Overview
Measure Overview
This measure will support hospital efforts to further optimize quality of care for patients with sepsis, particularly the quality of transitional care, by providing a comprehensive assessment of post-discharge events. The measure will also provide detailed information about post discharge readmission rates. The measure will incentivize improved transitions of care, including easy-to-understand discharge summary and discharge instructions, medication reconciliation, and coordinated post-discharge care.
Sepsis is a leading cause of death in hospitals. Each year, according to the Centers for Disease Control and Prevention (CDC), at least 1.7 million adults in the U.S. develop sepsis, and at least 350,000 die as a result. It is also one of the main reasons for hospital readmissions in the U.S.
New measure never reviewed by MAP Workgroup, or PRMR or used in a Medicare program
Submitted for Fall 2025 cycle & currently under review.
N/A
Measure Specification
The measure includes unplanned acute care readmissions for any cause within 30 days after discharge of the eligible index hospitalization of sepsis.
This measure excludes admissions that are planned and may occur within 30 days of discharge from the hospital. Only an unplanned inpatient admission to a short-term acute care hospital can qualify as a readmission. Planned readmissions, which are generally not a signal of quality of care, are not considered readmissions in the measure outcome as defined below.
The measure uses a planned readmission algorithm to determine admissions that qualify as a planned readmission. The planned readmission algorithm is a set of criteria for classifying readmissions as planned using Medicare claims and encounters. The algorithm identifies admissions that are typically planned and may occur within 30 days of discharge from the hospital.
The planned readmission algorithm has three fundamental principles:
- A few specific, limited types of care are always considered planned (transplant surgery, maintenance chemotherapy/ immunotherapy, rehabilitation);
- Otherwise, a planned readmission is defined as a non-acute readmission for a scheduled procedure; and,
- Admissions for acute illness or complications of care are never planned.
Not applicable
The target population for this measure is Medicare FFS beneficiaries and MA patients aged 65 years and older hospitalized for sepsis at non-federal short-term acute care hospitals and who are discharged alive. The cohort includes hospital admissions with a discharge diagnosis of sepsis (index admission) for patients with a continuous 12-month Medicare enrollment period prior to the index admission.
Not applicable
This measure excludes index admissions for patients who meet any of the following exclusion criteria:
- Age < 65 at time of index admission;
- In-hospital mortality during index admission;
- Admissions resulting in transfers-out (as they are counted for the hospital that ultimately discharges the patient);
- Admissions during which patients leave hospital against medical advice (AMA);
- Admissions for patients without at least 30 days post-discharge enrollment in Medicare FFS and MA;
- Admissions resulting in patients discharged to hospice;
- Sepsis admissions captured in the pneumonia readmission measure;
- Those with additional sepsis admissions within 30 days of an index admission (because they are not considered as index admissions); and
- With a secondary diagnosis code of COVID-19 coded as present on admission (POA) on the index admission claim.
Note: As the years of data used for measure development include data CMS has determined were impacted by the COVID-19 pandemic, any hospitalizations with a principal diagnosis code of COVID-19 or with a secondary diagnosis code of COVID-19 coded as POA on the index admission claims were not included in the measure cohort. However, this exclusion will be removed prior to measure’s program implementation since the data will no longer include the COVID-19 public health emergency period.
Meaningfulness
Importance
The review of published literature and empiric data provided by the developer in submission materials underscore the importance of a hospital sepsis readmission measure by demonstrating that 30-day readmissions following sepsis hospitalization are common (17-26%) and often preventable, contributing to poor patient outcomes and substantial health care costs. Sepsis survivors face elevated risks of complications, including infection, cognitive impairment, and functional decline, which can be mitigated through targeted post-discharge interventions. The measure addresses a clear gap in current quality reporting and offers an opportunity to improve care transitions, reduce avoidable readmissions, and enhance long-term outcomes. Empirical studies and a systematic review support the measure’s relevance, and its implementation could drive improvements in hospital practices, care coordination, and patient safety. Patients on the technical expert panel (TEP) for this measure strongly agreed that the measure, as specified, is meaningful and generates information that is valuable for informing care decisions. This unanimous strong agreement underscores the perceived relevance and importance of the measure from the patient and caregiver standpoint.
Conformance
The intent of the sepsis readmission measure is to improve the quality of care and care transitions for patients hospitalized with sepsis by providing a comprehensive assessment of post-discharge events, including detailed readmission rates. By incentivizing practices to provide clear discharge instructions, medication reconciliation, and coordinated follow-up care, the measure aims to reduce preventable readmissions and enhance patient outcomes. The measure’s numerator, denominator, and exclusions are clearly defined and directly support the intent of this measure. The numerator includes unplanned acute care readmissions for any cause within 30 days after discharge of the eligible index hospitalization of sepsis among the denominator population of Medicare FFS beneficiaries and MA patients aged 65 years and older hospitalized for sepsis at non-federal short-term acute care hospitals and who are discharged alive. This measure aligns with the Hospital Inpatient Quality Reporting Program objective to improve the quality of care that hospitals provide and to distribute clearly defined and objective data about hospital performance as well as the Hospital Readmissions Reduction Program’s objective of improving communication and care coordination efforts to better engage patients and caregivers on post-discharge planning.
