PRMR MUC List Commenting

The provision of high-quality malnutrition care is important for adults of all ages. Please consider expanding the GMCS to include all adults 18 years of age and older. We see malnourished adults under 65 years of age daily at our hospitals, and nutrition intervention is a key aspect of their care. Thank you.

Thank you for taking these comments.  

Please seriously consider expanding the Global Malnutrition Composite Score to all adults (18+ years and older).  Disease-related malnutrition is underrecognized and under-diagnosed now, and I have great hope that the GMCS will force attention so that early action and intervention to reduce the incidence, especially upstream before acute care admissions. As the data accumulates from acute care, and is reflected upon, it will be recognized that the condition often starts in ambulatory settings (and is then hopefully caught in acute care by the admission screening workflows and then picked up by the GMCS. 

My health systems background since 1975 intensely has been intensley focused on disease-related protein-calorie malnutrition, and the circumstances surrounding it. This condition is not a respecter of age and occurs at all ages and is a cause and a consequence of many diseases, and just gets worse and worse with aging. We need to know the volumes accurately so that it can be studied and medical professionals and the public are more aware of it and guided to early action to reduce this type of malnutrition and ideally make significant inroads to prevent it by early screening. For example, starting screening for seniors using the MNA-elderly at annual senior wellness visits and before major elective surgery is a big step in the right direction that will help prevent acute care malnutrition and hospital admissions, and expensive morbidities. We therefore need to know the incidence accurately in acute care for all ages, and the GMCS is a practical, doable approach that needs to be expanded to all adults, please.

 Because of the significant impact of malnutrition throughout the life cycle, a proposal for expansion of the GMCS to include all adults 18 years and older is necessary to provide high-quality malnutrition care for adults. 

People are often unaware that diet could help improve their medical condition or they are unsure how to implement nutritional components to their daily meal routine.  Dietitians are most helpful in looking at all aspects:  medical condition, labs, dentition, finances, abilities, etc. to help formulate a meal plan that will suit their needs and delay or abort the need for further medical interventions.

Dear Sir/Madam:

 The Global Malnutrition Composite Score (GMCS) is currently an electronic clinical quality measure, highlighting the value of providing high-quality malnutrition care for adults aged 65 and older. Because of the significant impact of malnutrition throughout the life cycle, please consider an expansion of the GMCS to include all adults 18 years and older on the MUC list for 2024.   Watching out for malnutrition across all ages from pregnancy to birth to death has always been part of regular nutrition care provided by registered dietitians.  Expanding this measure allows other health professionals to regularly monitor for it also across  all adults age 18 and above (until expanded for all ages that is) .  This is vitally important since often times ill patients see  the nurse and doctor first when seeking care.  RDNs will continue to provide this care across the lifespan, but by including this measure you support all health professionals  ability to find malnutrition early in all patients.  It is well known that better nutrition earlier in a hospitalization improves patient outcomes and decreases hospital stay days.

As  a dietitian who assists patients  with chronic disease management after discharge,  I have seen that all patients in better health , including nutrition health, continue to heal better and take better care of themselves after hospitalization.

Thank you for this serious consideration.

The Global Malnutrition Composite Score (GMCS) would be one of many essential quality measurement tools used help enhance nutrition support for malnourished patients and those at-risk of malnutrition. Applying this tool to all people over the age of 18 would help to provide better health outcomes for adults of all ages, and help practitioners understand the gaps of nutrition support for adults of all age groups.

Thee role of the R Register d d Dietitian  Nutritionist is vital to identifying and treating malnutrition in all  healthcare settings.  Please preserve the role of the RDN to ID:treat malnutrition. 

Be sure to include Registered Dietitians in this, and expand the patient population to anyone 18 years and older. 

Why only limit malnutrition diagnosis to 18 years and above? 

The Global Malnutrition Composite Score (GMCS) is currently an electronic clinical quality measure, highlighting the value of providing high-quality malnutrition care for adults aged 65 and older. Because of the significant impact of malnutrition throughout the life cycle, a proposal for expansion of the GMCS to include all adults 18 years and older has been included in the MUC List for 2024. While there are additional steps required prior to adoption of this expansion, inclusion on the MUC list is a critical step in advancing this initiative to improve the quality of care for those in the greatest need, those with malnutrition. In our great country, we should not have anyone suffering from malnutrition at any age.

Nutrition is an essential part of healthcare and when malnutrition is identified, patient outcomes are improved and hospital redadmits are reduced. Please expand the GMCS to include all adults 18 years and older in the MUC List for 2024.

Expanding applicability of the Global Malnutrition Composite Score from only 65 years and older to 18 years and older is appropriate and beneficial. Registered Dietitian Nutritionists (RDNs) are trained in identifying, treating and documenting malnutrition diagnoses in the acute and long-term care settings. The same evidenced-based methodology is used to assess patients 18 years and older. The diagnosis is discussed with the attending physician and care is provided based on the acuity of the patient. This measure should be applied to all patients.

Salutations and Greetings Committee members,

I wasn't sure how to begin this, because after years of practice in the nutrition field, I have a lot to say. To begin with my work is very unique, I was pursuing food science after earning my degree, did that for a number of years before heading back into the community nutrition arena. 

I will very simply start with food access is a human right based on Maslow's hierarchy of needs. We cannot focus on helping individuals at a higher level without addressing this basic human right. To go farther, we have professionals whom study the science of what we eat and how it effects our bodies, nutrition. I recently wrote a paper discussing the inadequate training of other medical professionals in the United States on nutrition, and the one limitation I noted, was that it may not be a focus because in the U.S. we have the privillege of having medical trained nutrition professionals to include DTR/NDTRs and RDNs. 

To go farther, what is worse is considering my work, when I do evaluations of other organizations and the providing of food to individuals under the organizations care, not only do they receive more money to feed their clientele, but the clientele are not receiving the bare minimum of adequate intake. It is one thing for them to refuse, we cannot make individuals eat, but to inappropriately access the needs when we have the knowledge to intervene is nothing short of unacceptable. When we have the resources to provide a basic right for individuals to get better we should provide it at the best level that we can. 

By trying to create some standard, this will not only be the start to help with employment nutrition professionals in the field to help address this issue, but it will bring the conversation to the table. We are finding new and great things scientifically that years ago we wouldn't have even dreamed of. We as humans deserve the dignity of provided food access at the best level to everyone.

Thank you for your time and listening,

Malnutrition affects individuals across the lifecycle.  The proposal for expansion of the GMCS to include those individuals 18 years and older is valid and important to capture the diagnosis of malnutrition in the adult population. 

