August 25, 2023, Public Comment to CDC/HICPAC from COVID Safe Maryland

Dear Sydnee Byrd, M.P.A. (HICPAC, [email protected]),

COVID Safe Maryland is a volunteer group of Marylanders working to stop the spread of SARS-CoV-2 (COVID-19) in our state. We organize to reduce transmission, support people experiencing Long COVID, and remember those who have died from COVID-19. We advocate because policies that promote the unmitigated spread of COVID-19 force many of us out of public life, and put all of us at risk. We believe that everyone deserves the right to safely access essential spaces such as healthcare offices, schools, prisons, and public transit.

During the first three months of 2023, U.S. hospitals reported an average of 1231 patients per week that had caught COVID-19 during their stay, with a high of 2287 patients with hospital-acquired COVID-19 in the first week of January 2023 (using the current CDC 14-day definition).¹ COVID-19 has been one of the top five major causes of death in the US since 2020,²,³ and many of those deaths were likely due to hospital-acquired COVID-19, which has a 5-10% mortality rate.⁴,⁵ Now more than ever, it is imperative to maintain standards for high quality infection control regulations and practices in both inpatient and outpatient settings. Therefore, we call upon the CDC and HICPAC to recognize and act on the following:

1. All infection controls should be in place at all times, using a time-tested concept from patient safety that “layering” of individually imperfect controls is necessary to strengthen overall control. Comprehensive airborne infection controls should be standard, core, and routine, for all (inpatient, outpatient, etc.) patient encounters, both to minimize infections of any type, and to improve the cognitive performance and healing progression for all the people involved. These controls are relatively inexpensive to implement, compared to the costs that healthcare-associated infections will incur on the healthcare system and our general population. The minimum controls should include: 

• Air cleaning, via ventilation, filtration, and Far UV-C,
• Universal respirator (i.e. N95, P100, PAPR) use for all workers (not just patient contacts), visitors, and all medically-appropriate patients,
• All workers (not just patient contacts) staying home on paid leave when symptomatic or testing positive for an airborne disease (including COVID-19, TB, RSV, flu, etc.),
• Frequent, regular testing of all people in healthcare facilities with contact tracing programs to track any potential exposures. Additionally, public reporting of test results, exposure, transmission rates, and hospitalization counts.

2. HICPAC membership should include professional experts on all aspects of the built environment. The current roster lacks technical experts in air engineering, water quality, or surfaces. It is well known that many infections spread via physical vectors (air, water, and surfaces). 
3. HICPAC should recognize and adhere to recommendations separately provided in comments submitted by People’s CDC, World Health Network, and National Nurses United. 
4. HICPAC needs to improve its transparency and processes in decision making and stakeholder engagement by adopting the following changes:
5. HICPAC is clearly missing the benefits of patient and public input, and should consult the FDA, CMS, or other federal counterparts to improve these input processes, and implement changes as soon as possible. See About the FDA Patient Representative Program.
6. HICPAC must drop the unnecessary and overly restrictive limits on public comments, provide more opportunities and time allotments for oral comments, and remove the page restrictions on written comments. 

The HICPAC infection control standards play a crucial role in safeguarding public health. The public health landscape has not “returned to normal”; it has been profoundly changed by the spread of COVID-19. The new standards are an opportunity to build a stronger healthcare system for all, and we urge you to draft a standard that is up to this challenge.

Sincerely, 

COVID Safe Maryland ([email protected], https://covidsafemd.com/ )