Feasibility
No, not an eCQM
The data elements for this measure are not captured in structured electronic fields and do not align with USCDI-defined data standards, as noted in the measure submission form. A claims-based measure for clinical quality is often highly feasible because it relies on routinely collected administrative data, which is already available across health care systems and does not require additional data entry or clinical abstraction. This allows for broad implementation, consistent data capture, and lower operational burden compared to chart-based measures. However, feasibility concerns include limitations in clinical detail, potential inaccuracies in coding, and challenges in risk adjustment due to lack of granular patient-level information.
Validity
Face validity; empiric validity [MERIT submission form; Supplemental Materials]
Facility
Yes
Thirteen subject matter experts, patients, and caregivers on the TEP voted on the face validity of the sepsis readmission measure. Twelve of respondents agreed the measure could distinguish hospital performance. Only one TEP member disagreed, noting concern with the model performance statistics and potential influence of confounders outside a hospital’s control that may correlate with worse performance.
Empiric validity was evaluated by examining correlations between the measure and components of CMS’s Overall Hospital Star Ratings, including readmission, summary, and patient experience scores. As hypothesized, the measure showed statistically significant negative correlations with the Readmission Group Score (r = -0.35), Summary Score excluding readmissions (r = -0.25), and Patient Experience Group Score (r = -0.21), supporting its validity. These results demonstrate that the measure aligns with existing indicators of hospital quality and is capable of differentiating performance across institutions
Measure developers address potential threats to measure validity through use of a risk adjustment model. The risk adjustment approach for the sepsis readmission measure incorporates key patient-level variables, including functional status, demographics, clinical conditions, and payer type (e.g., MA). The results of risk model performance suggest the model adequately accounts for differences in patient case mix, supporting its use for fair comparisons across hospitals.
Reliability
Random Split-Half Correlation
Facility
The developer assessed the reliability of the sepsis readmission measure using split-half methodology, which evaluates consistency by comparing scores from two randomly divided halves of hospital data. To ensure accuracy, the process was repeated multiple times and adjusted for sample size using the Spearman-Brown formula.
In collaboration on this PA, the measure developer provided the additional context that they calculated reliability results using 2 years of data (2022-2023) from 3,053 facilities with at least 25 admissions. The developer provided the minimum, maximum, median, and 25th and 75th percentiles. Among hospitals with at least 25 admissions, the minimum reliability was 0.205, the median reliability was 0.682, and the maximum reliability was 0.986. Reliability results reported by the developer show that 69% of accountable entities met the split-half reliability threshold of ≥ 0.60.
No additional analyses were conducted.
The following table was provided by the measure developer to demonstrate reliability estimates by decile.
Table 1. MUC2025-055 Accountable Entity-Level Reliability Estimate (January 1, 2022-December 31, 2023)
| - | Overall | Min | Decile 1 | Decile 2 | Decile 3 | Decile 4 | Decile 5 | Decile 6 | Decile 7 | Decile 8 | Decile 9 | Decile 10 | Max |
| Mean Reliability | 0.682 | 0.205 | 0.254 | 0.384 | 0.521 | 0.642 | 0.727 | 0.782 | 0.826 | 0.862 | 0.894 | 0.932 | 0.986 |
| Mean Score | 18.085 | 18.107 | 17.944 | 17.984 | 17.939 | 18.037 | 18.064 | 18.155 | 18.074 | 18.177 | 18.264 | 18.21 | 20.756 |
| Number of Entities | 3,053 | 21 | 312 | 296 | 309 | 305 | 306 | 302 | 308 | 305 | 306 | 304 | 1 |
| Number of Persons/ Encounters/ Episodes | 1,315,690 | 525 | 10,421 | 18,064 | 33,027 | 53,529 | 79,658 | 105,855 | 142,821 | 186,672 | 253,832 | 431,811 | 6,769 |
Usability
Yes, the submission materials briefly discuss the measure’s usability within relevant programs.
This measure has high usability in both the Hospital IQR and Readmission Reduction programs. It provides a standardized, claims-based approach to identifying unplanned 30-day readmissions following sepsis hospitalization, enabling hospitals to monitor performance and target improvement efforts. By highlighting post-discharge outcomes, the measure supports interventions such as enhanced discharge planning, medication reconciliation, and coordinated follow-up care. Its alignment with existing data systems and public reporting thresholds makes it feasible to implement, while its focus on preventable readmissions helps hospitals prioritize high-impact strategies to improve patient outcomes and reduce costs.
The developer did not identify any unintended consequences during measure development or model testing. However, they note that they are committed to monitoring this measure’s use and assessing potential unintended consequences over time, such as the inappropriate shifting of care, increased patient morbidity and mortality, and other negative unintended consequences for patients.
