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New in the Reportable Disease Rule, 2007. Danae Bixler, MD, MPH Infectious Disease Epidemiology Program WVDHHR. Objectives. Outline: Timeline Changes in rule: Reporting timeframes New diseases to be reported Diseases that are no longer reportable
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New in the Reportable Disease Rule, 2007 Danae Bixler, MD, MPH Infectious Disease Epidemiology Program WVDHHR
Objectives • Outline: • Timeline • Changes in rule: • Reporting timeframes • New diseases to be reported • Diseases that are no longer reportable • New sections that impact public health practice • Common issues that CAN be solved by application to the rule • Strengths and limitations of the rule
Timeline • Revision began 2003-4 • Internal review / drafting 2003-4 • Statewide comment 2004 • Legislative session 2005 • Rejected because of fiscal note • Second attempt 2005-6 • Statewide comment: 2005 • Legislative approval 2006 • Final copy received August 2006
Timeline (2) • Outstanding issues • Reporting of novel influenza • Further cleanup: • Eliminate reporting of occupational health • Name change to Shigatoxin-producing E coli • Eliminate provider reporting of chronic hepatitis C • Final version received March 5, 2007
Definitions • Local Health Officer = Local health officer or designee • Commissioner = Commissioner or designee
General Changes • Five categories of reportable conditions: • Immediate • 24 hours • 72 hours • Weekly to LHD • Weekly to state • Local health departments must report to state in the same timeframe as providers • Electronic reporting mandated from local health departments when the commissioner declares WVEDSS operational – anticipated July 2, 2007.
Selected DiseasesReportable Immediately to Local Health Category I • Category A BT agents • Anthrax • Botulism • Plague • Smallpox • Tularemia • Viral Hemorrhagic Fever • Novel influenza infection • Outbreaks • Measles and SARS
Immediately Reportable Events – Provider Responsibilities • Immediately report by phone to the local health department • Include: • Patient name, address, telephone number, date of birth, sex, race • Physician name, address, office phone and fax • Any other information requested by the commissioner
Immediately Reportable Events – Laboratory Responsibilities • Immediately report by phone to the local health department • Include: • Patient name, address, telephone number, date of birth, sex, race • Physician name, address, office phone and fax • Name of submitter • Specimen source, date of collection, date of result, name of test, test result, normal value or range • Laboratory name, address, phone and fax
Immediately Reportable Events – Local Health Department Responsibilities • Immediately report by phone to DHHR: 800-423-1271 • File a WVEDSS report • Required July 2, 2007 • See 64-7-7 (outbreaks)
Selected DiseasesReportable at 24 Hours to Local Health Category II • Animal bites • Hepatitis A, B • Meningitis (meningococcus, H flu) • Pertussis • Staphylococcus aureus resistant to Vancomycin • STEC (Enterohemorrhagic E coli) • Tuberculosis
Selected Diseases Reportable at 72 Hours to Local Health Category III • Amebiasis • Campylobacteriosis • Cryptosporidosis • Cyclospora • Giardiasis • Listeriosis • Salmonellosis • Shigellosis • Trichinosis • Yersiniosis
Selected DiseasesReportable at 1 Week to Local HealthCategory IV • Arboviral infection • Chickenpox (aggregate total only) • Community-acquired MRSA (invasive) • Death from chickenpox • Influenza-like illness (aggregate only) • Influenza-related death (age < 18) • Legionellosis • Lyme disease • Invasive bacterial diseases (S pneumo, GAS, GBS) • Tuberculosis latent infection
Selected DiseasesReportable at 1 Week to State HealthCategory V • AIDS • Chancroid • Chlamydia • Gonococcal disease • Hepatitis C • Providers – acute • Laboratories – all positive test results • PID • Syphilis
Eliminated • Aseptic meningitis • Bacterial meningitis, other • Encephalitis, other • Hepatitis C, chronic (from providers) • Herpes • Occupational illness • Rheumatic Fever
Rabies (64-7-5) • Animal bites reportable to the local health department within 24 hours • Ferret added to list of animals that may be quarantined. • Language added to: • Allow humane destruction of animals other than a domestic dog, cat or ferret, ‘especially a wild mammal or hybrid…’ • Enable reporting of rabies post-exposure prophylaxis to WVEDSS
Immunizations (64-7-6) • Reporting requirements expanded to persons 18 years of age and younger • Newly reportable • Smallpox vaccination • Pandemic influenza vaccination • Immunizations of adults (voluntary)
Disease outbreaks (64-7-7) • Immediate notification of: • Local health officer • The Bureau • Collaboration with • The Bureau • Other jurisdictions • Federal public health officials • Steps in investigation outlined • Enabling language to complete special studies (e.g., case-control, cohort), hold individually identifying data confidential
Surveillance program evaluation and special studies (64-7-8) • Commissioner given the ability to do evaluation of surveillance systems or special studies, including: • Right to request medical or laboratory records to perform audits for completeness, accuracy and timeliness of reporting • Do special studies (e.g., case-control, cohort, cross-sectional) on the health of the population for the purpose of quantifying the risk to the population or access to appropriate prevention and control services • Hold data confidential
Bioterrorism response (64-7-9) • Immediate notification • Definition • Collaboration with other local health officers, state and federal officials, law enforcement • Investigation as in outbreak investigation section
