Comment from Kilroy, Amy

Amy KilroySupportBusiness
Summary: Amy Kilroy of Providence Alaska Medical Center requests that the NHSN revise its surveillance definitions to require clinical corroboration by a licensed healthcare provider for patient-reported signs or symptoms. The commenter argues that relying on uncorroborated patient reports can lead to inaccurate data, misclassification of infections, and unnecessary clinical interventions.
I am requesting NHSN reevaluate surveillance criteria within Chapter 7 (UTI/CAUTI Event), Chapter 4 (CLABSI Event) and Chapter 9 (SSI Event) that allow patient-reported signs or symptoms to contribute to meeting surveillance definitions. NHSN's UTI and SSI protocols rely in part on symptom-based surveillance criteria, and these determinations directly impact publicly reported HAI data and national benchmarking. While patient-reported information is essential for clinical assessment, surveillance systems have a different purpose: the generation of standardized, reproducible, and comparable data across facilities. Patient reports may be influenced by health literacy, symptom interpretation, cognitive status, recall bias, and documentation variability. Consequently, two facilities reviewing the same patient statement may reach different surveillance conclusions. I recognize that requiring clinical corroboration could decrease surveillance sensitivity in some cases. However, the benefit would be improved specificity, reliability, and inter-rater consistency. A balanced alternative would be to require that patient-reported symptoms be documented and validated by a licensed healthcare provider before being used to satisfy NHSN surveillance criteria. This would preserve the value of the patient report while improving confidence in NHSN surveillance data and public reporting outcomes. HAI surveillance is meant to identify infections that can reasonably be linked to healthcare delivery, so organizations can direct prevention efforts, use resources efficiently, assess interventions, and improve patient outcomes. To support that goal, surveillance definitions should track the underlying epidemiology and mechanisms of infection acquisition as closely as possible. When definitions do not reflect major external risk factors, or rely on subjective criteria that are interpreted inconsistently, they can classify events in ways that undermine the accuracy, reproducibility, and usefulness of reported data.

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