I am a registered dietitian with more than 25 years in my profession.  The relationship between malnutrition/nutritional status and many other outcomes (muscle wasting and falls risk; wound healing and risk for pressure ulcers; infection risk; success of other therapies)  is well demonstrated in the research and in studies of human physiology.  But the ability to demonstrate the role of the dietitian and the effective management of malnutrition in order to improve outcomes, reduce risk for harm, and provide healthcare in a cost effective manner is hampered by lack of good measures and data.  Including malnutrition and the composite score as a measure enables hospital administrators, clinical leaders, nutrition department staff, and others to demonstrate the effectiveness on all levels of identifying and properly managing malnutrition.   As our population ages, becomes more diverse, and struggles with social determinants of health (such as access to food by way of poverty or food deserts), ensuring we are keeping our eyes on malnutrition/nutrition status is essential for the provision of sound healthcare.  

Implementation of the GMCS is a critical step to improving healthcare outcomes, including with medical nutrition therapy, and will help to shift the belief that malnutrition only occurs in the underweight or older adults.

The patient safety structural measure is important to ensure quality care in hospitals. To decrease morbidity and mortality hospitals must  remain focused on protecting the health and well being of the patients that entrust  us with their lives. There is no improvement without learning. Applying continuous quality improvement methods is vital to prevent patient harm events. The public is who healthcare serves so this reporting makes sense.  Being transparent by sharing  this information can restore trust and confidence in the health care systems where it has been lost. 

I am writing to support the adoption of MUC2023-188, the Patient Safety Structural Measure.  I am the patient safety director for a non-hospital healthcare entity, and would urge CMS to adopt and apply this measure to any healthcare organization which receives payment for acute care services and not limit the measure to hospitals.  A broader application would support patient safety and healthcare quality throughout the continuum of care, including out in the community/prehospital environment where healthcare is increasingly provided through mobile integrated health, emergency medical services, and critical care transport services.  Additionally, oversight/audit is important for attestation measures:  deeming organizations must incorporate audit measurements into their survey activity in order for this measure to be recognized as important by Boards and leaders.

I am writing to voice my strong support for Patient Safety Structural Measure MUC2023-188, which accurately reflects the contemporary consensus on how best to revitalize efforts to improve the safety of health care. As a registered nurse and healthcare risk management professional, I believe this measure will help incentivize the leaders of hospitals and health systems to re-prioritize patient safety.

We commend CMS’ recognition of the significant impact malnutrition has on all adult patient outcomes, as well as its consideration of the benefits of the expansion of the Global Malnutrition Composite Score (MUC2023-114) as an eCQM when extended to all adult ages 18 years or older. CMS has long recognized the prevalence of malnutrition, its negative impact on patient outcomes, and the persistent barriers to high-quality malnutrition care.^1,2 2018 data indicates that more than 30% of hospitalized patients have malnutrition depending on the patient population and the criteria for assessment³ and that approximately 20 percent of hospitalized patients require complex nutrition plans and dietary orders.  Recent studies have shown that 1 in 3 hospitalized adult patients are at risk of malnutrition⁴, however, malnutrition is not always identified and diagnosed, as only 8% of non-neonatal and non-maternal adult hospitalizations were coded for malnutrition³. Ongoing malnutrition research supports identifying, diagnosing, and treating malnutrition at all ages.^5-9 

In addition, the recognition of malnutrition as a critical issue for all adults continues to support the alignment with the Meaningful Measures 2.0 Initiative, which strives to identify high priority areas for quality of care, build value-based care and promote health equity. CMS has an immediate opportunity to advance the objectives of the initiative by expanding the age of the inpatient malnutrition eCQMs in the hospital pay-for-reporting program(s). The below provides a summary of how the expansion of the age coverage to all adults aligns with the Initiative: 

1. Using high-value quality measures impacting key quality domains.

The burden of malnutrition on patients in the hospital setting as detailed in a report published by the AHRQ Healthcare Cost and Utilization Project (HCUP) is of great importance as it affects all key quality domains. The report mentions that malnourished hospitalized patients are three to five times more likely to experience in-hospital death and experience a 56 % higher rate of hospital 30-day readmissions compared with non-malnourished patients.⁶ Furthermore, malnutrition is a key health disparity that HCUP data demonstrate is more likely to affect African American patients.

Malnutrition, defined as a nutrition imbalance including under-nutrition and over-nutrition, is a pervasive, but often under-diagnosed, condition in the United States. Malnutrition prevalence is exacerbated among patients who are already ill: chronic diseases such as diabetes, cancer, and gastrointestinal, pulmonary, heart, and chronic kidney disease. Chronic disease treatments can result in changes in nutrient intake and ability to use nutrients, which can lead to malnutrition. The Global Malnutrition Composite Score quality measure is vital to implementation of malnutrition quality improvement and advancing and standardizing nutrition care in hospitalized patients. Lack of evaluation and management can result in negative health and financial outcomes as malnourished adults have been found to utilize more health services with more visits to physicians, hospitals, and emergency rooms. Nutrition interventions have been repeatedly shown to positively impact health status and be cost-effective in improving health outcomes among malnourished patients.

1. Prioritizing outcome and patient-reported measures.

Malnutrition is a patient-safety risk and has been shown to be an independent predictor of negative patient outcomes, including mortality, lengths of hospital stay, readmissions, and hospitalization costs.^10-11 Malnourished patients are also more likely to develop pressure ulcers,¹² infections,¹³ post-operative complications^14-15 and experience falls.^16-17 In addition, malnutrition in the hospital is associated with increased cost of care and the economic burden of disease-associated malnutrition in the U.S. was estimated to be as high as $157 billion in 2014, with $15.5 billion directly linked to cost of treatment.¹⁸ Average hospital costs for all non-neonatal and non-maternal hospital stays were $12,900, while patients diagnosed with malnutrition had hospital costs averaging up to $22,200 depending on the type of malnutrition indicated.⁶ In 2016, those costs were reported to be $17,500 per readmission, 26-34% higher compared to patients readmitted without malnutrition. 

Furthermore, malnutrition is a state of deficit, excess, or imbalance in protein, energy or other nutrients that adversely impacts an individual patient’s body form, function, and clinical outcomes.¹⁹ For many adults, the lack of adequate protein and the loss of lean body mass are particularly significant problems. This occurs whether the individual is underweight, or counterintuitively overweight or obese, because it is inadequate protein, not fat that is the problem. The importance of malnutrition prevention, identification and intervention for at-risk and malnourished individuals is magnified by malnutrition’s impact on independence, well-being, and the severity of medical conditions and disabilities. Therefore, all patients need to remain engaged in their nutritional care and understand the signs and symptoms of malnutrition, including communicating their nutritional status and history to their providers. This measure supports the interdisciplinary teams focus on the patient’s preferences regarding food choices, timing of meals, and/or self-feeding strategies within their individual, social and environmental circumstances.  The data generated from the clinical processes promoted by the eCQMs is critical for comprehensive discharge planning inclusive of nutrition care and helps inform patients and caregivers on how to continue improving their nutritional status after discharge. 

