New HIV Infection Reporting Requirements

The regulations basically add HIV infection to the list of reportable diseases, but procedures are distinctly different: Patient identification information must be encoded — hence the new “non-names reporting.”

The reporting requirement applies to a variety of laboratory tests which, when positive, identify the presence of human immunodeficiency virus (HIV). These include HIV antibody, HIV p-24 antigen, Western blot, immunofluorescence antibody tests, and tests that detect HIV nucleic acid.

Generating the non-name code is a cooperative effort involving the clinical laboratory and healthcare provider. The majority of the encoding is done by the laboratory, but the healthcare provider must make certain that specific information is submitted on the laboratory requisition requesting the HIV test.

Necessary elements include the patient’s surname (used to generate the Soundex code); the patient’s date of birth (mm/dd/yyyy); the patient’s gender (male, female, male-to-female transgender, female-to-male transgender); the date the biological specimen was collected; the name, address and telephone number of the health care provider; and the facility where services were rendered.

If the test is positive, the laboratory creates a “partial non-name code” and affixes it to the laboratory report returned to the clinician’s office. The physician’s office finalizes the non-name code by adding the last four digits of the social security number.

The healthcare provider then completes an HIV/AIDS Case Report form. Unlike procedures for other reportable diseases, these forms are to be sent to the health officer of the county in which the health care provider facility is located.

There are two HIV/AIDS case report forms — one for children under age 13 and the other for persons age 13 and older; both forms can be obtained from local health departments. Only one case report form needs to be completed for each patient newly diagnosed with HIV.

The case report form must be submitted to the health officer of the county in which the health care provider facility is located within seven calendar days of receiving a patient’s confirmed HIV test and partial non-name code from a laboratory.

Laboratories are required to report to health departments all positive laboratory tests that detect the presence of HIV, each time that they are done. It is the responsibility of local health departments to sort out the data and eliminate duplications. To do this, health department staff may need the assistance of healthcare providers.

To that end, healthcare providers must maintain a system that cross-references patient data — either by using the partial non-name code (as generated by the laboratory) or the complete non-name code (as finalized by the healthcare provider).

It is recommended that healthcare providers maintain a log that lists patient name, date of HIV test, non-name code, and when a case report was submitted the county. This information must be secured to protect confidentiality, and its only valid purpose is to exchange information with the local health officer or authorized designee to complete or “unduplicate” the HIV case reports.

Keep in mind that reporting HIV infection does not eliminate the need to report AIDS cases. Whether upon initial presentation or after progression from a known HIV infection, an AIDS case should be reported as usual, using standard patient identification information, to the county in which the patient lives.

HIV non-name reporting will be a new experience for healthcare providers, laboratories and public health departments. In the long run, the information will benefit health education and treatment programs.

Sacramento County Department of Health and Human Services Epidemiology and Disease Control staff stands ready to be of assistance to healthcare providers and laboratories.

For questions, call Sacramento County Department of Health and Human Services Epidemiology and Disease Control at (916) 875-5881 or visit the web site at http://www.sacdhhs.com.

TaitKa@SacCounty.net