Syndromic surveillance and electronic laboratory reporting (64-7-10) • Commissioner may create a list of syndromes to be reported: • Acute neurological illness • Acute vomiting and/or diarrhea • Death in the emergency room • Febrile illness with flu-like symptoms • Febrile illness with flu-like symptoms and rash • Pneumonia • Septicemia of unknown etiology • Other syndromes as defined by the Commissioner
Syndromic surveillance and electronic laboratory reporting (64-7-10) • When certified as operational by the Commissioner, laboratories with automatic reporting capability will report positive results daily, including • Patient name, address, telephone number, date of birth, sex • Submitter • Specimen source, date of collection, date of result • Test name, result, normal value or range • Laboratory name, address, phone and fax
Syndromic surveillance and electronic laboratory reporting (64-7-10) • When certified … laboratories with automatic reporting capability will report … additional conditions including: • Adenovirus • Enterovirus • Influenza • RSV • Rotavirus
Submission of Laboratory Specimens to Office of Laboratory Services:Isolates (12.2.b.1) • Bacillus anthracis • Clostridium botulinum • Corynebacterium diphtheriae • Tularemia • Salmonella • Shigella • Campylobacter
Submission of Laboratory Specimens to Office of Laboratory Services:Isolates (12.2.b.1) (2) • Listeria monocytogenes • Suspect or confirmed ETEC • Yersinia pestis • From a sterile site: • N meningitidis • S pneumoniae • Haemophilus influenzae • Other isolates as determined by the Commissioner
Submission of Virological, serological, EM , molecular samples … (12.2.b.2.G) • LaCrosse, West Nile, Eastern equine, St Louis encephalitis viruses • Orthopox virus • Poliomyelitis • Rabies • Rubella • Rubeola • SARS • Other specimens as determined by the Commissioner • Novel influenza virus
FAQ # 1 ‘I’m not sure I have jurisdiction…’ • For local health departments, jurisdiction = • Your county • Schools, camps, vessels and department-operated health care facilities are required to: • Report …. 64-7-12.3.a.1 • Assist with investigation …. 64-7-12.3.a.2 • Follow methods of control … 64-7-12.3.a.2
FAQ # 2‘Dr. C wants written permission from the patient to report…’ • Pg 17: …Providers and … facilities … shall: • Report …. 64-7-12.1.a.1 • Assist … in … investigation 64-7-12.1.a.2 • Submit specimens … 64-7-12.1.a.3 • HIPAA letter • http://www.wvdhhr.org/idep/PDFs/IDEP/HIPPA_Letter_11-05.pdf
FAQ # 3‘… I need to rule out this case, but negative results aren’t reportable ….’ • … Providers and … facilities … shall • ‘assist the … local health officer in ruling out previously reported cases … by submitting copies of negative laboratory tests … 16-7-12.1.a.7
FAQ # 4‘ … Dr. B won’t help me with contact investigation …’ • Pg 17-18: Health care providers and … facilities … shall … • Assist … in any necessary contact investigation … 64-7-12.1.a.2 • … advise … the patient … members of the patient’s household and other patient contacts …64-7-12.1.a.4 • Follow a method of control specified by the commissioner in established protocols … 64-7-12.1.a.5 • Assist … the local health officer by promoting implementation of the control method … specified in the protocol … 64-7-12.1.a.6
FAQ # 5“Dr. A won’t report.’ • If … a … provider,… facility, laboratory … failed to report … the local health officer … shall request an explanation …64-7-14.6 • The local health officer shall report to the commissioner the … provider, … facility, laboratory … and his or her reason for failure to comply … 64-7-14.7 • (Call us first)
FAQ # 6‘Attorney X is requesting a disease report – can I give it to him?’ • Pg 21: … the local health officer may release confidential information … to: • The patient 64-7-18.2.a • The patient’s physician …. 64-7-18.2.d • Any individual with the written consent of the patient and of all other individuals identified …64-7-18.2.e
Limitations • Isolation and quarantine • Operational plans require court orders • Owned dog, cat or ferret: • Only option: ‘… shall direct owner to confine …’ 64-7.5.3 • Keeping the rule up to date … Commissioner … • … may…add or delete a disease or condition … 64-7-3.1.a • … may require same day reporting …
Strengths of the Rule • Clear responsibilities for providers, laboratories, health officials, schools, vessels… • Reporting • Investigating • Outbreak investigation • Contact investigation • Surveillance evaluation and special studies • Confidentiality • Electronic reporting
Strengths of the Rule • Reportable Disease Protocol Manual • The commissioner shall establish specific protocols …64-7-3.2.a • … providers and … facilities … 64-7-12.1.a.5 • … laboratories …64-7-12.2.b.1 • … local health officers … 64-7-14.3.a and 64-7-14.3.b • … schools, camps, vessels, and department-operated health care facilities …. 64-7-12.3.a.3
Myth:‘… I don’t have the authority to ...’ • 64-7-14 Responsibilities of Local Health Officers: • Comply with rule • Maintain records • Investigate/collect specimens/manage contacts/report to BPH • Reportable disease protocol manual • Consultation with the Commissioner • Investigate providers who don’t report
Always … advise appropriately and document… You (the local health officer) can have tremendous influence (authority) in your jurisdiction …
Conference Call on the Reportable Disease Rule and WVEDSS • WHO: Local Health Departments, Hospital Infection Control Professionals, Hospital Laboratory Directors • WHEN: Wednesday, May 30 and Friday, June 8, 2007; 12:00 to 1:30 PM • HOW: dial 1-888-819-5079; passcode = 586900 • CAUTION: Only 125 lines each call