Appropriateness of Scale
Overview
None specified
This measure offers meaningful benefits across facilities by enabling standardized tracking of post-discharge outcomes and identifying opportunities to reduce preventable readmissions. However, the burden may vary depending on hospital resources, infrastructure, and patient populations. Facilities with robust care coordination programs or resources may find implementation easier and more beneficial, while those with limited staffing or technical capacity may face challenges in intervention development. Additionally, hospitals serving more populations that have more comorbidities or challenges accessing care may experience higher baseline readmission rates, which could affect performance unless adequately adjusted for in the model and recalibrated over time as the measure matures. While a condition-related measure, Severe Sepsis and Shock: Management Bundle, in Hospital IQR (SEP‐1) assesses early and timely sepsis treatment, this Sepsis Readmission measure focuses on discharge planning and coordination of post‐discharge ambulatory care.
Considerations for the committee: Based on clinical and professional experience, the committee should consider the distribution of benefit and risks/burdens of the measure within the proposed program population.
Time to Value Realization
Overview
None specified
While the measure developer briefly mentions potential outcomes for their measure to improve care transition quality and patient outcomes in the long-term, there may be need for further examination of near- and long-term impacts of this measure after implementation across provider and patient populations.
Considerations for the committee:
- What are the potential near- and long-term impacts of this measure on measured entities, proposed CMS programs, and patient populations?
- Will benefits and burdens associated with this measure be realized within an appropriate implementation time frame?
- How will this measure mature through revisions in the future if added to these programs’ measure sets?
Public Comments
MUC2025-055
The Kansas Hospital Associaton has concerns regarding this measure.
The inclusion of Medicare Advantage (MA) beneficiaries raises concern, as hospitals have limited ability to account for or influence MA plan utilization management policies, including prior authorization requirements, network limitations, discharges based on plan requirements and post-acute care restrictions. These plan-level factors may affect utilization outcomes in ways that are unrelated to hospital performance and could introduce variability that is outside the hospital’s control.
We recommend reconsideration of the inclusion of MA beneficiaries in the from utilization calculations to ensure the measure more accurately reflects hospital performance.
Sepsis Readmission
Support this measure as Sepsis is notably one of the highest conditions with readmissions. To this point only sepsis measure within CMS quality programs was sepsis bundle process measures. We have been internally measuring against other health care providers and provide it valuable especially with risk adjustment methodology applied.
Hospital Sepsis readmission rate
Rationale: Sepsis is a leading cause of death in hospitals. Each year, according to the Centers for Disease Control and Prevention (CDC), at least 1.7 million adults in the U.S. develop sepsis, and at least 350,000 die as a result. It is also one of the main reasons for hospital readmissions in the U.S. This measure will support hospital efforts to further optimize quality of care for patients with sepsis, particularly the quality of transitional care, by providing a comprehensive assessment of post-discharge events. The measure will also provide detailed information about post discharge readmission rates. The measure will incentivize improved transitions of care, including easy-to-understand discharge summaries and discharge instructions, medication reconciliation, and coordinated post-discharge care.
ECRI's Support of the CMS MUC - Safety & Diagnostic Excellence
ECRI, a global nonprofit advancing evidence-based healthcare, has submitted the attached comments on the MUC with an emphasis on measures most relevant to patient safety and diagnostic excellence.
ECRI supports the CMS Measures Under Consideration (MUC) List and its role in advancing meaningful, high-value measurement. Of particular significance are the measures focused on chronic disease management and diagnostic safety. Strengthening measurements in these domains supports more efficient, timely, and coordinated care across the healthcare system to better serve patients.
The attached comments from ECRI include recommendations on the importance of patient-reported outcomes, minimizing unnecessary reporting burdens, and feedback in support of the following measures:
Hospital 30-Day, All-Cause, RSRR Sepsis re: SHEA Comments
SHEA supports the adoption of the Hospital 30-Day, All-Cause, Risk-Standardized Readmission Rate (RSRR) Following Sepsis Hospitalization as a national quality measure. While we acknowledge the known limitations of claims-based measures, including variability in sepsis diagnosis and coding practices across institutions, these challenges are well recognized across existing CMS readmission measures and can be mitigated through robust risk adjustment, transparent methodology, and ongoing evaluation. The inclusion of a readmissions measure represents an important step toward moving beyond a narrow focus on early inpatient care and advancing a more comprehensive, patient-centered view of sepsis outcomes. By promoting continuity of care and accountability across the full sepsis care continuum, this measure has the potential to inform system-level improvement efforts and enhance the quality of care delivered to patients recovering from sepsis.
Sepsis Measures
Dear CMS:
I write as a member of the Advisory Board to Sepsis Alliance (www.sepsis.org), and the President & CEO of the Home Care Association of New York State (HCANYS) which has been leading community based sepsis interventions in NYS for more than decade, and has led the NY Initiative "Sepsis Prevention and Intervention in Community and Across the Continuum," to express my support for the CDC Sepsis Core Elements and to urge adoption of new structural and outcome measures along side SEP-I, and not in place of it.
Sepsis is a medical emergency that requires timely recognition and treatment. Quality measurement must reflect structure, process, and outcomes.
I support the CDC Core Elements to assess sepsis care structure and outcome measures such as risk-adjusted mortality and 30-day all-cause readmissions. These measures are important but not sufficient on their own.
Process measures remain essential to ensure timely and appropriate care for individual patients. SEP-1 is the only nationally standardized process measure for sepsis and provides critical accountability.
New structural and outcome measures should be adopted alongside SEP-1, not in place of it. Maintaining all three elements of measurement is essential to protecting patients and improving sepsis care nationwide.