1. Transforming measures to be fully digital and incorporating all-payer data.

The GMCS (MUC2023-114) has been developed to utilize data from all patients admitted to a hospital. It includes all payer data and is considered an eCQM.  Use of data in this format and applicability to all payers, aids in easing implementer burden while encouraging high-quality malnutrition care for all adult inpatients.  

1. Aligning measures across value-based programs and across partners, including CMS, federal, and private entities.

The Global Malnutrition Composite Score (CMS 986) has been identified as a measure that aligns with CMS’ priorities and initiatives, particularly health disparities and patient-centered delivery of care. It has also been identified as addressing the 2023 Healthcare Effectiveness and Data Information Set (HEDIS) Social Need Screening and Intervention. In addition, the GMCS meets the nutrition screening requirement under The Joint Commission’s Requirements to Reduce Health Care Disparities Leadership Standard. By expanding the measure age of coverage to adults 18 years of age and older, CMS will support meeting this goal for all adults, not just those 65 years of age or older. 

Furthermore, addressing malnutrition in the healthcare setting aligns with the National Quality Strategies established by the Agency for Healthcare and Quality. Malnutrition can be directly linked to the NQS’ three aims, which include: 

• Better care by making healthcare patient centered, reliable, accessible, and safe. 
• Better health by supporting proven interventions to address behavioral, social, and environmental determinants of health.
• Lower cost of healthcare for individuals, families, employers, and government.

1. Developing and implementing measures reflecting social drivers/determinants of health (SDOH).

Malnutrition is a pressing clinical area associated with poor patient outcomes and increased healthcare costs across all care settings. The burden of malnutrition on patients in the hospital setting as detailed in a report published by the AHRQ HCUP demonstrates that malnutrition is a public health issue. Furthermore, malnutrition is a key health disparity issue that HCUP data demonstrate is more likely to affect African American patients. Because food insecurity caused by economic and social burdens can increase the risk of malnutrition, addressing malnutrition and its root causes, as done through the thorough assessment and care planning of the Registered Dietitian Nutritionists (RDN) and the interdisciplinary team in the health care setting, can therefore support the reduction of health disparities.^20-21

It is important to note that, in addition to aligning with several CMS goals, the proposed expansion (MUC2023-114) of the age range from 65 to 18 years of age or older for the GMCS (CMS 986) is not expected to result in any additional reporting burden for institutions that choose to select this measure as one of the 3 self-selected eCQMs because the data element of age already is being collected

Conclusion

The Academy of Nutrition and Dietetics and Avalere appreciate the continuous engagement of CMS pursuant to tackling malnutrition and improving quality care at the national level. In years past, we have commended CMS for moving forward with approving the GMCS as an eCQM. 

The importance of identifying, diagnosing, and treating malnutrition continues to grow. Further, the relationship between malnutrition and food insecurity and its effects on health equity has been proven to be of importance and continues to be studied. The existing Global Malnutrition Composite Score eCQM has been extensively tested, incentivizing the adoption of evidence-based malnutrition care best practices that are associated with reduced costs and improved patient outcomes. 

Given the merit of the expansion of the measure age range to 18 years of age or older as described above, we strongly recommend that CMS consider adoption of the MUC 2023-114 into the Hospital IQR program.

We thank CMS for the continued engagement, and we look forward to working with you on future integration of these measures in the acute care setting and efforts to improve malnutrition quality of care across all care settings.

I think this measure for 2022 is not reflective of properly judging physicians on costs associated with cataract surgery. I operate at an ambulatory surgery center, and I don't have any extra charges/visits, etc.  It is my understanding that medical costs that a patient experienced that had nothing to do with me were attributed to me (for example, if they saw their retinal specialist and had an intravitreal injection for their pre-existing age-related macular degeneration around the time of cataract surgery, those costs were attributed unfairly to me).   I looked at some of the raw data, and things just didn't make sense. I am hopeful that changes will be made going forward.  If not, I would hope that this measure is eliminated entirely.

In thinking about cataract surgery in general, this cost measure may very well be a reason that some ophthalmologists will stop offering this service to our patients. Reimbursement for the surgery is now at such a low level where I feel like I can generate revenue just as efficiently by seeing patients in the office rather than going the operating room.  Additionally, as you know, cataract surgery includes a 90 day post-op period for which visits are not reimbursed (which for me is a minimum of 3 office visits).  With reimbursement for cataract surgery so low, and now that I am being punished financially/fined due to this cataract cost measure, it sure is tempting to stop performing cataract surgery.

Re: PSSM MUC2023-188. As a parent whose daughter died directly caused by medical errors, this measure is essential to support patient and patient safety both physically and emotionally. The harm done to patients and families does not end with the actual event. They are continually harmed through practices that deny or minimize the event and have to fight with no energy to do so for accountability and transparency simply to get to the truth and to get committments for measures that ensure that like kind events will not happen to others. Please help us help all Americans by implementing these measures. One day, you, your family members and others you love will inevitably and sadly benefit from doing so. Thank you.

My name is Rabia Brar.  Patient safety is important to me because as a healthcare quality and safety leader. I write in support of the Patient Safety Structural Measure (#MUC2023-188) on the CMS list of Measures Under Consideration.

The reasons I support this measure is because it states the kinds of patient safety best practices I expect as a patient of all hospitals in the United States.  It is important to me that:

1.     Hospital leaders and boards of directors prioritize patient safety and are actively engaged in making sure the right safety practices are in place. 
2.     Hospitals adopt as their goal “zero preventable harm” as the patient safety strategic goal. Even if that goal is aspirational, it should be what every hospital is aiming to achieve.
3.     Hospitals establish a culture of safety that engages all its staff and puts in place systems for preventing and learning from medical errors or other problems that put patients at risk for harm or discrimination.
4.     Hospitals have systems in place for reporting harm events and being open and honest with patients and the public when harm events occur. I also expect hospitals to report their events to government agencies or other bodies that focus on learning and prevention.
5.     Hospitals should engage the patients and families they serve in patient safety work.  They should also be focused on helping patients access our medical records and correct errors in them when we find them.

