# The new reporting obligation for Respiratory Syncytial Virus (RSV) in Germany – a critical view

## TL;DR

Germany introduced mandatory RSV reporting in 2023, but the paper argues it is unnecessary and could overburden health authorities.

## Contribution

The paper critically evaluates the new RSV reporting obligation in Germany using existing data and legal frameworks.

## Key findings

- Mandatory RSV reporting could generate over 100,000 annual reports, exceeding combined reports of rota and noroviruses.
- EU Commission and ECDC do not recommend mandatory RSV reporting, and it is legally questionable.
- Wastewater sentinels offer a better alternative for monitoring RSV without overburdening health authorities.

## Abstract

In summer 2023, mandatory reporting of respiratory syncytial virus (RSV) by name was introduced in Germany. The stated objectives were:

to improve the database to prevent overburdening of the healthcare system, to implement targeted, early investigation and action by local health authorities to prevent further spread, and to assess vaccines after the expected approval of RSV vaccination.

to improve the database to prevent overburdening of the healthcare system,

to implement targeted, early investigation and action by local health authorities to prevent further spread, and

to assess vaccines after the expected approval of RSV vaccination.

These objectives are examined against the background of data from mandatory reporting of RSV in the German federal state of Saxony, which has been required since 2002, and the data from the ARE (acute respiratory diseases) survey in Germany, considering

the basic legal requirements and options of the Infection Protection Act, the requirements of the EU Commission for the collection of data on infectious diseases and the recommendations by experts of the European Centre for Disease Prevention and Control (ECDC), the options for individual or general preventive measures by the health authorities and previous experience with the evaluation options of the reported data (especially regarding the effectiveness of vaccinations).

the basic legal requirements and options of the Infection Protection Act,

the requirements of the EU Commission for the collection of data on infectious diseases and the recommendations by experts of the European Centre for Disease Prevention and Control (ECDC),

the options for individual or general preventive measures by the health authorities and

previous experience with the evaluation options of the reported data (especially regarding the effectiveness of vaccinations).

An extrapolation of the previously reported data from Saxony to the whole of Germany shows that over 100,000 reports per year must be expected (more than the reports of both rota and noroviruses together). Neither the requirements of the EU Commission nor the views of an expert group of the ECDC recommend mandatory RSV reporting. Mandatory reporting by name is also not appropriate from a legal perspective. A sentinel, which is also better suited to assessing vaccinations, would be more appropriate to avoid unnecessarily overburdening the health authorities. In addition, initial experience with wastewater sentinels for RSV has shown that they may be used to record local and regional RSV infections – albeit without information on the severity of the disease and thus the burden on the healthcare system.

Against this background, mandatory reporting of RSV does not appear to be appropriate. Instead, the existing sentinels should be continued and further expanded, possibly supplemented by RSV wastewater monitoring.