In closing, with 87% of sepsis originating in home and community, I also urge CDC to examine the efficacy of community based sepsis assessment and intervention such as what we are performing in NY State (https://tinyurl.com/bdcme2pb) in collaboration with Sepsis Alliance, the END SEPSIS-Rory Staunton Legacy, and the NYS Office for Aging, and its impact on avoiding initial sepsis admissions, readmissions, prevention, and both lives and costs saved.
Thank you for your consideration of our support for the Core Elements and for SEP-1.
Al Cardillo, President & CEO
Home Care Association of NYS
and HCA Education & Research
Sepsis Comments
The American College of Emergency Physicians (ACEP) and our partnering societies support adoption of the measure for 30-Day, All-Cause, Risk-Standardized Readmission Rate Following Sepsis Hospitalization. This measure appropriately recognizes sepsis as a condition associated with substantial post-discharge vulnerability and reinforces the importance of care transitions, recovery, and longitudinal management as integral components of high-quality sepsis care.
We acknowledge known limitations of claims-based measures, including variability in sepsis diagnosis and coding practices across institutions. However, such limitations are well-recognized across many CMS readmission measures, and can be mitigated through robust risk adjustment, transparent methodology, and ongoing evaluation. Importantly, the inclusion of a readmissions measure signals the need to move beyond a narrow focus on early inpatient care and toward a more comprehensive, patient-centered view of sepsis outcomes.
As this measure is implemented, we emphasize the importance of ongoing evaluation and iterative refinement, including efforts to better distinguish readmissions that reflect appropriate clinical responses to disease progression or relapse from those that may be associated with unmet post-discharge needs, gaps in care transitions, or system-level barriers to recovery. We view this measure as an important step toward improving continuity of care and accountability across the full sepsis care continuum.
SHM continues to oppose the…
SHM continues to oppose the 30-day readmission window in CMS’ measures. Current evidence suggests that the window of impact for preventing readmissions or returns to the ER is much shorter than 30 days, and may be as short as 7 days. Therefore, the measure as structured makes hospitals and clinicians accountable for factors well outside of their control. We urge CMS to narrow the episode window for these measures to focus on the modifiable factors within hospitals and clinician’s control to prevent or reduce readmissions.
Chin DL, Bang H, Manickam RN, Romano PS. Rethinking Thirty-Day Hospital Readmissions: Shorter Intervals Might Be Better Indicators Of Quality Of Care. Health Aff (Millwood). 2016 Oct 1;35(10):1867-1875. doi: 10.1377/hlthaff.2016.0205. PMID: 27702961; PMCID: PMC5457284.
30-day ACR Following Hospitalization for Sepsis
The American Medical Association (AMA) is increasingly concerned that there is growing evidence that the measures used in the Hospital Readmissions Reduction Program (HRRP) may be leading to negative unintended patient consequences and are no longer capturing the appropriate patient population due to the structure and timeframe of the measures.[1],[2] For example, the literature is beginning to show that readmission measures based on administrative claims may be leading to increased mortality.2
The AMA believes that additional analyses are needed before new measures are implemented in this program. For example, it remains unclear to what degree is the reported association of lower readmissions with higher mortality found over longer or shorter time periods such as, one year or one week, as compared to the first 30-days post discharge. Gupta and co-authors report that the inverse association was still evident at one year.2 To what degree are any positive or negative correlations related to all-cause mortality and/or readmissions versus the condition-specific outcome? It is also worth examining whether trends exist based on unadjusted data and adjusted data. Most of the studies identified through our search of the literature, including Dharmarajan, et al.[3], used risk-adjusted data. Most individual patient care decisions are not made with risk-adjustment in mind. To better understand the outliers (those who are readmitted), there is a need to investigate and determine whether there is small, but important associations between reduced readmissions rates with patient mortality. Therefore, are we masking the issue by only examining the adjusted rates? Examination of unadjusted and risk-adjusted rates could help address this concern. We also believe that the timeframe of the readmission measures and whether the post discharge period is appropriate must be reexamined.
In addition, this measure includes some of the same changes that CMS has made to the other readmission measures; specifically, the risk adjustment model was updated to use individual ICD-10 codes rather than the CMS Hierarchical Condition Category (HCC) model; the measure now includes Medicare Advantage (MA) beneficiaries; and the data collection timeframe is two years. How each of these changes impact the reliability and validity of the measure has not been provided in this submission and we are concerned that without a phased approach, it will be extremely difficult for hospitals to determine their impact (e.g., what is the effect of the expansion to MA beneficiaries as compared to the reduction in the number of years of data used to calculate the measure). We also recommend CMS provide data on how hospitals’ performance shift since the potential impact on each hospital is critical to ensure that the results can be used to drive further improvement in patient care.
We also recommend that the minimum sample size is increased to produce a higher intraclass correlation coefficient (ideally 0.6 or higher for all hospitals since we consider the minimum achieved with 25 admissions (0.205) to be too low.