For all these reasons I strongly support the Patient Safety Structural Measure.  Thank you for this opportunity to make this public comment.

My name is Shannon Crowell.  Patient safety is important to me as a Registered Nurse/Quality professional and as patient, daughter and wife with personal experience/s of avoidable harm. I write in support of the Patient Safety Structural Measure (#MUC2023-188) on the CMS list of Measures Under Consideration.

The reasons I support this measure is because it states the kinds of patient safety best practices I expect as a patient of all hospitals in the United States.  It is important to me that:

1.     Hospital leaders and boards of directors prioritize patient safety and are actively engaged in making sure the right safety practices are in place. 

2.     Hospitals adopt as their goal “zero preventable harm” as the patient safety strategic goal. Even if that goal is aspirational, it should be what every hospital is aiming to achieve.

3.     Hospitals establish a culture of safety that engages all its staff and puts in place systems for preventing and learning from medical errors or other problems that put patients at risk for harm or discrimination.

4.     Hospitals have systems in place for reporting harm events and being open and honest with patients and the public when harm events occur. I also expect hospitals to report their events to government agencies or other bodies that focus on learning and prevention.

5.     Hospitals should engage the patients and families they serve in patient safety work.  They should also be focused on helping patients access our medical records and correct errors in them when we find them.

For all these reasons I strongly support the Patient Safety Structural Measure.  Thank you for this opportunity to make this public comment.

As a dietitian in the hospital setting, I see firsthand how malnutritrion negatively impacts patients - both in their outcomes and their lengths of stay. Although many improvements to diagnosis and treatment of malnutrition have been made in the last decade, it is still not always taken as seriously as it should be. Directing more resources to improving nutrition status and identifying patients at risk is essential to improving overall patient care in hospitals. 

My name is Vonda Vaden Bates.  I am writing as a Patient Safety Champion with Patients for Patient Safety US, which is a patient-led network of people who know that  healthcare safety is an urgent priority in the USA.  I write in support of the Patient Safety Structural Measure (#MUC2023-188) on the CMS list of Measures Under Consideration.Our
It is a fundamental moral and ethical responsibility to deliver safe care. Patient safety is at a crossroads, having seen a decline in commitment and systematic improvement for many years, accelerated by the pandemic. US hospitals and health systems have struggled to commit to safe care because of an under-resourced state, greed, and genuine confoundment about how to make this a priority. These are complex issues. However, evidence-based approaches are proving to improve the situation. 

This measure mandates what we know works. It is an excellent starting point for CMS.  Please ensure its adoption. 

much-needed

The Patient Safety Structural Measure provides much-needed guidance to hospital leaders on how to deliver safer care. It also creates a way to recognize the hospitals and health systems that are exemplary for their leadership and action on patient safety., The questions the Patient Safety Structural Measure asks hospital leaders to attest to reflect what patients in the United States expect all hospitals to be doing, and it aligns with other national guidance such as the Safer Together: The National Action Plan to Advance Patient Safety.
For all these reasons I strongly support the Patient Safety Structural Measure.  Thank you for this opportunity to make this public comment.
 

My name is Lilia Bacu.  I am writing as a Patient Safety Champion with Patients for Patient Safety US, which is a patient led network of people who feel that making healthcare safety is an urgent priority.  I write in support of the Patient Safety Structural Measure (#MUC2023-188) on the CMS list of Measures Under Consideration.   Name: Patient Safety Structural Measure.  Number: MUC2023-188.
It is a fundamental moral and ethical responsibility to deliver safe care. Patient safety is at a crossroads, having seen a decline in commitment and systematic improvement for many years, accelerated by the pandemic. I believe that our hospitals and health systems have struggled in their commitment to safe care because it is under resourced and not a priority.
The Patient Safety Structural Measure provides much needed guidance to hospital leaders on the ways that they can deliver safer care. It also creates a way to recognize the hospitals and health systems who are exemplars for their leadership and action on patient safety. The questions the Patient Safety Structural Measure asks hospital leaders to attest to reflect what patients in the United States expect all hospitals to be doing, and it aligns with other national guidance such as the Safer Together: The National Action Plan to Advance Patient Safety.
For all these reasons I strongly support the Patient Safety Structural Measure.  Thank you for this opportunity to make this public comment.

Name: Patient Safety Structural Measure.  Number: MUC2023-188.

My name is Lilia Bacu.  I am writing as a Patient Safety Champion with Patients for Patient Safety US, which is a patient led network of people who feel that making healthcare safety is an urgent priority.  I write in support of the Patient Safety Structural Measure (#MUC2023-188) on the CMS list of Measures Under Consideration.
It is a fundamental moral and ethical responsibility to deliver safe care. Patient safety is at a crossroads, having seen a decline in commitment and systematic improvement for many years, accelerated by the pandemic. I believe that our hospitals and health systems have struggled in their commitment to safe care because it is under resourced and not a priority.
The Patient Safety Structural Measure provides much needed guidance to hospital leaders on the ways that they can deliver safer care. It also creates a way to recognize the hospitals and health systems who are exemplars for their leadership and action on patient safety. The questions the Patient Safety Structural Measure asks hospital leaders to attest to reflect what patients in the United States expect all hospitals to be doing, and it aligns with other national guidance such as the Safer Together: The National Action Plan to Advance Patient Safety.
For all these reasons I strongly support the Patient Safety Structural Measure.  Thank you for this opportunity to make this public comment. Name: Patient Safety Structural Measure.  Number: MUC2023-188.

Hello, 

I recommend that we start moving away from the word "Doctor" and move towards the word "Provider" within the HCAHPS survey questions. APPs are becoming a large part of the care delivery and in many cases acting as the main provider for a patient. I come from a rural hospital and we utilize our APPs as the main hospitalist for a patient during their stay. When patients received survey questions regarding a "doctor" it can be very confusing because they might not have interacted with  a doctor but rather an APP. 

Thank you,

Sara 

My name is Ariana Longley. Patient safety is important to me because because I was temporarily harmed while seeking care and believe that because I was engaged my harm was less significant. I write in support of the Patient Safety Structural Measure (#MUC2023-188) on the CMS list of Measures Under Consideration.

