By Lambert Strether of Corrente.
For readers who don’t know what HICPAC (Healthcare Infection Control and Prevention Advisory Committee) is, we’ll get to that in Part 1 below. With the principle of Stafford Beers that “The purpose of the program is what it does,” the purpose of HICPAC is to infect patients in hospitals and nursing homes with Covid and other airborne diseases by creating CDC (Centers for Disease Control) guidance that does not require universal. hiding the face, and denying the fact of the transfer of the plane in the air.
Here is our post on the first WHN (World Health Network) complaint. WHN’s newly filed Supplemental Complaint adds these four additional points:
1. Illegally Formed HICPAC Membership
2. Conflicts of Interest Among HICPAC Members
3. Failure to Cope with Airlift
4. Confidential Proceedings of the FACA Violation Task Force
In this short message, I will look at all four points of the complaint, but I will quote some things from NC’s HICPAC posts, because – here lambert preens – I was told on good authority that they should give the WHN lawyers something fruitful. opinions. So to point 1.
1. Illegally Formed HICPAC Membership
For those who arrived late, I promised to explain more about HICPAC in one place, so let me quote from a previous post:
The CDC describes HICPAC and its mandate as follows:
HICPAC is a federal advisory committee appointed to provide advice and guidance to DHHS and CDC regarding infection control practice and strategies for the surveillance, prevention, and control of healthcare-associated infections, antimicrobial resistance and related events in United States healthcare settings.
Here is the structure of HICPAC, from the CDC’s About page:
HICPAC has 14 voting members who are not employees of the organization. These experts are appointed by the Secretary of HHS following an application and nomination process. HICPAC voting members bring expertise including, but not limited to, infectious diseases, infection prevention and control, health care epidemiology, nursing, clinical and environmental microbiology, surgery, hospital medicine, internal medicine, epidemiology, health policy, research of health services, public health, and related medical fields.
HICPAC also includes six ex officio members representing federal agencies within HHS, as well as liaison representatives who bring relevant patient safety expertise from health-related organizations, consumer groups, community organizations, and partners. These ex-officio members and liaison representatives are included in the HICPAC charter, which is renewed annually by HHS. Ex officio representatives and consultants are non-voting members of HICPAC.
The “allied medical fields” do a lot of work there. Since airborne transmission and its prevention are fundamentally engineering problems, some may find it surprising – since #CovidIsAirborne – that there are no aerosol scientists or ventilation engineers on the Committee. Then again, if we look at HICPAC as the highest expression of the Infection Control hive mind, we might not find it so surprising.
Note in particular the requirement of 14 voting members. From the Supplementary Complaint, page 1:
The HICPAC Charter requires that the committee be composed of 14 members. This violation of its Charter was brought to the attention of the Inspector General in the WHN Chief Complaint. However, on August 22, 2024, HICPAC had a meeting with only 11 members. This action by HICPAC shows that it is ignoring its charter and the Inspector General’s authority to enforce it. From the time of WHN’s first complaint until today, HICPAC has been an informally constituted committee with no legal validity or enforcement.
Good, since if the Inspector General finds WHN, that would prevent HICPAC from fulfilling its Beersian mission of infecting patients.
2. Conflicts of Interest Among HICPAC Members
This content begins on page 2 of the supplemental complaint. I’m going to rearrange it a bit, to gently place the gauntlet on the table (“A”) by throwing it down (“C”). Also, I need to explain FACA (Federal Advisory Committee Act). I wrote in this post:
HICPAC meetings are held, the CDC said, under the Federal Advisory Committee Act (FACA), as described by the Congressional Research Service (CRO):
Federal advisory committees are created by Congress, the President, and executive branch agencies to obtain expertise and policy advice from individuals outside the federal government. Most federal advisory committees are governed by the Federal Advisory Committee Act (FACA; 5 USC Chapter 10), which includes formal meeting and transparency requirements. The Office of the Secretary of Committee Management (hereinafter the “”Secretary”)” of the General Services Administration (GSA) is responsible for matters related to advisory committees under FACA. In the final rule, GSA stated [w]Although FACA is not a public participation law, it directly affects the executive branch’s accountability for the use and management of Federal advisory committees as a major means of obtaining public participation…..
I followed what I thought was a jugular, open meeting violation, but WHN is now gone what indeed jugular: Following the money.