Lastly, we also question the lack of socio-economic factors in the risk adjustment due to evidence that hospitals with larger populations of poor patients perform poorly on the measures. We recognize that some of the measures have been tested to consider economic related variables; however, we do not believe the appropriate risk models were tested. The traditional approach of risk adjusting at the patient level may not be appropriate for measures where the measurement period includes care that is outside of the control of the hospital and a 30-day post-acute phase where the availability of community supports, and other resources directly impact a patient’s care. We believe that there may be community-level variables that affect the risk of readmission during the days following hospital admission but are not currently addressed. Measures that extend beyond the hospital stay or outside the locus of control of the measured entity should continue to have socio-economic adjustments addressed and analyzed at different levels (e.g., patient, hospital, and community).
Due to these concerns and unanswered questions, the AMA does not support inclusion of this measure in the Hospital Inpatient Quality Reporting Program or HRRP.
[1]Graham, Kelly. Et al (2018). Preventability of Early Versus Late Hospital Readmissions in a National Cohort of General Medicine Patients. Ann Intern Med. Doi. 10.7326/M17-1724.
[2]Gupta, Ankar, et al. Association of the Hospital Readmissions Reduction Program Implementation With Readmission and Mortality Outcomes in Heart Failure. JAMA Cardiol. 2017.
[3] Dharmarajan, Wang, Lin, et al. Association of Changing Hospital Readmission Rates With Mortality Rates After Hospital Discharge. JAMA. 2017;318:270-278.
RSRR Sepsis
The AHA appreciates that CMS is considering multiple measures related to sepsis, which is a critical issue for hospital safety and quality. We hope that the agency and the measure developer can share additional contextual information for this readmissions measure to help us better understand how its use would benefit patients and providers. Based on the underlying physiological causes of sepsis, there are many similarities and even overlap between patients who are diagnosed with sepsis and those diagnosed with pneumonia; we urge CMS to clarify whether this measure’s patient population does overlap with that of the pneumonia readmissions measure, or how CMS has accounted for potential double-counting of patients.
Further, we also recommend that the measure developer point to particular interventions that hospitals can take to reduce sepsis readmissions rates and determine whether there are patient- or facility-level factors that may influence the feasibility of implementing those interventions. For example, adherence to medication and access to post-acute care are two factors that reduce readmissions in general; however, the influence of these factors may depend on patient-level characteristics including payer mix (e.g., MA beneficiaries are significantly less likely to use post-acute care). Thus, while it is reasonable to specify the measure based on a broad cohort, it will be important to apply a robust risk adjustment to this measure—especially for use in the HRRP.
Comments on MUC2025-055
Vizient supports the agency’s efforts to identify measures to help improve sepsis care. However, the MUC2025-055: Hospital 30-Day, All-Cause, Risk-Standardized Readmission Rate (RSRR) Following Sepsis Hospitalization measure under consideration, which includes patients with a sepsis diagnosis, may be unnecessary. For example, several of the contemplated measures introduce new requirements which appear to overlap with existing measures that hospitals report, such as the Severe Sepsis and Septic Shock: Management Bundle (SEP‑1). Vizient is concerned that introducing multiple new sepsis‑related measures, especially if existing measures are retained, risks increasing burden without clear evidence regarding which measurement approach, if any, will be most beneficial in the context of patient care.
We are also concerned that this and other sepsis-related measures currently under consideration suggest that CMS is seeking to add several measures to different quality programs, which runs counter to the agency’s aims to reduce the overall number of measures, decrease burden and streamline program requirements. Given the overlap with SEP-1 and the significant burden associated with SEP‑1, we suggest retiring SEP‑1 and replacing it with significantly fewer measures.
Vizient also notes that the considered sepsis measures would benefit from undergoing additional review, as these measures have not been used in CMS programs or thoroughly vetted or tested by hospitals. Vizient cautions against advancing measures that have not been rigorously evaluated by experts and tested, as such measures may not achieve their desired outcome, create unintended consequences or prove unworkable in real‑world settings. Vizient believes additional analysis and testing would help to better understand the impacts of these measures, including whether similar benefits can be achieved with fewer measures.
Support for MUC2025-055
The Infectious Diseases Society of America (IDSA), together with our partnering professional societies representing clinicians and researchers involved in sepsis care across healthcare settings, strongly supports CMS’s efforts to advance national sepsis quality measurement. We recognize that no individual measure will be perfect at inception, and that each will require thoughtful implementation, monitoring, and refinement over time. Nonetheless, we believe the propose measure represents an important, necessary step toward improving sepsis care and outcomes. We support CMS moving forward while continuing to engage stakeholders to address implementation challenges, unintended incentives, and equity implications informed by prior experience with national quality measures.
IDSA and our partnering societies support adoption of the measure for 30-Day, All-Cause, Risk-Standardized Readmission Rate Following Sepsis Hospitalization, while recognizing important limitations that warrant careful implementation and interpretation. This measure appropriately recognizes sepsis as a condition associated with substantial post-discharge vulnerability and reinforces the importance of care transitions, recovery, and longitudinal management as integral components of high-quality sepsis care.