The reasons I support this measure is because it states the kinds of patient safety best practices I expect as a patient of all hospitals in the United States.  It is important to me that:

1.     Hospital leaders and boards of directors prioritize patient safety and are actively engaged in making sure the right safety practices are in place. 
2.     Hospitals adopt as their goal “zero preventable harm” as the patient safety strategic goal. Even if that goal is aspirational, it should be what every hospital is aiming to achieve.
3.     Hospitals establish a culture of safety that engages all its staff and puts in place systems for preventing and learning from medical errors or other problems that put patients at risk for harm or discrimination.
4.     Hospitals have systems in place for reporting harm events and being open and honest with patients and the public when harm events occur. I also expect hospitals to report their events to government agencies or other bodies that focus on learning and prevention.
5.     Hospitals should engage the patients and families they serve in patient safety work.  They should also be focused on helping patients access our medical records and correct errors in them when we find them.

For all these reasons I strongly support the Patient Safety Structural Measure.  Thank you for this opportunity to make this public comment.

Patient Safety Structural Measure

We must protect healthcare workers who step forward for patient safety. It is inexcusable that so many physicians have sued this hospital for patient safety issues.  We are a small community in Northern Maine and we would like our voices heard!

https://www.change.org/p/good-healthcare-workers-need-your-help

My name isArmando Nahum.  Patient safety is important to me because I lost my son to an infection he caught in a hospital that was caring for him. I write in support of the Patient Safety Structural Measure (#MUC2023-188) on the CMS list of Measures Under Consideration.

The reasons I support this measure are because it states the kinds of patient safety best practices I expect as a patient in the United States.  It is important to me that Hospital leaders and boards of directors prioritize patient safety and are actively engaged in making sure the right safety practices are in place. 

1. Hospitals adopt “zero preventable harm” as their patient safety strategic goal, as recommended in the CMS National Quality Strategy.  Even if that goal is aspirational, it should be what every hospital aims to achieve.
2. Hospitals establish a culture of safety that engages all its staff and puts in place systems for preventing and learning from medical errors or other challenges that put patients at risk for harm or discrimination.
3. Hospitals have systems in place for reporting harm events and being open and honest with patients and the public when harm events occur. I also expect hospitals to report their events to government agencies, accreditation bodies or other organizations that focus on learning and prevention.
4. Hospitals should engage the patients and families they serve in patient safety work, as recommended by the President’s Council of Advisors on Science and Technology. Listen to our experiences and factor it in to your work to decrease preventable harm, bias and discrimination.  They should also be focused on helping patients access our medical records and correct errors there when we find them.

For all these reasons I strongly support the Patient Safety Structural Measure.  Thank you for this opportunity to make this public comment.

My name is Kayoko Corbet.  I am writing as a Patient Safety Champion with Patients for Patient Safety US, which is a patient-led network of people who feel that making healthcare safe is an urgent priority.  I write in support of the Patient Safety Structural Measure (#MUC2023-188) on the CMS list of Measures Under Consideration.

I used to work as an RN at hospitals, and I have firsthand knowledge of how dangerous a hospital environment can be. Unfortunately, patient safety has been under-resourced and given lip service by most hospital administrations. Due to medical errors and other adverse events, too many people have lost their lives or been injured, and taxpayers have been paying dearly for would-be-avoidable medical expenses.

The Patient Safety Structural Measure provides much-needed guidance to hospital leaders on the ways that they can deliver safer care. It also recognized the critical role of the patients, their families, and care partners in strengthening patient safety, which has been absolutely overdue.

I strongly support the Patient Safety Structural Measure.  Thank you for this opportunity to make this public comment.

I  write to express support for the inclusion of the Age-Friendly Hospital measure in the CMS Hospital Inpatient Quality Reporting (IQR) Program. This is a new type of measure, a “programmatic composite” measure, which considers the full program of care needed for geriatric patients in the hospital. Developed in partnership with the American College of Surgeons (ACS), the Institute for Healthcare Improvement (IHI), and the American College of Emergency Physicians (ACEP), this measure is meant to help build a better, safer environment for older adults and will help patients and their family caregivers know where to find best care.

Current proposal is an attestation process - I recommend a more robust confirmation process to ensure the accuracy of organization's reporting.

Standardize harm metric (e.g. NME, PSE, SSE) so organizations and public are comparing apples to apples.

Recommend a measure for preventing safety events which includes sharing lessons learned from internal or external organizations. 

As a healthcare consultant, I see hospitals across the country who think they have a good patient safety program but fall quite short. This measure, while only a process measure, would be an excellent step forward in ensuring that minimal standards are being followed. 

My name is Edward Donnelly. Patient safety is important to me because as a Professional Nurse and Certified Professional in Healthcare Quality (CPHQ) I have dedicated my 42-year career to the safe delivery of care to patients in every setting.  In addition to my experiences in hospitals, along with my wife, also a Professional Nurse, we were directly involved with the oversight of the care of our parents were provided and were required to "step in" when their respective needs were not being met and/or they were put at risk.

I write in support of the Patient Safety Structural Measure (#MUC2023-188) on the CMS list of Measures Under Consideration. The reasons I support this measure are because it states the kinds of patient safety best practices I expect as a patient and family member in the United States. It is important to me that: 1. Hospital leaders and boards of directors prioritize patient safety and are actively engaged in making sure the right safety practices are in place. 2. Hospitals adopt “zero preventable harm” as their patient safety strategic goal, as recommended in the CMS National Quality Strategy. Even if that goal is aspirational, it should be what every hospital aims to achieve. 3. Hospitals establish a culture of safety that engages all its staff and puts in place systems for preventing and learning from medical errors or other challenges that put patients at risk for harm or discrimination. 4. Hospitals have systems in place for reporting harm events and being open and honest with patients and the public when harm events occur. I also expect hospitals to report their events to government agencies, accreditation bodies or other organizations that focus on learning and prevention.

My name is Kayoko Corbet.  I am writing as a Patient Safety Champion with Patients for Patient Safety US, which is a patient-led network of people who feel that making healthcare safe is an urgent priority.  I write in support of the Patient Safety Structural Measure (#MUC2023-188) on the CMS list of Measures Under Consideration.

I used to work as an RN at hospitals, and I have firsthand knowledge of how dangerous a hospital environment can be. Unfortunately, patient safety has been under-resourced and given lip service by most hospital administrations. Due to medical errors and other adverse events, too many people have lost their lives or been injured, and taxpayers have been paying dearly for would-be-avoidable medical expenses.

The Patient Safety Structural Measure provides much-needed guidance to hospital leaders on the ways that they can deliver safer care. It also recognized the critical role of the patients, their families, and care partners in strengthening patient safety, which would help hospital clinicians and has been absolutely overdue.

I strongly support the Patient Safety Structural Measure.  Thank you for this opportunity to make this public comment.

