Upcoming HICPAC Public Meeting Information

16 comments on “Upcoming HICPAC Public Meeting Information”

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Day of the meeting — today is Aug 22, 2024, and there is still no opportunity for written comment for the public.

I would like to know if they are considering any changes to the current work restrictions guidelines for Healthcare workers who are positive for COVID. The current guidelines are very restricting to healthcare workers but not to the general public. Also they are not feasible and ambiguous. Most health care entities are ignoring these guidelines and choosing to follow the guidelines for the general public found here: (https://www.cdc.gov/respiratory-viruses/guidance/?CDC_AAref_Val=https://www.cdc.gov/respiratory-viruses/guidance/respiratory-virus-guidance.html.)

In my opinion, retesting is excessive and costly. We do not currently do this with flu or RSV. COVID should be the same.

Healthcare must protect patients. Ensuring the highest levels of mitigation measures are not restrictions but necessary policies to ensure the health and wellbeing of patients and staff.

I would also like to see this topic reviewed. If we continue to follow this recommendation, we should be getting further funding for antigen test kits. Healthcare staff should have these available to order free of charge. I know this is a burden for some our staff wanting to return to work but not having test kits at home.

I see 3 new HICPAC has added 3 new members. I have emailed repeatedly requesting a Certified Nurse Assistant, CNA, be represented on this important committee. CNAs represent real world experiences in real time. All of the recommendations, regulations and guidelines are worthless if they are not implemented on the frontline. Nursing homes lost hundreds of thousands of residents and staff during the pandemic, so infection control is critical in post acute care, as it is all health care. CNAs see everyday what is being implemented and what is leaving residents, staff and visitors vulnerable. Please consider adding a CNA or equivalent as they have valuable perspective. Thank you.

One day to go and still no open Federal Register for the public to be able to make comments for the HICPAC meeting on August 22, 2024.

Two days until the HICPAC meeting and no open Federal Register yet for comments. Is it because you don’t want to hear from the public?

Please make the comments open so the public can comment.

Keeping comments closed so that the public cannot comment is wrong.

Public engagement and input are vital to HICPAC’s work. All HICPAC webcasts include time for oral public comment for members of the public. All individuals interested in making an oral public comment during the meeting, need to submit a request. The submission period to make an oral public comment at the August meeting closed on August 12. The public can always submit written comments to HICPAC via the HICPAC mailbox (HICPAC@CDC .gov); these are shared with HICPAC members. Members of the public are encouraged to submit written comments about draft documents using the Federal Register process via Regulations.gov when documents are posted. Currently, HICPAC does not have any draft documents for public comment in the Federal Register. When new documents are posted, the public will be notified in many ways.

It’d be super cool if HICPAC could make comments available well before the meeting. Seems like it is against the law to not make comment available. After the fact is not good enough. It shortchanges the public of their voice in this process.

Public engagement and input are vital to HICPAC’s work. All HICPAC webcasts include time for oral public comment for members of the public. You may hear the oral public comments live and/or in the recording that is posted after the meeting – HICPAC Meeting – Aug. 22, 2024 (youtube.com)For written comments on draft documents in the Federal Register, CDC and HICPAC review and respond to the public comments via the Regulations.gov process; draft documents are then revised to reflect public input. Currently, HICPAC does not have any draft documents for public comment in the Federal Register. When new documents are posted, the public will be notified in many ways. The public can always submit written comments to HICPAC via the HICPAC mailbox (HICPAC@CDC .gov); these are shared with HICPAC members.

Why has the Federal register not been made available for members of the public to give their written comments?

Not all members of the public have the time and resources to become oral commentators–especially because it requires a person to be not working at the time of the meeting– and many members of the public would prefer to leave a written comment.

HICPAC needs to open the comments and leave it open with enough time for people to get their comments in on the topics that the meeting is covering.

Many people are concerned about healthcare mitigations for airborne transmission, and their safety at healthcare appointments.

Thank you for your comment. The public can always submit comments to HICPAC via the HICPAC mailbox (HICPAC@CDC .gov); however, members of the public are encouraged to submit written comments about draft documents using the Federal Register process via Regulations.gov.

As a person who is very interested in infection control at healthcare facilities, where is the federal register number so that I can leave a written comment for consideration for the ICPAC meeting?

I have been at numerous medical appointments in the last four weeks for a family member with advanced Stage 4 cancer and out of the dozens and dozens of healthcare practitioners we have encountered, only two of them wore a mask of any sort — and both wore nuisance masks that do not have adequate seals for airborne transmission, and of those two, one wore the mask because they were not feeling well. My family member is not be protected against infection against anything that could be in the air. A recent study in JAMA-No indicated that on average, a patient can be set back by 34 days from their treatment by becoming infected with Covid-19. “Masking Policies at National Cancer Institute–Designated Cancer Centers During Winter 2023 to 2024 COVID-19 Surge”, JAMA Netw Open. 2024;7(7):e2424999. doi:10.1001/jamanetworkopen.2024.24999, (https://jamanetwork.com/journals/jamanetworkopen/fullarticle/2821699 ) Time is an absolutely critical component of treatment for cancer patients because cancer is constantly growing, finding and treating cancer earlier offers more success. Appropriately protecting cancer patients by not infecting them at their healthcare appointments is important in their care and in the success (and statistical data success) of any cancer program.