A key consideration for this measure is its exclusive reliance on claims-based data for both sepsis identification and risk-adjustment, which – unlike the Adult Sepsis Event (ASE)-based mortality measure – may variably identify sepsis hospitalizations and incompletely capture key aspects of illness severity and clinical complexity. As a result, this measure may be more susceptible to residual confounding and unintended incentives whereby documentation or coding practices may influence measured performance without corresponding improvements in patient outcomes, warranting careful interpretation and ongoing evaluation.
We further emphasize the need to consider equity implications of readmission-based measures. Readmissions following sepsis are strongly influenced by access to post-discharge resources, outpatient follow-up, rehabilitation services, and social determinants of health that vary widely across patient populations and communities. Without careful evaluation, such measures may disproportionately penalize hospitals serving socioeconomically disadvantaged populations. We recommend stratified analyses and ongoing monitoring to assess differential impacts and ensure that this measure promotes equitable improvement rather than widening existing disparities.
Despite these concerns, we view this measure as an important step toward improving continuity of care and accountability across the full sepsis care continuum. As implementation proceeds, we encourage continued refinement to better distinguish readmissions that reflect appropriate clinical responses to disease progression or relapse from those that are associated with unmet post-discharge needs, gaps in care transitions, or system-level barriers to recovery. As electronic clinical data infrastructure continues to mature, we also encourage CMS to explore future ASE-based approaches for sepsis readmission measurement to improve clinical specificity, validity, and harmonization with the ASE-based sepsis mortality measure.
Comments re: MUC2025-055
We ask for a way to exclude patients for medical non-compliance following the index stay if able to be measured.
Hospital 30-Day, All-Cause, RSRR After Sepsis
The Iowa Hospital Association (IHA) appreciates CMS’s efforts to improve care quality and reduce unnecessary readmissions. However, we have significant concerns regarding the proposed measures addressing hospital 30-day, all-cause, risk-standardized readmission monitoring and associated penalties.
External Factors Beyond Hospital Control
A substantial number of providers outside the hospital have influence whether a patient is readmitted within 30 days. Additionally, many readmissions occur for reasons unrelated to the initial procedure. For example, if a patient undergoes a knee replacement and slips on ice 24 days later, this is not due to substandard care or inadequate discharge instructions. Numerous factors, including patient lifestyle choices, are beyond the hospital’s ability to mitigate.
Unreasonable Strain on Hospitals
While commercial insurers have adopted 30-day all-cause readmission penalties, extending this approach to Medicare would impose a disproportionate financial strain on safety-net and rural hospitals. These facilities serve low-income, medically complex, and vulnerable patients, yet often have fewer resources to invest in care-coordination programs that help prevent readmissions. As a result, they face a higher risk of penalties despite delivering high-quality care, threatening their financial stability and ability to sustain essential services.
Need for Clear Guidelines and Appeals Process
If CMS proceeds with these measures, clear and detailed guidelines must be established regarding penalties, as well as fair and timely appeal processes. CMS should also define timelines for review to ensure due process for hospitals.
Recommendation for Shorter Evaluation Window
We strongly recommend limiting evaluation to readmissions occurring within a shorter timeframe, such as 7–14 days post-procedure. This would more accurately reflect care quality and reduce the impact of unrelated events.
IHA encourages CMS to reconsider the application of these measures as currently proposed. If implemented, they should include firm guidelines, fair appeal processes, and a reduced evaluation window to ensure alignment with factors hospitals can reasonably influence.
Premier has concerns that…
Premier has concerns that this proposed measure population does not align with the SEP-1 chart abstracted measure. When the “same” population is measured, the cohorts should align. It creates undue administrative burden for hospitals to create multiple populations to mirror CMS measure denominators for the same condition. It is also inappropriate to consider this for the HRRP program until results have been publicly reported through the IQR program to allow hospitals time to understand the measure and work improvement. CMS should not implement this measure as currently specified until these issues have been addressed.
Premier questions the application of this quality measure for improvement purposes when the data lags by two years. This can impact both the observed performance by not reflecting today’s outcomes and the risk adjustment by using older data to create expected values for more recent patients. Premier has also observed that the risk standardized results do not change much over time and may not reflect performance improvement because it is heavily driven by the random effect in the model. The use of the Predicted to Expected ratio rather than the Observed to Expected ratio, while helpful to reduce undue influence from outliers, does not provide a good reflection of actual performance. Consequently, CMS should emphasize that this methodology is best suited for payment purposes and not quality improvement purposes. The utility of the measure is further hindered by the facility level hierarchical methodology, which does not allow for drill downs into further subgroups, e.g. by physician grouping.
Comment on Proposed Sepsis Measures
I am writing as a member of the Board of Directors of Sepsis Alliance to offer my appreciation for the work being done to improve outcomes for patients with sepsis and reduce the financial and human cost of sepsis in the United States. I believe that the proposed measures, if adopted in addition to the existing process measure, SEP-1, will help achieve this goal. If, however, the proposed measures are adopted as a replacement to the existing accountability measure represented by SEP-1, we will do a disservice to patients with sepsis.
Sepsis is a medical emergency that requires timely recognition and treatment. During the first Trump Administration, important work was done by CMS to analyze the cost to Medicare of care for patients with sepsis. That tabulation documented a cost in excess of $40 billion per year in costs for in-patient hospital admission and subsequent skilled nursing facility admission for Medicare patients. Clearly, this is a significant problem that must be addressed.
