Ms. Genevieve Raganelli, Regulatory Officer
Deputy Administrative Practice Officer
Office of Legal and Regulatory Compliance
Office of the Commissioner
New Jersey Department of Health
PO Box 360
Trenton, New Jersey 08625-0360

Re: Proposal Number PRN 2017-106

Proposed New Rule N.J.A.C. 8:43G-14.9 Hospital Licensing Standards, Infection Control: Sepsis Protocols

Dear Ms. Raganelli:

The Association for Professionals in Infection Control and Epidemiology, Inc. of Northern New Jersey (APIC NNJ) appreciates the opportunity to provide comments concerning the Department of Health’s (“DOH”) proposed new rule to the Hospital Licensing Standard implementing Sepsis Protocols. 

APIC NNJ is a member organization with over 200 active members largely consisting of Infection Preventionists, many of whom are board certified in the field of infection prevention and epidemiology. APIC NNJ is active in collaborating with health and other regulatory agencies, licensed independent practitioners and other health associations not only to improve but also to shape infection prevention standards that are guided by scientifically proven, evidence-based practices. Many APIC NNJ members are active participants in their respective organization’s sepsis quality improvement efforts, providing consultation and expert guidance.

While APIC NNJ does support the best practices of hospitals having robust sepsis screening, treatment protocols, staff training and quality improvement programs; we feel strongly that the development, implementation, and monitoring of such programs must be handled with a multidisciplinary approach. This approach should include at minimum nursing, medicine, pharmacy, laboratory, staff development and continuous quality monitoring under the direction of Quality Improvement staff, with consultation and expert guidance provided by Infection Control as required.

Therefore, APIC NNJ opposes the proposed regulation being included in the Hospital Licensing Standard Subchapter 14 Infection Control, as this places the responsibility of the regulation under the Infection Control Program. We recommend that the oversight of this regulation and its proposed requirements be assigned to the Subchapter 27 Continuous Quality Improvement, allowing for a multidisciplinary approach to implementation and monitoring.

Thank you for this opportunity to comment on this rule proposal. If you have any questions regarding our comments, please do not hesitate to contact me.

Sincerely,

Sharon Parrillo, BSN RN CIC
APIC NNJ President 2017
Assistant Director, Infection Prevention
Robert Wood Johnson University Hospital Somerset
110 Rehill Avenue, Somerville, NJ 08876
sharon.parrillo@rwjbh.org
908-243-8646