I also recently donated blood to the Red Cross, and as one of the 15% of the population who is cytomegalovirus negative, I have concerns. No one at the donation location would mask in my presence, even though the CO2 concentration was at 1590 as measured by an Aranet4 CO2 measuring device. Some scientific literature suggests that CMV does have an airborne transmission component. Perhaps they are trying to infect me with CMV so that I can stop providing donations for the most vulnerable of our populations, which is newborn babies who require CMV-negative blood when they do need blood products?

I would like to make the HICPAC committee aware of these experiences of mine for their consideration as they determine how to move forward with advising healthcare facilities.

So, I would very much like that it is easily found on their website how to do so on the Federal Register. If it is there, it is no easily found. If it is not there, then it needs to be.

HICPAC is interested in hearing stories like yours. Members of the public can always submit comments to HICPAC via the HICPAC mailbox (HICPAC@cdc.gov); however, we encourage you to submit written comments about draft documents using the Federal Register process via Regulations.gov. Please stay tuned to the public meetings or the HICPAC website for HICPAC Federal register postings.

The pediatric community is very concerned about the adverse impact of implementing enhanced barrier precautions (EBP) at long-term care facilities caring for children. We feel that the decision-making about EBP was exclusively derived from multi-drug resistant organism (MDRO) research from adult long-term care facilities and did not consider the unique population and care needs of children in these settings. The use of EBP was targeted for specific high-risk residents with chronic wounds and/or indwelling devices. In adult nursing homes, this population is usually a minority of their population, however in pediatric long term care facilities – it is the vast majority. Among children with medical complexity, admission to a pediatric-specific long term care center (with constant medical supervision and a robust Antibiotic Stewardship Program) will tend to reduce hospital admission rates and decrease antibiotic use, thereby potentially mitigating the risk of MDRO colonization.

We appreciate the update to Enhanced Barrier Precautions in Nursing Homes FAQ #6: “The studies that informed EBP, including defining which care activities most commonly result in transfer of MDROs to staff hands and clothing, were conducted in adult nursing home populations. Such activities and risks might be different among pediatric nursing home populations and additional consideration is needed when implementing EBP in these settings. Nursing homes with pediatric residents who implement EBP for their pediatric population as part of their MDRO prevention plan may need to redefine high-contact resident care activities based on the anticipated degree of contact and developmental abilities of pediatric residents (e.g., repositioning an infant compared to a young adult may require different levels of assistance).” The Centers for Medicare and Medicaid Services (CMS), the Center for Clinical Standards and Quality, and the Quality, Safety and Oversight Group (Ref. QSO-24-08-NH), has published this guidance as a national standard, and all other national infection control organizations point to The U.S. Centers for Disease Control and Prevention’s (CDC) enhanced barrier precautions as the national standard. Therefore, it is expected to be implemented as a national standard, per CMS regulations.

Children in institutional settings are at risk of structural neglect (limited physical resources, unstable staffing patterns, and social-emotionally inadequate caregiver-child interactions) that impacts their psychological and developmental well-being. Pediatric long-term care facilities pay special attention to this and work hard to promote individualized care, attention, touch, developmentally appropriate, stimulating and supportive environments, outings and community engagement (e.g., going out of facility to school, interactions with facility dogs, swimming in the facility pool, baby developmental play groups, sensory groups, going out for fishing trips, snuggling, reading times). Broadly applying EBP to all children adds a physical barrier and time barrier to interaction with the child for touch and comfort when a child is well, but also when they are showing signs of agitation, frustration, or illness. Developing children and those with intellectual disabilities need regular touch, interaction, and comfort.

As stewards of care for the medically complex and vulnerable pediatric population, we believe in the intent of protecting our residents from the potentially harmful effects of MDRO transmission. However, without specific data on the incidence and transmission risk of MDROs in pediatric facilities, it is impossible to know the true burden MDROs play in the morbidity and mortality of this medically complex population. It is also impossible to measure the effects that EBP may have in reducing that morbidity and mortality. As written, the current guidance on EBP use will have adverse effects on residents’ socioemotional development, will decrease their ability to participate in therapies and activities, will have calamitous effects on care costs – and potentially affect the long-term viability of organizations that provide this level of care. While we appreciate the update in FAQ #6 and the clarification of the guidance, it doesn’t fix the concerns we are addressing in this comment. We request that CDC guidelines for standards be modified for the pediatric nursing home population to address the needs of the children and ensure that the system reduces the adverse effects on residents and the catastrophic effects of care costs. The guidance should allow for modification to the EBP to address only children with active MDROs.

Thank you,
Linda Mosiello, Board President
Pediatric Complex Care Association

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