I support the CDC Core Elements to assess sepsis care structure and outcome measures such as risk-adjusted mortality and 30-day all-cause readmissions. These measures are important but not sufficient on their own. Quality measurement must reflect structure, process, and outcomes.
Process measures remain essential to ensure timely and appropriate care for individual patients. SEP-1 is the only nationally standardized process measure for sepsis and provides critical accountability.
New structural and outcome measures should be adopted alongside SEP-1, not in place of it. Maintaining all three elements of measurement is essential to protecting patients, saving lives, reducing costs and improving sepsis care nationwide.
Society of Infectious Diseases Pharmacists Comment
The Society of Infectious Diseases Pharmacists (SIDP), together with our partnering professional societies representing clinicians and researchers involved in sepsis care across healthcare settings, strongly supports CMS’s efforts to advance national sepsis quality measurement. We recognize that no individual measure will be perfect at inception, and that each will require thoughtful implementation, monitoring, and refinement over time. Nonetheless, we believe the propose measure represents an important, necessary step toward improving sepsis care and outcomes. We support CMS moving forward while continuing to engage stakeholders to address implementation challenges, unintended incentives, and equity implications informed by prior experience with national quality measures.
SIDP and our partnering societies support adoption of the measure for 30-Day, All-Cause, Risk-Standardized Readmission Rate Following Sepsis Hospitalization, while recognizing important limitations that warrant careful implementation and interpretation. This measure appropriately recognizes sepsis as a condition associated with substantial post-discharge vulnerability and reinforces the importance of care transitions, recovery, and longitudinal management as integral components of high-quality sepsis care.
A key consideration for this measure is its exclusive reliance on claims-based data for both sepsis identification and risk-adjustment, which – unlike the Adult Sepsis Event (ASE)-based mortality measure – may variably identify sepsis hospitalizations and incompletely capture key aspects of illness severity and clinical complexity. As a result, this measure may be more susceptible to residual confounding and unintended incentives whereby documentation or coding practices may influence measured performance without corresponding improvements in patient outcomes, warranting careful interpretation and ongoing evaluation.
We further emphasize the need to consider equity implications of readmission-based measures. Readmissions following sepsis are strongly influenced by access to post-discharge resources, outpatient follow-up, rehabilitation services, and social determinants of health that vary widely across patient populations and communities. Without careful evaluation, such measures may disproportionately penalize hospitals serving socioeconomically disadvantaged populations. We recommend stratified analyses and ongoing monitoring to assess differential impacts and ensure that this measure promotes equitable improvement rather than widening existing disparities.
Despite these concerns, we view this measure as an important step toward improving continuity of care and accountability across the full sepsis care continuum. As implementation proceeds, we encourage continued refinement to better distinguish readmissions that reflect appropriate clinical responses to disease progression or relapse from those that are associated with unmet post-discharge needs, gaps in care transitions, or system-level barriers to recovery. As electronic clinical data infrastructure continues to mature, we also encourage CMS to explore future ASE-based approaches for sepsis readmission measurement to improve clinical specificity, validity, and harmonization with the ASE-based sepsis mortality measure.
MUC2025-055 measure
Support with modification: Supports imporance of this measure outcomes, however it is primarily driven by inpatient care delivery. Recommend cautious approach for MA Stars if used.
Implementation of RSRR reporting
I am retired research microbiologist and member of the Sepsis Alliance Advisory Board. From my 26 years of experience in Pharma developing new antibiotics and vaccines to prevent the devasting impact of Sepsis pathogens, I welcome new policies that seek better outcomes for patients at risk of developing sepsis.
It is vital that hospitals and insurance companies are held accountable for rigorous sepsis care structure and outcome measures such as risk-adjusted mortality and 30-day all-cause readmissions. However, these new proposed measures are important but not sufficient on their own. SEP-1 is the only nationally standardized process measure for sepsis and provides critical accountability. New structural and outcome measures should be adopted alongside SEP-1, not in place of it. Maintaining all three elements of measurement is essential to protecting patients and improving sepsis care nationwide. I urge those responsible for setting policy at the federal level to ensure that SEP-1 remains a core element of sepsis control policy.
Robert G.K. Donald Ph.D.
Sepsis readmission measure
I am a pulmonary/critical care physician who has cared for 1000s of sepsis patients. I am also a board member of Sepsis Alliance.
Sepsis is a medical emergency that requires timely recognition and treatment. Quality measurement must reflect structure, process, and outcomes.
I support the CDC Core Elements to assess sepsis care structure and outcome measures such as risk-adjusted mortality and 30-day all-cause readmissions. These measures are important but not sufficient on their own.
Process measures remain essential to ensure timely and appropriate care for individual patients. SEP-1 is the only nationally standardized process measure for sepsis and provides critical accountability.
New structural and outcome measures should be adopted alongside SEP-1, not in place of it. Maintaining all three elements of measurement is essential to protecting patients and improving sepsis care nationwide.
Jim O'Brien
Sepsis Measures
I speak to you today as a sepsis survivor, the father of a 23-year-old daughter who died from septic shock after a hemorroidectomy, a brother who died from a UTI, and the Founder of the Sepsis Alliance. I know professionally that lives are saved when sepsis is recognized early and treated with timely, evidence-based care.
