Public Reporting of Employee and Non-Employee Healthcare Personnel

Influenza Vaccination/Informed Declination Rates

Influenza Subcommittee HAI Advisory Committee July 7, 2010

Members • Raymond Chinn, MD (Chair)• Lilly Guardia-LaBar, RN, CIC• Julie Marleau• Tricia McLendon, MPH (CDPH)• Carole Moss• Frank Myers, MA, CIC• Terry Nelson, MBA, RN, CIC• Rebecca Siiteri, RN, MPH (CDPH) • Dawn Terashita, MD, MPH• Francesca Torriani, MD• Kavita Trivedi, MD (CDPH)

California Health and Safety Code, Section 1250

Requires that all licensed general acute care hospitals (GACH) must:

• Offer annual onsite influenza vaccinations, upon availability, to all employees at no cost to the employee;

• Require its employees to be vaccinated to obtain a written declaration that the employee declined vaccination; and

• Annually report to CDPH infection prevention process measures as recommended by the CDC Healthcare Infection Control Practices Advisory Committee, including but not limited to influenza vaccination measures of healthcare personnel 

Challenges Accuracy of submitted data

– Various interpretations of what constitutes an employee

– Inclusion or exclusion of employees vaccinated elsewhere

– Broad definition of non-employee healthcare personnel (HCP): left up to the institution to decide

– Difficulty in capturing information on HCPs

For 2008-09 and 2009-10 Seasons

• Post disclaimer that data collected had significant limitations making comparisons difficult to interpret

• Attach report describing limitations in depth

Non-Reporting Hospitals for the 2008-2009 Influenza Season

• Epidemiology Unit has/ will contact ~ 100 hospitals to verify non-reporting status

• Request to re-submit data for those hospitals that stated that data was submitted

• ? Re-analysis of aggregate data

Reporting Influenza for the 2008-2009

Post aggregate CA data, w/ list of reporting facilities and non-reporting facilities after CDPH contacts non-reporting facilities to verify reporting status

Aggregate data to include employees only:

Report aggregate vaccination percent Report aggregate declination percent Report “unknown” percent

Reporting for 2009-2010• Issues: availability of vaccine and pandemic

strain• Hospitals given a 90 day grace period (4/30 –

7/1, 2010) to submit or correct/re-submit data• Oct. 30, 2010: similar to reporting of 2008-09

season for employees: post aggregate CA data, w/ list of reporting facilities and non-reporting facilities

Aggregate data to include employees only: Report aggregate vaccination percent Report aggregate declination percent Report “unknown” percent

For the 2010 – 2011 Season

• Input from EOHD advisors– Michael Allerton (Kaiser)– Connie Perez-English (Kaiser)– Annie McCary (LAC-USC)– Robert Harrison, MD (CDPH, UCSF)

• Survey: 2 data collection forms from Epidemiology Unit: HCP groups vs. unit

• Sent out to hospitals in LA for input by Dawn Terashita, MD

Reporting for 2010-2011 SeasonVaccination rates for employees: listing by hospitals

– Denominator:• Use “paycheck” (in-patient “surveyable”: Kaiser) from

institution as surrogate marker• Include only employees who are on payroll on 03/31• Exclude all those who are on “leave of absence” on 03/31

– Numerator (cut off date 03/31/10):• Total number vaccinated (subcategories: those vaccinated at

the institution and those vaccinated elsewhere) • Total number of employees who declined (exclude those

employees who declined because they were vaccinated elsewhere)

• Total number of unknown

– CDPH to calculate vaccination and vaccination/informed declination (outreach) rates

Comments and Responses Regarding Issues with Employees Reporting

• Accuracy of data when work force is dynamic: response: not perfect, best that can be done is to use a cutoff date

• Is separate category of vaccinated elsewhere necessary? response: yes, to capture the total number vaccinated

• Some employees who are vaccinated elsewhere will not answer question (HIPAA) and fill in “other” in their declination; response: included in declination is a category of “vaccinated elsewhere” so this should suffice

Definition of Healthcare Personnel

Healthcare personnel might include (but are not limited to) physicians, nurses, nursing assistants, therapists, technicians, emergency medical service personnel, dental personnel, pharmacists, laboratory personnel, autopsy personnel, students and trainees, contractual staff not employed by the healthcare facility, and persons (e.g., clerical, dietary, housekeeping, maintenance, and volunteers) not directly involved in patient care.

Non-Employee HCP: 2010-11• Option 1

– Target special groups, e.g. • Includes all license independent practitioners

(LIPs) who have privileges at the hospital on March 31: requires Medical Staff office support

• Volunteers no March 31: information could be captured by EOHD

• Contract agencies/registries rates: how to best obtain information

HCP Surveillance: Targeted GroupVaccinated by facility

Vaccinated elsewhere

Declinations Unknown

Paid Employees

Physicians (Licensed Independent Practitioners)

Registry nurses

Volunteers

Issue of denominator for non-employee HCP

Issues with GroupsHow to capture various groups that are targeted:

– MDs: difficult for EOHD; response: needs oversight of Medical Staff office

– Volunteers: why is this group important; response: volunteers in some institutions have very close contact with patients

– Registry: should this be all or none, or targeted? Difficult since there may be many in this group; response: incorporate into contract to assure compliance

– Classify MD and other non-employee HCPs; response: the latter group too difficult obtain data

– Separate by patient contact; comment: ditto

Contract/Registry HCP: AFL 08-17 Page 4 August 29, 2008: an Alternative

As influenza vaccination of all healthcare personnel is recommended by the CDC, it is suggested that acute care hospitals establish a process ensuring that contract agencies provide evidence of influenza vaccination and/or verification of informed declination for all contracted healthcare personnel.

Recommendation for Registry/Contract HCPs

• Require hospitals to provide an attestation from registry and contract agencies confirming that they require their employees to either get vaccinated for influenza or sign a declination

• Denominators and numerators of vaccinated or declined registry would not be collected

Non-Employee HCP2010-11

• Option 2– Target special care areas caring for high

risk patients, e.g. ED, ICU, pediatric units, s• SF General model: point prevalence surveillance• Every HCP is required to have documentation of

vaccination/informed declination when providing care in the designated patient care unit.  The oversight will be the unit manager

HCP Surveillance: Targeted Areas

Vaccinated by facility

Vaccinated elsewhere

Declinations Unknown

Paid Employees

Emergency Department

ICU

Pediatrics

Issue of denominator for non-employee HCP

Issues with Targeted Areas

• Confusion between employees and healthcare personnel

• Difficult to capture registry personnel

• How should numerator and denominator for registry supplied?

Motions

• Format for 2008-2009 reporting

• Format for 2009-2010 reporting

• Format for 2010-2011 reporting for employees

• Format for 2010-2011 reporting for non-employee healthcare personnel