Public Comment to Medicare: Support Universal Masking and Monitoring of Healthcare-Acquired Infections
Centers for Medicare and Medicaid Services public comment closes June 9
Below is my public comment submitted to the Centers for Medicare and Medicaid services in support of universal masking as well as monitoring of healthcare-acquired COVID infections. Public comment closes on June 9 at 11:59pm Eastern time. The People’s CDC has great resources to help you make a comment.
After June 9, you can still take action by asking your senators to ask CMS for these protections.
I am a physician (pathologist) as well as a patient myself and a family member of multiple high risk and immunocompromised people. Now that most healthcare systems, including all of the healthcare systems in my city, Madison, Wisconsin, have dropped universal masking, there is no longer any safe way to access care. Since February 2022, I have been unable to safely work in a hospital environment as masking was dropped in pathology and laboratory areas. Now, masking has been dropped in most patient care areas as well. Patients are delaying necessary care due to the risk of COVID exposure in these settings. As a pathologist, I am highly concerned that we will see an ongoing delay of care will worsen delays in cancer screenings [1] and other preventative care, which may lead to increased cancer rates for years to come.
We need CMS to provide rules, incentives, and penalties to improve basic patient and worker safety through universal masking and stopping COVID transmission in healthcare settings.
It is now well-established that COVID is a systemic disease that spreads through the air. These aerosols are generated by breathing or talking - no specific “aerosol generating procedures” are needed for COVID transmission. Vaccination reduces but does not eliminate the risk of severe acute disease and long COVID. Rates of long COVID are estimated to be about 10% [2], leaving millions impacted. Repeated infections further increase the risk of organ system damage [3] and long COVID [2].
Patients deserve access to safe care that will not unnecessarily expose them to infectious diseases. Universal masking, ideally with N95 respirators, is a new addition to universal precautions that improves our standards of care [4]. We must not lose ground on this important advancement and allow biased ways of thinking to cloud our judgement around patient safety and providing quality healthcare. Just as CMS provides important standards and programs for hand hygiene, glove use, and sterile technique to prevent healthcare-acquired infections such as surgical site infections and C. difficile, you must institute standards and support for universal masking in healthcare as well as monitoring for healthcare-acquired COVID infections.
Many healthcare workers are not informed about the risks of repeated COVID infections, and the cumulative impact of repeat infections will only worsen severe staffing shortages impacting every area of medicine. I am director of a laboratory medical professional training program in cytotechnology, and we anticipate hundreds of unfilled vacancies in our small field over the next several years. We cannot afford to face further staffing issues due to acute illness and long COVID due to unnecessary workplace exposures. Effective education about COVID transmission and risks of infection must be a part of any effective program to stop healthcare-acquired COVID infection and should be incorporated into mandatory safety and infection control training, with CMS support.
The end of the federal public health emergency unfortunately does not mean the end of COVID’s impact on our lives. COVID continues to be a leading cause of death [5] and life expectancy has dropped with a widening gap between the United States and other similarly-resourced countries [6]. This is a key moment to build on, rather than disregard, the lessons we have learned from the ongoing pandemic.
Please protect patients, healthcare workers, and our healthcare system quality and capacity by creating standards that support universal masking in healthcare and by requiring monitoring for COVID as a healthcare-acquired infection.
References
Mast C, Deckert J, Muñoz del Río A. Troubling Cancer Screening Rates Still Seen Nearly Two Years Into the Pandemic. Epic Research. Accessed May 13, 2022. https://epicresearch.org/articles/troubling-cancer-screening-rates-still-seen-nearly-two-years-into-the-pandemic
Thaweethai T, Jolley SE, Karlson EW, et al. Development of a Definition of Postacute Sequelae of SARS-CoV-2 Infection. JAMA. Published online May 25, 2023. doi:10.1001/jama.2023.8823
Bowe B, Xie Y, Al-Aly Z. Acute and postacute sequelae associated with SARS-CoV-2 reinfection. Nat Med. 2022;28(11):2398-2405. doi:10.1038/s41591-022-02051-3
Kalu IC, Henderson DK, Weber DJ, Haessler S. Back to the future: Redefining “universal precautions” to include masking for all patient encounters. Infect Control Hosp Epidemiol. Published online February 10, 2023:1-2. doi:10.1017/ice.2023.2
McPhillips D. Covid-19 was the fourth leading cause of death in 2022, CDC data shows. CNN. Published May 4, 2023. Accessed June 7, 2023. https://www.cnn.com/2023/05/04/health/covid-fourth-leading-cause-of-death/index.html
McPhillips D. US has been falling behind on life expectancy for decades, study shows. CNN. Published June 1, 2023. Accessed June 7, 2023. https://www.cnn.com/2023/06/01/health/us-life-expectancy-lagging/index.html