In a letter recently submitted to the Secretary of the Department of Health and Human Services, the IAFC advocated that the Centers for Disease Control and Prevention be authorized to act as the enforcement agency for the regulations contained in Part G, Notification of Possible Exposure to Infectious Diseases, of the Ryan White HIV/AIDS Treatment Extension Act of 2009 (RWA).
Although this regulation has been on the books since 2009, no agency is currently identified to enforce compliance for Part G. Why is this important? Because it’s directly related to taking care of our own.
Soon after I accepted my current position, which came with the duty of infection-control officer, a firefighter walked into my office first thing one morning. He looked at me and said, “I got stuck last night.”
Of course he was referring to an exposure injury from a contaminated needle. His face expressed the anxiety I know he felt. He asked, “What do I do?”
I looked at him blankly, not knowing what to say or do next. After getting his story, I sent him to our occupational medicine physician. That’s it; it’s all I had. It troubled me terribly and drove me to find out how to take care of our own.
What’s driving the IAFC’s backing of the appointment of an enforcement agency is primarily noncompliance by receiving facilities with regard to the timely (48 hours max) notification to first responders that they’ve been exposed to a communicable disease.
Notification occurs in two ways, and both are made though each agency’s designated officer (DO), also required in the RWA.
The first way, notification from a first responder to the receiving facility, occurs when a first responder is exposed to a patient’s bodily fluids in the field. Once the patient is transported to a receiving facility, the RWA provides a process by which source-patient testing can be conducted at the request of the DO. Once the disease status of the patient is known and communicated to the first responder and treating physician via the DO, decisions can be made regarding the treatment of the exposed first responder.
The other way, notification from a receiving facility to the first responder, occurs when a patient at a receiving facility is diagnosed with a communicable disease identified in the in the RWA. Notification must be made by the receiving facility to first responders who had contact with that patient.
Much of the hesitation by receiving facilities to comply with the RWA is embedded in the fear of releasing confidential patient information. What’s the common denominator in these processes? Relationships and communication.
A receiving facility’s internal procedures for taking care of their own have been in place for a long time—notification, source-patient testing and infection-control officers—all of which ensure excellent exposure management for their healthcare workers.
That’s what RWA does for first responders, but for RWA to work, we need the resources of the receiving facilities.
The key to compliance is establishing and maintaining relationships and communication with receiving facilities in your community and your state’s department of health. This takes continual time and effort. Bring the human element to the table; it’s not the hospital that is essential to the processes; it’s the hospital’s charge nurses, ER director, infection-control officers, billing clerks, ER physicians and nurses.
It’s through these relationships that we’ll cultivate their commitment to our first responders and not just compliance to a law.
So while the IAFC is promoting the appointment of an enforcement agency to help with compliance, do your part: establish and nurture your relationships with the people and make Ryan White’s legacy work for your first responders.