A. Financial Relations. WHN writes:
An important principle of FACA is that the staff of the advised agency (in this case, the CDC) are not allowed to be members of the committee because of the nature of the financial relationship that may prevent independence. Although funding is not strictly prohibited, it is clear that conflicts of interest must be avoided.
Financial relationships between the institution and individual members such as the one that currently exists between the CDC and all HICPAC committee members pose a serious risk that includes the independence of their decision. This is not only because income links can influence certain decisions, but also because .
To put it bluntly, if the CDC handwashing desk writes your HICPAC check, it’s unlikely you’ll give it the attention it deserves.
B. Competition for Funding and Competing Siloes. WHN writes:
In addition, HICPAC members, are recognized for their expertise in areas such as blood-borne infections, sepsis, acute injuries, hand hygiene, fomite transmission, sterilization and disinfection, antimicrobial resistance, and Ebola, . This creates a conflict of interest that may interfere with the decision to shift the focus from infection prevention to airborne diseases, which is needed to effectively address hospital-based transmission of COVID-19. [IPC]and his colleagues. This natural tension is compounded by common conflicts of interest among CDC officials responsible for appointing HICPAC members and setting the committee’s agenda, including current and former Federal Officers of HICPAC and the director of NCEZID.
I don’t know anyone who has a problem with the threatening IPC. Is it? (And if these two sections make HICPAC and CDC look like a self-serving pit, well, it looks like they are. It would also be interesting to know if the CDC Foundation is involved in this “natural conflict” at all. .)
C. Perverse Incentives in Hospital-Acquired Fee-for-Service Programs. WHN writes:
The mandate of the HICPAC Chair provides guidance on the “prevention, and control of healthcare-associated infections” Therefore, committee members who are compensated for promoting the spread of infection (or are compensated through ignorance or willful ignorance of the science of infection control in the healthcare setting), conflict with the interests and purpose of HICPAC.
Specifically, it is clear that direct payment systems can lead to counterproductive benefits in preventing hospital-acquired infections (HAIs). In fee-for-service payment models, hospitals are reimbursed for services provided, including treatment of HAIs. In such a system, hospitals can generate more revenue by providing more care to treat these diseases, rather than preventing them in the first place.
No matter how hard I try, I can never be sarcastic enough. The best financial incentives I could find are valuable; don’t want to spend money on respirators instead of cheap baggy blues; not wanting to release HEPA air filtration systems. It has not happened that the hospital is not motivated to treat patients, and therefore masked and non-pharmacological interventions of all kinds may face institutional resistance, but the concept is clear.
3. Failure to Cope with Airlift
From page 4:
As presented in the Basic Complaint, the COVID-19 pandemic and the continued presence of COVID-19 in the United States have increased the urgency of understanding airborne transmission of infection in health care settings. In fact, in 2024, the CDC confirmed the atmospheric condition for the transmission of COVID-19. However, despite having three vacancies, HICPAC continues to fail to field experienced members.
Instead of properly adding Members to HICPAC – that is, people who can vote on the Directive, this is what HICPAC does instead:
4. Confidential proceedings of the FACA Violation Task Force
HICPAC has established a “working group,” with no voting power, that meets in private. From page 3:
HICPAC convened an Isolation Precautions Guideline Workgroup to examine the issue of airborne transmission of infection in health care settings. However, the operation of this Working Group is not open to the public contrary to 5 USC App. § 10(a)(1) [FACA]where the exception to the meetings being open to the public under 5 USC App. § 10(d) does not apply.
The composition of the Workgroup emphasizes that the current members of HICPAC do not have the necessary expertise to decide on air transfers in health care settings. Although HICPAC, in direct violation of its Charter, still has three vacancies, and the Workgroup has qualified experts on air transport, rather than bringing the committee into compliance with the law, it decided instead to establish a Working Group with these experts. We submit that this act of creating a public Workgroup can be interpreted as a strategy of HICPAC to avoid having serious and potentially controversial debates brought to the attention of the public. WHN submits that HICPAC should focus on filling its remaining vacancies [on the Committee proper] and experienced airfreight specialists.
The conclusion
It is hard to see why the CDC and HICPAC are acting this way. It’s almost like they’re hiding somethingMR SUBLIMINAL Ka-ching! Bodies piled high?
ATTACHMENT: WHN Supplementary Complaint
Here’s an Additional Appeal:
Addendum-Appeal-HICPAC-23.10.2024-Final
Here are the Supporting Materials for the Additional Complaint:
Materials-Support-Appeal-HICPAC-23.10.2024
Congratulations to WHTN on a job well done.
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