SHEA expertise is routinely sought by regulatory and legislative entities. This section showcases public comments and policy communications.

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The Society for Healthcare Epidemiology of America provided comments both individually and with The Infectious Diseases Society of America (IDSA) in response to the proposed rule, “Hospital and Critical Access Hospital (CAH) Changes To Promote Innovation, Flexibility, and Improvement in Patient Care,” within the Medicare and Medicaid programs, commonly referred to as the “Conditions of Participation (CoPs).”   The individual comments SHEA submitted respond to changes in infection prevention provisions and clarifications needed in the final rule.  The joint comments SHEA submitted with IDSA  focus on the antibiotic stewardship portion of the proposed rules.

SHEA  Comments Addressing Infection Prevention (878 KB)
SHEA & IDSA Joint Comments Addressing Antibiotic Stewardship (432 KB)

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SHEA signed on to both Senate and House letters supporting increased funding for programs within CDC such as the National Healthcare Safety Network (NHSN), Antibiotic Resistance (AR) Solutions Initiative, and the Advanced Molecular Detection (AMD) program.

National Healthcare Safety Network (NHSN) Funding Support Letter – Senate (218 KB)
National Healthcare Safety Network (NHSN) Funding Support Letter – House (217 KB)

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APIC and the SHEA endorsed the Preventing Superbugs and Protecting Patients Act. Senator Patty Murray (D-WA) introduced the legislation and it would establish cleaning instructions and validation data requirements for reusable medical devices, including duodenoscopes. The bill advances recommendations from the “Preventable Tragedies: Superbugs and How Ineffective Monitoring of Medical Device Safety Fails Patients” report released in January 2016 on the multidrug-resistant organism outbreak associated with contaminated duodenoscopes.

View PDF (198 KB)

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SHEA provided comments in response to Docket ID number HHS–OPHS–2015–0008, specifically the Federal Policy for the Protection of Human Subjects.

View PDF (197 KB)

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SHEA provided comments on The Joint Commission’s proposed new standard for Antimicrobial Stewardship in healthcare settings.

View PDF (220 KB)

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On October 14, 2015 SHEA submitted comments to the Centers for Medicare & Medicaid Services (CMS) in response to the proposed rule on the Reform of Requirements for Long-Term Care Facilities in the Medicare and Medicaid program.

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On August 24 SHEA submitted comments to the Centers for Medicare & Medicaid Services (CMS) in response to the proposed rule for the Medicare End-Stage Renal Disease (ESRD) Prospective Payment System and Quality Incentive Program for dialysis centers.

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On June 16, 2015, SHEA submitted comments to Centers for Medicare & Medicaid Services (CMS) Hospital Inpatient Prospective Payment Systems (IPPS) program for Acute Care Hospitals and Quality Reporting Requirements for Specific Providers.

Full Comments (585 KB)
Summary Comments (326 KB)

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The Society for Healthcare Epidemiology of America (SHEA) provided comments in response to the proposed rule for the Office of the National Coordinator’s 2015 Edition Health IT Certification Criteria as published in the March 30, 2015 Federal Register.

View PDF (385 KB)

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The Society for Healthcare Epidemiology of America (SHEA) provided comments in response to the proposed rule for Stage 3 of the Electronic Health Record Incentive Program as published in the March 30, 2015 Federal Register.

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The Society for Healthcare Epidemiology of America (SHEA) provided the CDC and White House with a robust list of commitments on our strategy to alight with national strategy on combating antimicrobial resistant bacteria. The actual summit took place at the White House on June 2, 2015.

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The Society for Healthcare Epidemiology of America (SHEA) response to a request for comments from the Presidential Commission for the Study of Bioethical Issues on ethical considerations and implications of public health emergency response with a focus on current Ebola Virus Disease (EVD) epidemic, as published in the December 8, 2014 Federal Register.

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Since the 2010 publication of the "SHEA Guideline for the Management of Healthcare Workers Who Are Infected with Hepatitis B Virus (HBV), Hepatitis C Virus (HCV), and/or Human Immunodeficiency Virus (HIV)" (1), additional strides have been made in the therapy of these three bloodborne pathogens. Effective treatments offer the promise of sustained virologic control, further reducing the already exceedingly small risk of transmission from an infected healthcare provider to a patient.

View PDF (280 KB)

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On June 30, 2014, SHEA submitted comments to CMS on the Hospital Inpatient Prospective Payment System (IPPS) proposed rule for FY 2015.

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SHEA submitted comments in response to the FDA proposed rule regarding the safety and effectiveness of consumer antiseptics and topical antimicrobial drug products for over-the-counter human use.

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On June 13, 2014, SHEA submitted comments to CMS in response to the proposed rule for fire safety requirements for certain health care facilities. The Society’s comments address the topics of anesthetizing locations and alcohol based hand rubs.

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SHEA, APIC and HONOReform submitted comments in response to the FDA’s Draft Guidance for industry addressing appropriate packaging sizes for injectable drug and biological products in order to prevent medication errors and misuse or pooling of leftover drug products.

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SHEA joined with coalition of health care organizations in support of FY 2015 CDC funding for National Healthcare Safety Network, Prevention Epicenters Program, Detect and Protect Against Antibiotic Resistance Initiative and Advanced Molecular Detection Initiative.

View letter sent to Appropriations Committees PDF (127 KB)

View letter sent to Appropriations Subcommittees PDF (127 KB)

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SHEA and IDSA submitted joint comments to NIOSH in response to its request for information on Respiratory Protective Devices used in health care.

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SHEA provided comments in response to HHS’ National HAI Action Plan proposed new five-year 2020 targets.

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