Montgomery Hospital-PA

This comment is in relation to the proposed rule on HAI's and submitting CLIP measures. Currently in PA we are not required to submit this data through NHSN. However, we do submit to almost all sections of the Patient Safety module. In hospitals without electronic medical records and limited staff this is quite time consuming given that data is entered into the system manually rather then through data transfer. Adding a new piece of reporting would be time consuming and cumbersome to most hospitals. While I realize the importance of this data, in PA we do enter information to the PA patient safety authority in our comment fields on patients that develop a CLABSI. That code is dedicated to maximal barrier precaution use. Using maximal barrier precautions is one way to decrease the amount of CLABSI in the facility, which is why we follow this. Please keep in mind that, as you stated on page 364 of this document, there are only 2 states that currently require facilities to report to NHSN at least one month of CLIP data. One month of data does not really provide useful information especially when it may not be the same month from all facilities collecting data. Thank you for reviewing this comment.