Comment Submitted to the Federal Register Concerning Proposed Rule CMS-1808-P

June 10, 2024

This comment was submitted to the Federal Register on 10 June 2024 concerning proposed rule CMS-1808-P. The proposed rule includes a provision that would require hospitals to regularly report data on influenza, COVID-19, and Respiratory Syncytial Virus (RSV) even outside of a declared public health emergency. In the absence of such a rule, many hospitals ceased reporting these data in late April 2024.

10 June 2024

To: Centers for Medicare & Medicaid Services (CMS), Department of Health and Human Services (HHS)

Re: FY 2025 LTCH PPS Proposed Rule, CMS-1808-P

I am Hayley Brown, a research associate at the Center for Economic and Policy Research, where I study disability justice, workplace safety, and the economic impact of Long COVID, among other topics. I support the proposed standard in CMS-1808-P that would require hospitals to submit weekly information on RSV, COVID-19, and influenza infections, irrespective of a declared public emergency.

Hospital data are essential for public health surveillance. Continuous monitoring helps in the early detection of outbreaks, allowing for prompt responses to prevent widespread transmission. Consistent surveillance enables efficient resource allocation and can help guide vaccination campaigns and other interventions. It also allows officials to gauge the acute-phase virulence of variants and plan accordingly. Consistent monitoring provides critical information for developing and improving vaccines and therapeutics, allowing researchers to gauge their ongoing effectiveness as pathogens evolve.

Understanding trends in infection and disease severity is also economically valuable. Controlling outbreaks early on can avoid health care system strain associated with treating large numbers of patients simultaneously. It is also important for workplace safety, productivity, and resilience. Preventing and controlling infections reduces absenteeism and improves productivity among workers in health care and other industries.

In public health, if you wait until there’s an official emergency to collect these data, you’re already too late. The emerging situation with H5N1 makes tracking these data all the more pressing. Tying essential data collection to a public emergency declaration leaves public health officials and vulnerable citizens in the dark about emerging threats. Divorcing this vital work from emergency declarations is crucial to controlling situations so that they don’t become emergencies in the first place.

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