Background: An infection control (IC) surveillance program for smaller (<100 acute beds) hospitals was piloted for 18 weeks in 14 hospitals. The aim of the pilot stage was to test a theoretical program in the context in which it was to be implemented. Method: An evaluation framework was developed, outlining the program's intended activities for data collection, management, analysis, reporting, and use. This framework was used as a reference to interview each of the 12 IC nurses participating in the pilot stage. Results: The preferred case finding methodologies were not uniformly applied. Management, analysis, and reporting of data were delayed because of infrequent and irregular IC hours and laboratory reporting. Reports were not always distributed to key persons. Specific action was only taken in response to the process (and not outcome) module reports. Conclusion: Discrepancies between the theoretical and actual implementation of a surveillance program for smaller hospitals were highlighted. The program will need to be revised before it is rolled out to all 89 eligible hospitals across Victoria.