National Healthcare Safety Network (NHSN)

The Society of Infectious Diseases Pharmacists (SIDP) supports the National Healthcare Safety Network (NHSN) as a vital resource for monitoring healthcare-associated infections and antimicrobial resistance. They request that the CDC provide specific details on the 72 revised forms and conduct a contemporary assessment of the reporting burden to ensure accurate resource allocation.

The American Health Care Association (AHCA) opposes the mandatory data collection and reporting requirements for annual influenza vaccination coverage for healthcare personnel. They argue that the data lacks practical utility, imposes a significant administrative burden on nursing homes, and that the agency has underestimated the costs and time required for reporting.

New England Baptist Hospital opposes the updated 2026 NHSN definition for deep incisional SSIs because it captures noninfectious cases like hematomas and seromas. They argue this increases reporting burdens and costs while artificially inflating standardized infection ratios (SIRs), and they request an edit for the 2027 requirements.

The commenter opposes the proposal to decrease burden hours for the National Healthcare Safety Network (NHSN). They argue that maintaining or increasing the current burden hours is necessary to ensure adequate funding for tracking infectious diseases and other critical health issues.

Representatives from Providence Health and Services argue that the current CDC/NHSN surveillance criteria for surgical site infections (SSIs) are too sensitive and lack specificity, leading to false positives. They request revisions to the criteria to include explicit exclusions for non-infectious processes, require infectious indications for "deliberate opening" of incisions, and add anatomic/causal plausibility filters to the surveillance window.

Representatives from Providence Health and Services argue that the current CDC/NHSN surveillance criteria for surgical site infections (SSIs) are too sensitive and lack specificity, leading to false positives. They request revisions to the criteria to include explicit exclusions for non-infectious processes, require infectious indications for "deliberate openings," and add anatomic/causal plausibility filters to the surveillance window.

Dr. Jason Kuhl, Chief Medical Officer at Providence Medford Medical Center, argues that the current NHSN Deep Incisional SSI surveillance definition is too broad and captures non-infectious complications. He requests revisions to the criteria to improve specificity by requiring objective markers of infection or excluding non-infectious clinical reasons for antibiotic use and surgical re-access.

Dr. Jason Kuhl of Providence Medford Medical Center argues that including uncorroborated patient-reported symptoms in NHSN healthcare-associated infection (HAI) surveillance definitions leads to inaccurate data and unnecessary clinical interventions. He recommends revising the definitions to require clinical corroboration by a licensed healthcare provider to ensure data integrity and reliability.

The commenters from Beth Israel Deaconess Medical Center and New England Baptist Hospital oppose the updated 2026 NHSN definition for deep incisional surgical site infections (SSIs). They argue that the current definition captures noninfectious cases like hematomas and seromas, which increases reporting burdens, costs, and artificially inflates standardized infection ratios (SIRs).

The commenter, identifying as an NHSN user, supports the inclusion of risk-adjusted calculations or the exclusion of HIPEC procedures from CMS reportable data metrics. They argue that because HIPEC significantly increases the risk of surgical site infections (SSI), including these cases in standard metrics without adjustment falsely skews hospital performance data and impacts reimbursement.