final signed memo

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Office of the Secretary

DEPARTMENT OF HEALTH & HUMAN SERVICES

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Assistant Secretary for
Preparedness & Response
Washington , D.C. 20201

DATE:

December 10, 2021

TO:

Andrea Palm, Deputy Secretary

THROUGH:

Dawn O' Connell,
Assistant Secretary for Preparedness and Response
Michael Wilkening, Senior Advisor for Technology and Delivery

FROM:

AJ Pearlman, Chief of Staff, COVID-19 Response

SUBJECT:

Unified Hospital Data Surveillance System for COVID-19 Reporting
Changes - UPDATED DECISION

ACTION REQUESTED
The purpose of this memorandum is to update a September 23 , 2021 decision memorandum that
was signed on November 9, 2021 (Subject: Unified Hospital Data Surveillance System for
COVID-19 Reporting Changes; see Attachment). The previous memorandum was signed with an
amendment to hold on a decision related to removing or making optional approximately 50 data
reporting elements collected through the Unified Hospital Data Surveillance System (UHDSS).
This memorandum requests removing or making optional many of these data reporting elements,
with several exceptions. By removing or making optional data elements that have been found to
be duplicative or are no longer needed to inform response activities, HHS is responding to
stakeholders (including hospitals, the health information technology sector, and state, local,
Tribal, and territorial organizations) who have provided consistent feedback to reduce reporting
burden on hospitals.

SUMMARY
HHS collects COVID-19 data from hospitals as instructed by the Centers for Medicare &
Medicaid Services (85 FR 54820; 85 FR 85866). Reporting guidance is posted on the HHS
website (https ://www.hhs.gov/sites/defau lt/fi les/cov id- I 9-fags-hospitals-hospital-laboratoryacute-care-faci lity-data-reporting.pdf).
A September 23, 2021 memorandum (Attachment) approved revision of the UHDSS guidance to
add several data elements, including required reporting of more detailed daily pediatric hospital
data; daily seasonal influenza data; and weekly sotrovimab therapeutic data. A recommendation
in the memorandum to remove or make optional approximately 50 data reporting elements was
put on hold, pending further discussion.

'The guidance can be found at https://www.cms.gov/files/document/qso-21-03 -hospitalscahs.pdf-O

Unified Hospital Data Surveillance System for COVID-19 Reporting Changes - DECISION
Page 2

Based on discussions that have occurred between the Deputy Secretary's office, ASPR, CDC,
OCIO, CMS, and the White House COVID team, we now recommend removing or making
optional data reporting elements, with the exception of vaccination-related questions and
questions involving suspected COVID-19 patients. We will retain vaccine-related questions
because of feedback from several Operating and Staff Divisions regarding the current continued
usefulness of these voluntary data elements in informing the response. Further, we have received
feedback from external stakeholders that data on suspected cases of COVID-19 continue to be
useful.
We summarize the new recommendations regarding removing or making data elements optional
in the following Appendix. These recommendations are the same those in Appendix B of the
September 23 memorandum; however, reporting of healthcare personnel vaccination and
suspected COVID-19 data elements will continue. By removing or making optional data
elements that have been found to be duplicative or are not further needed to inform response
activities, HHS is being responsive to stakeholders who have provided consistent feedback to
reduce reporting burden on hospitals.
The decision regarding continued reporting of healthcare personnel vaccination and suspected
COVID-19 cases can be revisited in the future as the situation evolves. We do not believe the
emergence of the Omicron variant affects the data reporting recommendations provided in this
decision memo.
RECOMMENDATION
We recommend approval of the following data element changes to the UHDSS:
• Remove/make optional data reporting elements as delineated in the attached Appendix
(same recommendation as in the September 23, 2021 memorandum, with the exception
that reporting of vaccination of healthcare personnel vaccination and suspected COVID19 patients data elements will continue).
Amanda J.
Pearlman -5

Digitallysignedby Amanda J.
Pearlman -$
Date: 2021 .12.10 16:06:23 -05'00'

AJ Pearlman, Chief of Staff, COVID-19 Response

DECISION
Implement Proposed Reporting Changes as noted in the Decision Memorandum above.

DEC 2 0 2021
Date
2

Unified Hospital Data Surveillance System for COVID-19 Reporting Changes - DECISION
Page 3

Appendix
Recommended Changes in Data Reporting Elements
Unified Hospital Data Surveillance System
Field
Capacity
All hospital beds
All adult hospital beds

Ventilators
Total mechanical
ventilators
Mechanical ventilators
muse

Current

Aeency Proposal

Rationale

DailyMake inactive
Mandatory
DailyMake inactive
Mandatory

This information is
not needed at this
time and is not
anticipated to be
needed. These
values are not
incorporated into
analysis. Hospital
beds do not indicate
healthcare facility
burden. The
inpatient beds fields
(that are being
maintained) are used
as denominators for
occupancy metrics.