Sepsis is a medical emergency. Delays of even hours lead to organ failure, amputations, cognitive decline, prolonged ICU stays, and death. Families are left with lifelong consequences—whether from loss, disability, or trauma—when timely care doesI know—personally and not happen.
That is why, how we measure sepsis care matters.
Quality measurement must include structure, process, and outcomes. I support the CDC Core Elements that assess sepsis care infrastructure and outcome measures such as risk-adjusted mortality and 30-day all-cause readmissions. These measures are essential—but they tell us only what happened after the fact.
Process measures ensure action in the moment. They help make sure that a patient with worsening vital signs or altered mental status receives timely antibiotics, fluids, and escalation of care when every hour matters. SEP-1 is currently the only nationally standardized sepsis process measure, and it provides essential accountability for bedside care—especially for patients who cannot advocate for themselves.
Weakening or replacing process measurement would have real consequences: more missed sepsis, more delayed treatment, more preventable organ failure, and more families facing outcomes that did not have to happen.
New structural and outcome measures should be adopted alongside SEP-1, not in place of it. Maintaining all three elements of measurement is essential to protecting patients and improving sepsis care nationwide.
Sepsis Alliance Comment
On behalf of Sepsis Alliance, the nation’s leading nonprofit organization dedicated to saving lives and limbs from sepsis, we appreciate the opportunity to comment on CMS’s approach to sepsis quality measurement. We represent millions of sepsis survivors, caregivers, and families, and work closely with clinicians and policymakers to improve sepsis care across the country.
The quality improvement framework established by Avedis Donabedian emphasizes three essential components of high-quality care: structure, process, and outcomes. Sepsis Alliance supports the CDC Core Elements as an effective framework for measuring the structure of sepsis care, and we endorse the proposed outcome measures of risk-adjusted mortality and 30-day all-cause readmissions, with minor refinements.
However, structural and outcome measures alone are insufficient. They do not assess the processes of care delivered to individual patients, which are critical in a time-sensitive condition such as sepsis. These measures cannot replace SEP-1, which remains the only nationally standardized process measure holding hospitals accountable for timely and appropriate sepsis care.
Sepsis Alliance strongly supports adoption of the proposed structural and outcome measures alongside SEP-1, not in place of it. Maintaining all three domains of measurement is essential to ensure accountability, consistency, and continued improvement in sepsis care. If CMS adopts and sustains this comprehensive approach, it will be fulfilling its duty to the American public
Sepsis Measures
Sepsis is the #1 cause of hospital deaths in the U.S. and is the #1 cost of acute care. It is also the #1 cause for expensive and burdensome hospital readmissions with 40% of survivors requiring readmission within 90 days. Further, sepsis is the #2 cause of maternal mortality in the U.S., takes more children's lives than cancer, and disproportionately burdens our underserved communities across the nation.
We have to do better.
Sepsis is a medical emergency that requires timely recognition and treatment.
If we are going to be serious about reduce harm from sepsis, quality measurement must reflect structure, process, and outcomes.
I support the CDC Core Elements to assess sepsis care structure and outcome measures such as risk-adjusted mortality and 30-day all-cause readmissions. These measures are important but not sufficient on their own.
Process measures remain essential to ensure timely and appropriate care for individual patients. SEP-1 is the only nationally standardized process measure for sepsis and provides critical accountability. Research has show SEP-1 to be effective at saving lives without increasing the use of antimicrobials. Its addition to VBP will further secure its place as a critical component of sepsis care in the United States, and we look forward to continuing to revise and improve this measure as we continue to learn more about sepsis and we have more tools to assist it its diagnosis.
New structural and outcome measures should be adopted alongside SEP-1, not in place of it. Maintaining all three elements of measurement via these four measures is essential to protecting patients and improving sepsis care nationwide.
Readmission measurement for sepsis
As an advanced practice nurse who has been working on sepsis since 2004, sepsis readmission is one of the highest disorders that are readmitted in under 30 days at roughly 20%--organizations need an incentive to pay attention and design programs to support the transition of the sepsis patient better. This measure will do that
30-Day Mortality Rate Following Sepsis Hospitalization
The American Occupational Therapy Association (AOTA) supports capturing data for Medicare Advantage (MA) beneficiaries in the Hospital 30-Day, All-Cause, Risk-Standardized Mortality Rate (RSMR) Following Sepsis Hospitalization measure. Including MA data is critical to providing a complete and accurate picture of outcomes, given the growing enrollment in MA plans. This addition will enhance transparency, allow for meaningful comparisons across coverage types, and ensure accountability for all payers to cover necessary, high-quality care provided to Medicare beneficiaries.
MUC2025-055
The measure excludes hospitals that transfer patients onward for their sepsis care. I believe that it should exclude these patients from the receiving hospital's evaluation, as well. In these cases, patients are most commonly discharged to their home communities, and the post-discharge care will be up to their own primary care provider. The receiving hospital and its physicians can play only a very small role in readmission prevention by communicating with the patient's home provider.
This may not be my only critique, but it is a flaw that is readily discernible on a first reading.