My name is Dr Evan Benjamin and I write in support of the Patient Safety Structural Measure (#MUC2023-188) on the CMS list of Measures Under Consideration.
It is a fundamental moral and ethical responsibility to deliver safe care. Patient safety is at a crossroads, having seen a decline in commitment and systematic improvement for many years, accelerated by the pandemic. I believe that our hospitals and health systems have struggled in their commitment to safe care because it is under resourced and not a priority.
The Patient Safety Structural Measure provides much needed guidance to hospital leaders on the ways that they can deliver safer care. It also creates a way to recognize the hospitals and health systems who are exemplars for their leadership and action on patient safety. The questions the Patient Safety Structural Measure asks hospital leaders to attest to reflect what patients in the United States expect all hospitals to be doing, and it aligns with other national guidance such as the Safer Together: The National Action Plan to Advance Patient Safety.
For all these reasons I strongly support the Patient Safety Structural Measure.  Thank you for this opportunity to make this public comment.

I am Beau Tiffany, writing as a Patient Safety Champion with Patients for Patient Safety US, a patient-led network advocating for urgent improvements in healthcare safety. I am writing in support of the Patient Safety Structural Measure (#MUC2023-188) on the CMS list of Measures Under Consideration.

Delivering safe care is a fundamental moral and ethical responsibility. Patient safety is at a critical juncture, having witnessed a decline in commitment and systematic improvement over many years, a trend exacerbated by the pandemic. I believe our hospitals and health systems have faltered in their commitment to safe care due to under-resourcing and lack of prioritization.

The Patient Safety Structural Measure offers much-needed guidance to hospital leaders on how to deliver safer care. It also provides a means to recognize those hospitals and health systems that exemplify leadership and action in patient safety. The questions posed by the Patient Safety Structural Measure for hospital leaders to attest to reflect the expectations of patients across the United States. It aligns with other national guidance such as Safer Together: The National Action Plan to Advance Patient Safety.

For all these reasons, I strongly support the Patient Safety Structural Measure. Thank you for this opportunity to make this public comment.

I support the proposed structural measures because my child died after series of mistakes made at two hospitals. Though it has been eighteen years since my son died, the hospital where Gabriel was misdiagnosed has yet to have a substantive conversation with me about what happened or what they learned. Contrast Renown's silence with the hospital where he died, Stanford Children's Hospital. There his death was investigated, they apologized and explained. They took tangible steps to ensure children at their hospital would be safer. The responses of these two hospitals illustrates the power and necessity around medical events to understand and prevent them, and to provide patients and families the dignity of understanding what happened to themselves or to loved ones.

Please see attached letter from the leadership of the Coalition of State Rheumatology Organizations (CSRO) regarding the cost of care measure for rheumatoid arthritis. 

Patient Safety Structural Measure Public Comment:

I am writing in personal support of the Patient Safety Structural Measure (#MUC2023-188) in the CMS Measures Under Consideration.  

Background:

My work in patient safety was initiated by the loss of my son, Michael to a preventable medical error that happened repeatedly to 5 families in 4 years before us (and one after us). Lacking commitment and incentives towards transparency, safety improvement and learning from harm, the institution did not mitigate the causes of harm and the harm was repeated instead of prevented.  As a result, I have dedicated my life’s work to supporting safer healthcare and transparency after harm.

I serve as a Co-Founder of Patients for Patient Safety, which represents patients committed to making our healthcare systems safer, reducing preventable harm, and advancing transparency towards learning when harm occurs. I also serve on the Governing Board of the Institute for Healthcare Improvement and have led the national work for IHI to support governing boards in their oversight of quality and safety for health systems.  I also have served on Solutions for Patient Safety (SPS), a pediatric safety learning network. Finally, I served on the PSSM technical expert panel (TEP).

Patient Safety’s Struggle and Cost:

I believe that patient safety is at a crossroads having seen a decline in commitment and systematic improvement for many years, accelerated by the pandemic. Care in U.S. health systems has become more unsafe for patients and that normalized behavior and lack of consequence for the harm is morally unacceptable and a remarkable contrast with the Hippocratic Oath to ‘First Do No Harm’.  While the retraction in commitment to safety and harm increasing likely has many causes, it merits attention and multi-faceted commitment to address that harm. Harm is financially costly for the healthcare system and emotionally and physically devastating to patients. I believe it is a fundamental moral responsibility to ensure safety is a priority for care of patients in the U.S. 

The Patient Safety Structural Metric:

The Patient Safety Structural Metric (PSSM) provides much needed guidance as to the structural ways that health systems can deliver safer care and aligns in its domains with other national guidance such as the AHRQ National Action Plan.  

I support the PSSM for the following reasons:

1. Elevates governance responsibility for oversight of safety and active support of improvement
2. Prioritizes the need to structurally operationalize and resource safety improvement 
3. Demands transparency with patients about harm
4. Incentivizes greater patient engagement to support safer care 

Governance Responsibility for Safety: In my area of expertise, governance, the PSSM provides much needed elevated standards for governing boards that safety - patient and workforce - is a governance responsibility for oversight. Boards in the U.S. have highly variable commitment to safety and often do not understand how their health systems systemically identify safety priorities and how the leadership maintains and resources ongoing improvement work. Most boards do not understand how their system identifies safety events or potential harm, how much safety costs an institution, where the harm happens most frequently and severity of harm, and how the organization learns and improves to prevent future harm. As a result, if the board does not understand safety work in their institutions, it is often not a leadership priority to invest in it and support safety work. The PSSM Domain 1 gives recognition and motivation to boards who are setting safety as a resourced priority and in operational goals for their health systems.  Boards should ensure that the management has an integrative system safety assessment and be accountable to hear from management on their progress towards these improvement goals.  Boards often put their quality and safety work into the ‘consent agenda’ and it gets dismissed with no discussion which strongly signals this to leadership as a lower priority. The PSSM Leadership Domain 1 calls out that time spent in active discussion of safety work demonstrates board and leadership team commitment. In addition, the practice of notifying the board of serious harm events is a leadership practice in boards who are committed to transparency and improvement of safety.  Boards and leadership teams that elevate their practices to these standards in Domain 1 should be acknowledged for their leadership commitment to safety.

Operational Commitment to Safety: I also have seen how investment in consistent training of a safety culture and in safety improvement and systems leads to safer care. This was particularly made clear to me through the pediatric safety network called Solutions for Patient Safety and through my experience with the Institute for Healthcare Improvement.  Support of just culture, professional development of safety and integration of the front line into safety improvement leads to results.  As hospitals and care sites have workforce turnover and new risks are identified, continual training and reinforcement of safety work as a priority is part of best practice to deliver safe care. This involves analyzing trends, supporting a just culture so people can speak up when they have concerns and identifying areas for improvement.  It takes work to deploy highly reliable practices, to support a learning health system and understand where and how to improve care to make it safer. Domains 2, 3 and 4 identify the core practices that leading health systems deploy when they prioritize safety as an ongoing cultural and operational priority recognizing those that are doing these activities and incentivizing others to also elevate their operational safety work.

