, references, edited, in part or full, with your public comment, as you see fit.
After entering your comment, scroll down and select “Healthcare industry” in the dropdown menu of “What is your comment about?”
If you prefer you can also upload your comment as a PDF.
Note that the Federal Register comment tool does not accept posts with links and URLs. So to cite other sources or info, either upload the comment itself as a PDF, refer to sources without links, or upload PDFs of supporting info.
If you have the time and energy, please, upload any supporting references as PDFs. They literally must read every document uploaded! Here are a few suggestions.
Below is a sample template letter you can copy-paste all or part of it for your public comment, but please customize a little.
People’s CDC Sample Template Letter:
(The hyperlinks below will not transfer to the plain-text box. If you prefer to upload a fully cited version, here is a PDF you can upload instead).
To reduce the spread of COVID inside of hospitals, the Centers for Medicare and Medicaid Services (CMS) must implement financial incentives as part of CMS-1785-P.
The following measures should be implemented:
CMS should include COVID in its Hospital-Acquired Condition (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 try to minimize 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, the CDC, and to post these numbers publicly. Hospitals should also be required to specify how many days patients have been in the hospital when diagnosed with COVID.
“Hospital-onset COVID” should be defined as infections diagnosed after 5+ days of hospitalization. The CDC currently defines hospital-onset COVID as as only those cases diagnosed in people who are still in the hospital after 14 days of hospitalization. This vastly underestimates hospital-acquired COVID, particularly because with current variants, it only takes 2-3 days from COVID exposure to developing symptoms, and because the average hospital stay is only about 5.4 days.
The evidence that informs these suggestions includes:
During the first three months of 2023, U.S. 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 14-day cutoff). The UK has documented even higher rates, 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, and the CDC stopped requiring hospitals to report hospital-onset COVID in April 2023.
COVID has been one of the top five major causes of death in the US since 2020, and many of those deaths were likely due to hospital-acquired COVID, which has a 5-10% mortality rate. 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%, Surgical Site Infections for Abdominal Hysterectomy and Colon Procedures have a mortality rate of 3%, and Clostridioides-difficile (C. diff) infection has a mortality rate of 7.9%. Thus, hospital-onset COVID is well worth preventing.
Nearly 40% of all US residents are concerned about COVID outbreaks. Preventing COVID in the hospital is an equity issue. People of color continue to suffer disproportionate rates of COVID deaths. Half of health workers go to work with COVID symptoms, amid huge health worker shortages. CMS needs to protect both patients and health workers.
Even when community transmission is low, healthcare settings are the most likely place where people getting care for COVID could encounter vulnerable patients who could be harmed by COVID. Covid outbreaks are already happening in hospitals that ditched masks. If your hospital roommate has COVID, you have a 4 in 10 chance of catching it from them. No one should go to the hospital for a heart attack, an elective surgery or to deliver a baby and catch COVID.
In spite of these facts, hospital administrators lobbied public health departments to end COVID protections in healthcare. Vulnerable patients can still become severely ill or die from COVID. Anyone can get Long COVID, which disables over 4 million people in the United States. Hospitals should be protecting us from COVID when we are in their care. But hospitals are in a “crushing” financial crisis. They lose money when they have to cancel procedures when patients test positive for COVID. We are concerned that hospitals are putting profits over patient safety.
Please protect vulnerable patients, prevent health worker shortages, and promote health equity by requiring hospitals to protect patients from hospital-acquired COVID.