DailyMake inactive
Mandatory
DailyMake inactive
Mandatory

Per the Supply
Chain Logistics
Operations Cell
(which includes the
Strategic National
Stockpile) and
Supply Chain
Control this
information is not
used for planning or
operational
purposes.
Ventilators can only
be deployed when a
request is received
from the state. The
Strategic National
Stockpile has
significantly
increased the
number of
ventilators available,
and can deploy them
3

Unified Hospital Data Surveillance System for COVID-19 Reporting Changes - DECISION
Page4

rapidly where
needed. The
numbers reported
here can be
significantly
misleading because
if the facility is part
of a hospital system,
the hospital can
surge their own
ventilators to the
site. States also
often have
additional
ventilators available
through individual
stockpiles.
Hospital Onset, ED, & Deaths
DailyED overflow
Mandatory
DailyED overflow &
ventilated
Mandatory

Previous day's COVID19 deaths

DailyMandatory

Make inactive
Make inactive

Make inactive

This information is
not needed at this
time and is not
anticipated to be
needed. Staffing
continues to be one
of the largest
constraining factors.
Fields on ED visits
and COVID-19 ED
visits are tracked
and are being
maintained in the
collection.
Mortality data at the
Federal level are
collected by the
CDC National
Center for Health
Statistics in the Vital
Statistics System.
These are the
official numbers of
COVID-19 deaths
that are reported by
the government.
When additional
analysis is
4

Unified Hospital Data Surveillance System for COVID-19 Reporting Changes - DECISION
Page 5

conducted on
COVID-19 deaths,
line-level data is
used to identify
factors such as preexisting conditions,
age, etc. This field is
not being used for
analysis.
Staffine:
Critical staffing
shortage today

Critical staffing
shortage anticipated
within a week

Supplies
Are your PPE supply
items managed at a
facility level or health
system level

On hand supply (days)
• Ventilator supplies

DailyOptional

Make inactive

DailyOptional

Weekly - Optional

Weekly Mandatory

Make inactive

Weekly By field:
Mandatory

Staffing shortage
data are not
changing
significantly on a
daily basis
This question serves
as the only indicator
of facilities' staffing
needs. The ESF8
council has
previously requested
information on
staffing to help
inform decisions
related to requests
for personnel.
Collecting once
weekly will still
allow data
collection, but
reduce reporting
burden. Notably,
staffing can also be
inferred from the
number of staffed
beds.
This information
does not regularly
change and is not
needed to inform
action, decision
making, and/or
surveillance.
Based on input from
the Supply Chain
5

Unified Hospital Data Surveillance System for COVID-19 Reporting Changes - DECISION
Page 6

•

•

N95 respirators
• Surgical &
procedural masks
• Eye protection
• Gowns
Exam gloves

Ventilator supplies Make inactive

Eaches on hand
(various products)

Weekly Optional

Make inactive

Ability to obtain
(various products)

WeeklyMandatory

Make inactive

Ability to maintain 3day supply

Weekly Mandatory

By field:

Control Tower
(SCCT) and Supply
Chain Logistics
Operations Cell
(SCLOC),
current/anticipated
future operational
and reporting needs
focus on PPE only.
Additionally, the
question is not
specific enough to
pinpoint specific
supply chain
challenges with
individual products
as multiple supplies
are included as part
of this broad
category.
Eaches fields
request the count of
individual product
available. Per the
SCCT and SCLOC,
eaches fields are not
needed to drive
operations analysis,
or planning.
Additionally, the
fields are
significantly
burdensome as they
often require manual
counts of each
individual product
throughout the
facility .
Per Supply Chain
leadership, "ability
to obtain" is no
longer an important
or relevant data
field.
Based on input from
the SCCT and
6

Unified Hospital Data Surveillance System for COVID-19 Reporting Changes- DECISION
Page 7

•
•
•

•
•
•
•
•
•
•

•

Ventilator supplies
N95 respirators
PAPRs/elastomerics
Surgical &
procedural masks
Eye protection
Gowns
Gloves
Nasal pharyngeal
swabs
Nasal swabs
Viral transport
media

•
•
•
•

Ventilator supplies:
Make inactive
PAPRs/elastomerics:
Make inactive
Nasal pharyngeal
swabs: Make
inactive
Nasal swabs: Make
inactive
Viral transport
media: Make
inactive

Re-use or extend PPE
(various products)

Weekly Optional

Make inactive

Critical issues outreach
(open-ended question)

Weekly Optional

Make inactive

SCLOC,
current/anticipated
future operational
and reporting needs
do not focus on
ventilator supplies,
PAPRs/elastomerics,
nasal pharyngeal
swabs, nasal swabs,
or viral transport
media. Ventilator
supplies are a broad
category and do not
pinpoint individual
product potential
challenges. Testing
groups across HHS
noted they also not
use the fields or see
them as beneficial.
Entities across HHS
have increased
relationships with
relevant distributors,
and in some cases
manufacturers, to
monitor additional
challenges. The
other supplies listed
are primary supply
chain fields to
continue to monitor.
Current/anticipated
future operational
and reporting needs
do not focus on
these items.
Open-ended
questions are more
burdensome, and
more difficult to
incorporate
consistently into
analvsis.

Influenza

7

Unified Hospital Data Surveillance System for COVID-19 Reporting Changes - DECISION
Page 8

Total hospitalized
patients co-infected
with both COVID-19 &
influenza (laboratory
confirmed)
Previous day' s
influenza deaths
Previous day's deaths
for patients co-infected
with both COVID-19 &
influenza

Therapeutics
Previous day' s
remdesivir used
Current inventory of
remdesivir

Therapeutic B on hand
Therapeutic B
administered last week

Daily Optional

Make inactive

DailyOptional
DailyOptional

Make inactive

DailyOptional
DailyOptional

Make inactive

Weekly Optional
Weekly Optional

Make inactive

Make inactive

Make inactive

Make inactive

Per the CDC
Influenza Division,
the influenza fields
becoming
mandatory (already
approved change)
are the most
informative for
surveillance
purposes. These
fields were not
considered to be
useful for tracking
or modeling
purposes.
Remdesivir is no
longer a constrained
resource nor is being
allocated,
distributed, and/or
paid for bv the USG
FDA revoked the
Emergency Use
Authorization for
bamlanivimab
adminstered alone
(Therapeutic B) on
April 16, 2021.

8