Transparency with Patients about Harm: Health systems should not hide their harm but be honest with patients after harm and demonstrate their commitment to safe care in how they identify, mitigate and improve harm.  The current state of normalized deviance to hide harm and not improve is insulting to the relationship that patients entrust their care with their care team. An expectation for honesty and a commitment to improve care when harm happens should be a moral standard of care.

Patient Engagement for Safety: Domain 5 recognizes health systems that integrate patient engagement in their care team and into the operational processes create safer, more respectful, and more responsive care. I have a medically complex son and I have struggled to feel heard, correct inaccuracies in his records and identify areas to improve care for other patients based on challenges in our experience. Domain 5 identifies that integrating patients into the care team and incorporating our input and data into safety analysis creates a more respectful and robust view of the care. In the U.S., many health systems prioritize integration and engagement of patients, and Domain 5 creates recognition of systems for whom patient engagement is an operational practice and cultural value. Domain 5 also provides guidance for those systems working to learn how to better integrate patients as co-producers of safer care and an integral part of their own care team. 

The PSSM is a measure that encourages positive actions and an accountable affirmation of health systems doing work to make care safer. It is a step in the right direction towards safer care. Thank you for considering my public comment in support of the Patient Safety Structural Measure. 

Beth Daley Ullem

Patient Safety Structural Measure Public Comment:

I am writing in personal support of the Patient Safety Structural Measure (#MUC2023-188) in the CMS Measures Under Consideration.  

Background:

My work in patient safety was initiated by the loss of my son, Michael, to a preventable medical error that happened repeatedly to 5 families in 4 years before us (and one after us). Lacking commitment and incentives towards transparency, safety improvement and learning from harm, the institution did not mitigate the causes of harm and the harm was repeated instead of prevented.  As a result, I have dedicated my life’s work to supporting safer healthcare and transparency after harm.

I serve as a Co-Founder of Patients for Patient Safety, which represents patients committed to making our healthcare systems safer, reducing preventable harm, and advancing transparency towards learning when harm occurs. I also serve on the Governing Board of the Institute for Healthcare Improvement and have led the national work for IHI to support governing boards in their oversight of quality and safety for health systems.  I also have served on Solutions for Patient Safety (SPS), a pediatric safety learning network. Finally, I served on the PSSM technical expert panel (TEP).

Patient Safety’s Struggle and Cost:

I believe that patient safety is at a crossroads having seen a decline in commitment and systematic improvement for many years, accelerated by the pandemic. Care in U.S. health systems has become more unsafe for patients and that normalized behavior and lack of consequence for the harm is morally unacceptable and a remarkable contrast with the Hippocratic Oath to ‘First Do No Harm’.  While the retraction in commitment to safety and harm increasing likely has many causes, it merits attention and multi-faceted commitment to address that harm. Harm is financially costly for the healthcare system and emotionally and physically devastating to patients. I believe it is a fundamental moral responsibility to ensure safety is a priority for care of patients in the U.S. 

The Patient Safety Structural Metric:

The Patient Safety Structural Metric (PSSM) provides much needed guidance as to the structural ways that health systems can deliver safer care and aligns in its domains with other national guidance such as the AHRQ National Action Plan.  

I support the PSSM for the following reasons:

1. Elevates governance responsibility for oversight of safety and active support of improvement
2. Prioritizes the need to structurally operationalize and resource safety improvement 
3. Demands transparency with patients about harm
4. Incentivizes greater patient engagement to support safer care 

Governance Responsibility for Safety: In my area of expertise, governance, the PSSM provides much needed elevated standards for governing boards that safety - patient and workforce - is a governance responsibility for oversight. Boards in the U.S. have highly variable commitment to safety and often do not understand how their health systems systemically identify safety priorities and how the leadership maintains and resources ongoing improvement work. Most boards do not understand how their system identifies safety events or potential harm, how much safety costs an institution, where the harm happens most frequently and severity of harm, and how the organization learns and improves to prevent future harm. As a result, if the board does not understand safety work in their institutions, it is often not a leadership priority to invest in it and support safety work. The PSSM Domain 1 gives recognition and motivation to boards who are setting safety as a resourced priority and in operational goals for their health systems.  Boards should ensure that the management has an integrative system safety assessment and be accountable to hear from management on their progress towards these improvement goals.  Boards often put their quality and safety work into the ‘consent agenda’ and it gets dismissed with no discussion which strongly signals this to leadership as a lower priority. The PSSM Leadership Domain 1 calls out that time spent in active discussion of safety work demonstrates board and leadership team commitment. In addition, the practice of notifying the board of serious harm events is a leadership practice in boards who are committed to transparency and improvement of safety.  Boards and leadership teams that elevate their practices to these standards in Domain 1 should be acknowledged for their leadership commitment to safety.

Operational Commitment to Safety: I also have seen how investment in consistent training of a safety culture and in safety improvement and systems leads to safer care. This was particularly made clear to me through the pediatric safety network called Solutions for Patient Safety and through my experience with the Institute for Healthcare Improvement.  Support of just culture, professional development of safety and integration of the front line into safety improvement leads to results.  As hospitals and care sites have workforce turnover and new risks are identified, continual training and reinforcement of safety work as a priority is part of best practice to deliver safe care. This involves analyzing trends, supporting a just culture so people can speak up when they have concerns and identifying areas for improvement.  It takes work to deploy highly reliable practices, to support a learning health system and understand where and how to improve care to make it safer. Domains 2, 3 and 4 identify the core practices that leading health systems deploy when they prioritize safety as an ongoing cultural and operational priority.

Transparency with Patients about Harm: Health systems should not hide their harm but be honest with patients after harm and demonstrate their commitment to safe care in how they identify, mitigate and improve harm.  The current state of normalized deviance to hide harm and not improve is insulting to the relationship that patients entrust their care with their care team. An expectation for honesty and a commitment to improve care when harm happens should be a moral standard of care.

