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 Center 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." (See frequently asked questions, below)
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 http://ow.ly/felo9
FAQs on tracking flu vaccination rate The Centers for Disease Control and Prevention answers to common questions on reporting health care worker influenza vaccination rates include the following: The HCP Influenza Vaccination Summary Form in NHSN defines the influenza season as July 1 to June 30. Does this mean that my facility is required to report on twelve months of data when we do not vaccinate for all twelve months? No. Although influenza may occur any time of the year, you should report data for the period specified in the NHSN protocol, which is from October 1 to March 31 for the denominator, including all vaccinations given during the influenza season in the numerator. The July 1 to June 30 time period is used by NHSN to clearly define the end of one influenza season and the beginning of the next influenza season. For the 2012-2013 influenza season, NHSN is allowing facilities to report data for only half of the influenza season to align with the CMS rule that requires acute care hospitals to report data beginning on January 1, 2013. For subsequent influenza seasons, data for the entire reporting period (October 1 to March 31) are required to be reported as specified in the NHSN protocol. What types of nurses are counted as licensed independent practitioners? All advanced practice nurses should be included in the licensed independent practitioner category. Advanced practice nurses include nurse practitioners, nurse midwives, clinical nurse specialists, and nurse anesthetists. Would you count health care personnel (HCP) who are not working with patients for 30 days or more, but because of staff meetings, etc. are physically in the facility for 30 days or more? Yes. Individuals who perform any work duty in the facility for 30 days or more from October 1 to March 31, are included in the count, regardless of clinical responsibility or patient contact. My acute care hospital owns several outpatient provider practices that are physically separate from the main hospital campus. Employees of these clinics are on the hospital's payroll, so should we include them in our HCP influenza vaccination reporting? No. These employees should not be counted in the vaccination reports since they do not physically work in the acute care hospital. Many of our HCP also work at another facility in town. Must they be reported by every facility at which they work? Yes. These reports describe vaccination rates among HCP working at a specific facility, so all eligible HCP must be counted by each facility where they work. My hospital is part of a multi-hospital system that has one corporate payroll. Each hospital has its own NHSN number, so how should each hospital report its total number of HCP? Each facility should report the total number of HCP who physically work in that facility. If a healthcare worker (HCW) physically works in multiple facilities in the hospital system for 30 days or more from October 1 to March 31, this individual should be counted in the total number of HCP for each facility where he/she works. Should I count an employee who starts at my facility after October 1, or leaves their position after October 1? Yes. All employees, non-employee licensed independent practitioners, and non-employee students and volunteers aged 18 and older who physically work at the facility for 30 days or more from October 1 through March 31, regardless of exact stop and start dates, should be counted. Should HCP who are employees of the healthcare system (e.g., university), but who are not hospital employees, be included? Non-hospital employees should only be included if they are physically in the facility for 30 days or more from October 1 to March 31 and meet the criteria for either the licensed independent practitioner category or the adult students/trainees and volunteers category. They would not be in the employee category if they are not on the hospital's payroll. Are other licensed contract workers/non-employees such as nurses, technicians, therapists, etc. reported? Non-employee licensed or credentialed providers other than physicians, advanced practice nurses, and physician assistants are not required to be reported. |
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