Joint Commission and Influenza Vaccination: IC.02.04.01

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Joint Commission approves of this blog

The Joint Commission has just released proposed requirements addressing influenza vaccination of staff and licensed independent practitioners. Revisions to current requirements are proposed for Hospital, Critical Access Hospital, and Long Term Care accreditation programs with new requirements proposed for Ambulatory Care, Behavioral Health Care, Home Care, Laboratory, Medicare Based Long Term Care, and Office-Based Surgery accreditation programs.  Comments will be gathered until May 17, 2011.

You can review the proposed standards and leave comments on the JC site here.

For the Hospital Accreditation Program IC.02.04.01, elements 1-3 remain the same, elements 4 and 5 have been revised and elements 6-9 have been added. The new text is bolded below and the revised elements are:

1. The hospital establishes an annual influenza vaccination program that is offered to licensed independent practitioners and staff

2. The hospital educates licensed independent practitioners and staff about, at a minimum, the influenza vaccine; non-vaccine control and prevention measures; and the diagnosis, transmission, and impact of influenza. (See also HR.01.04.01, EP 4)

3. The hospital provides influenza vaccination at sites accessible to licensed independent practitioners and staff.

4. The hospital annually evaluates vaccination rates and the reasons given for declining the influenza vaccination.

4. The hospital includes in its infection control plan the goal of improving influenza vaccination rates. (For more information, refer to Standard IC.01.04.01)

5. The hospital takes steps to increase influenza vaccination rates.

5. The hospital sets incremental influenza vaccination goals, consistent with achieving the 90% rate established in the national influenza initiatives for 2020.

6. The hospital develops a written description of the methodology used to determine influenza vaccination rates. All hospital staff and licensed independent practitioners are to be included in the methodology for determining the influenza vaccination rates. (See also IC.02.04.01, EP 1)

7. The hospital evaluates the reasons given by staff and licensed independent practitioners for declining the influenza vaccination at least annually.

8. The hospital improves its vaccination rates according to its established goals and at least annually. (For more information, refer to Standards PI.02.01.01 and PI.03.01.01)

9. The hospital provides influenza vaccination rate data to key stakeholders including leaders, licensed independent practitioners, nursing staff, and other staff at least annually.

More on SHEA's Flu Vaccine Mandate for Healthcare Workers

Last week, Dan blogged about SHEA’s new position paper, which calls for annual influenza vaccination as a condition of initial and continued employment for healthcare workers (HCWs). Simply put, SHEA is recommending that HCWs without a contraindication to influenza vaccine be fired if they refuse to be vaccinated. That’s a strong stance coming from an organization that typically avoids strong stances. I’ve blogged before about why I think that mandating influenza vaccination is a bad idea, but in this posting I want to focus on the evidence behind the recommendation.

Of note, there are 3 Cochrane reviews on influenza vaccination published this year that are worth reading. If you’re not familiar with Cochrane Reviews, you can read more about them here. These reviews are generally thought of as the highest quality, most rigorous reviews of the medical literature, and the reviews are developed free of any commercial funding.

The first Cochrane review, Influenza Vaccination for Healthcare Workers Who Work with the Elderly, is most applicable to the SHEA position statement. SHEA’s position on the utility of vaccinating HCWs to prevent influenza transmission to patients is based on 4 studies in long-term care facilities (LTCFs). And of note, those 4 studies are part of the Cochrane review, which comes to the following conclusion: “We conclude there is no evidence that vaccinating HCWs prevents influenza in elderly residents in LTCFs.”

Another recent Cochrane review evaluated the utility of influenza vaccination of healthy adults, which presumably represents the majority of HCWs. The authors concluded: “Influenza vaccines have a modest effect in reducing influenza symptoms and working days lost. There is no evidence that they affect complications, such as pneumonia, or transmission.”

The last Cochrane review is least applicable to our current discussion, but interesting nonetheless. In reviewing the effect of influenza vaccine for the elderly, the authors conclude “The available evidence is of poor quality and provides no guidance regarding the safety, efficacy or effectiveness of influenza vaccines for people aged 65 years or older.”