Patient Engagement for Safety: Domain 5 recognizes health systems that integrate patient engagement in their care team and into the operational processes create safer, more respectful, and more responsive care. I have a medically complex son and I have struggled to feel heard, correct inaccuracies in his records and identify areas to improve care for other patients based on challenges in our experience. Domain 5 identifies that integrating patients into the care team and incorporating our input and data into safety analysis creates a more respectful and robust view of the care. In the U.S., many health systems prioritize integration and engagement of patients, and Domain 5 creates recognition of systems for whom patient engagement is an operational practice and cultural value. Domain 5 also provides guidance for those systems working to learn how to better integrate patients as co-producers of safer care and an integral part of their own care team. 

The PSSM is a measure that encourages positive actions and an accountable affirmation of health systems doing work to make care safer. It is a step in the right direction towards safer care. Thank you for considering my public comment in support of the Patient Safety Structural Measure. 

Beth Daley Ullem

I am writing in support of adopting the Patient Safety Structural Measure (PSSM).  It is imperative that hospitals be accountable for systemic management of patient safety and the PSSM will create a mechanism by which the public may have visibility into the methods, processes, and rigor of patient safety investigations and proactice safety management.  Preventable patient harm remains horrifically common in the United States and we need not only visibility into each healthcare organizations approach to managing patient safety, but the means of assessing the efficacy of their approach.  The compliance-based focus of healthcare organizations on reported measures of safety and quality has gotten us virtually nowhere, potetnially giving the public a false sense of the safety of care in healthcare organizations that perform well on measures that are intended to (but rarrely do)  represent the efficacy and value of the organizations learning and improvement stucture. It is time to hold healthcare organizations accountable for the implementation of Safety Management Systems, modeled after those that have proven of value in other high-risk domains, such as transportation, chemical processing, etc.  The PSSM is a crucial step in this direcdtion.  Jeff Brown 

My name is Nikki Mead. Patient safety is important to me because I have an aging parent and a husband with a chronic condition that requires surgery every 5-7 years. Not to mention all the friends and family that depend on safe medical care. I write in support of the Patient Safety Structural Measure (#MUC2023-188) on the CMS list of Measures Under Consideration.

I support this measure because it details the best patient safety practices I expect as a patient in the United States. It is important to me that:

1. Hospital leaders and boards of directors prioritize patient safety and are actively engaged in making sure the right safety practices are in place.
2. Hospitals adopt “zero preventable harm” as their patient safety strategic goal, as recommended in the CMS National Quality Strategy. Even if that goal is aspirational, it should be what every hospital aims to achieve.
3. Hospitals establish a culture of safety that engages all its staff and puts in place systems for preventing and learning from medical errors or other challenges that put patients at risk for harm or discrimination.
4. Hospitals have systems in place for reporting harm events and being open and honest with patients and the public when harm events occur. I also expect hospitals to report their events to government agencies, accreditation bodies or other organizations that focus on learning and prevention.
5. Hospitals should engage the patients and families they serve in patient safety work, as recommended by the  President’s Council of Advisors on Science and Technology. Listen to our experiences and factor it in to your work to decrease preventable harm, bias and discrimination. They should also be focused on helping patients access our medical records and correct errors there when we find them.

For all these reasons I strongly support the Patient Safety Structural Measure. Thank you for this opportunity to make this public comment.

My name is T. Gabe Houston. Patient safety is important to me because I represent injured parties and families who have suffered from unexpected outcomes or events while under the care and treatment of a healthcare provider.  I further represent patients and families during CRP meetings (Communication and Resolution Programs) under the banner of  Collaborative Alternative Legal Medical Solutions (C.A.L.M.S.).  I write in support of the Patient Safety Structural Measure (#MUC2023-188) on the CMS list of Measures Under Consideration.

I support this measure because it details the best patient safety practices I expect as a patient in the United States. It is important to me that:

1. Hospital leaders and boards of directors prioritize patient safety and are actively engaged in making sure the right safety practices are in place.
2. Hospitals adopt “zero preventable harm” as their patient safety strategic goal, as recommended in the CMS National Quality Strategy. Even if that goal is aspirational, it should be what every hospital aims to achieve.
3. Hospitals establish a culture of safety that engages all their staff and puts in place systems for preventing and learning from medical errors or other challenges that put patients at risk for harm or discrimination.
4. Hospitals have systems in place for reporting harmful events and being open and honest with patients and the public when harmful events occur. I also expect hospitals to report their events to government agencies, accreditation bodies or other organizations that focus on learning and prevention.

     5. Hospitals should engage the patients and families they serve in patient safety work, as recommended by the President’s Council of Advisors on Science and Technology. Listen to our experiences and factor it into your work to  decrease preventable harm, bias, and discrimination. They should also be focused on helping patients access our medical records and correct errors when we find them.

                For all these reasons I strongly support the Patient Safety Structural Measure. Thank you for this opportunity to make this public comment.

Organized and regulated guidance for the care of hospitalized older adults is imperative and overdue. 

I appreciate the opportunity to share my strong support for the Age-Friendly Hospital measure for inclusion in the CMS Hospital IQR program. I believe the measure is a critical piece in the optimization of care for older adult patients because it uses a holistic approach to create a quality program that can better meet the unique needs of our aging population. I am hopeful the measure will help build a safer environment and quality care for older adults who engage in medical services. I also hope that dissemination of this measure, when and if adopted, will be part of an outreach educational campaign to inform older adults and their caregivers so they call review a medical facility's score when selecting where to receive services. 

My name is Martin Murray. Patient safety is important to me because I have had several friends & family members who have had adverse and/or questionable experiences in hospitals regarding patient care & safety. I write in support of the Patient Safety Structural Measure (#MUC2023-188) on the CMS list of Measures Under Consideration.

I support this measure because it details the best patient safety practices I expect as a patient in the United States. It is important to me that:

1. Hospital leaders and boards of directors prioritize patient safety and are actively engaged in making sure the right safety practices are in place.
2. Hospitals adopt “zero preventable harm” as their patient safety strategic goal, as recommended in the CMS National Quality Strategy. Even if that goal is aspirational, it should be what every hospital aims to achieve.
3. Hospitals establish a culture of safety that engages all its staff and puts in place systems for preventing and learning from medical errors or other challenges that put patients at risk for harm or discrimination.
4. Hospitals have systems in place for reporting harm events and being open and honest with patients and the public when harm events occur. I also expect hospitals to report their events to government agencies, accreditation bodies or other organizations that focus on learning and prevention.

     5. Hospitals should engage the patients and families they serve in patient safety work, as recommended by the   President’s Council of Advisors on Science and Technology. Listen to our experiences and factor it in to your work to decrease preventable harm, bias and discrimination. They should also be focused on helping patients access our medical records and correct errors there when we find them.

For all these reasons I strongly support the Patient Safety Structural Measure. Thank you for this opportunity to make this public comment.