So given the lack of rigorous evidence supporting the utility of vaccinating HCWs to prevent transmission to patients, I find it astonishing that the Society for Healthcare Epidemiology would adopt such a position. I certainly would have no problem with a position statement that strongly encourages vaccination, but to recommend that HCWs be fired for noncompliance with vaccination is over the top and undermines SHEA’s credibility. The level of compliance with any intervention to improve the quality or safety of patient care must be correlated to the strength of the evidence, and in this case, the evidence for a mandate is lacking.

As I was looking at the Cochrane reviews, I wondered aloud how the SHEA guideline writers could have come to their conclusion. My good friend and colleague, Gonzalo Bearman, quickly responded, “they were blinded by dogma.” Amen, Gonzalo!

My surgeon has S. aureus!

Don't panic! Just based on probability a surgeon would have a 30% chance of being colonized with MSSA and perhaps a 1% chance of being colonized with MRSA. Researchers at NYU Hospital for Joint Diseases recently screened a total of 135 orthopedic surgeons for MRSA and MSSA nasal colonization. In the 74 attendings, 2.7% were MRSA+ and 23.3% were MSSA+. The story was a bit more interesting in the 61 residents with 59% MSSA+ and none MRSA colonized. Overall, 36% were MSSA+ and 1.5% were MRSA+, which is about what we would have guessed before the study.

These results are similar to Cecilia Johnston's report of healthcare worker colonization at Johns Hopkins a few years ago. She reported 28% S. aureus colonization (95% confidence interval [CI], 22%‐34%) and 2% MRSA colonization (95% CI, 0.04%‐4.0%). I pasted in Cecilia's results to highlight the fact that she calculated confidence intervals for each proportion. The NYU researchers were surprised by the high proportion of residents with MSSA colonization. Sure, the level was high, but if they would have calculated the 95% CI, which was 46%-71%, they might have been less excited.

It's possible that the long hours spent in direct patient care might be risk factors for MSSA colonization, as would frequently performing dressing changes, but these would not be unique to ortho residents. Perhaps they should repeat the study in the same residents at a later point to determine what proportion is transient vs persistent colonization. Of course, it would be nice to repeat the study in other cohorts of ortho residents and ortho nurses.

They also reported that patients screened prior to THR, TKR and major spine surgery at their hospital had 2% MRSA and only 18% MSSA colonization. It would have been nice to read more information about these patients, such as recent antibiotic exposure.

Schwarzkopf et al. in Journal of Bone and Joint Surgery (America): PubMed or JBJS
Johnston et al. in December 2007 ICHE
Easy confidence interval for proportion calculator: link

MRSA active surveillance: It just doesn't make sense

A study in the June issue of Infection Control and Hospital Epidemiology takes a look at staphylococcal colonization in healthcare workers. Over 250 HCWs were cultured and nearly half (44%) were colonized with S. aureus. MRSA colonization was found in 7% overall and was highest in nurses (10.5%). If the findings of this study are generalizable to other hospitals, this study has two important implications. First, given that nearly half of HCWs were colonized with S. aureus, hand hygiene practiced at very high levels of compliance is warranted. It seems that in the hysteria surrounding MRSA it's been forgotten that MSSA is also a pathogen. Second, why should hospitals engage in active detection and isolation (ADI) when non-patients are a significant reservoir for MRSA in the hospital setting? For those who continue to truly believe in ADI it seems that to me that their logic should dictate that MRSA colonized HCWs be removed from practice. And then there are visitors who may be colonized. The solution there could be to ban all visitors to the hospital. Of course, all of this assumes that the ADI zealots are driven by logic. Here's my recommendation: let's stop focusing on who has what organism (see Eli's posting from a few days ago), and just get everyone to wash their hands before and after every patient contact. The key word here is every. And maybe if that happened, we wouldn't need contact precautions any more. Now here's an interesting thought experiment: what could we do with all the money that's been spent on MRSA surveillance cultures over the last 5 years?