PRMR MUC List Commenting

My name is Lee Murray. Patient safety is important to me because I have several family & friends who have had adverse experiences related to patient safety. Some were injured, some neglected, and in some instances these resulted in death. 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.

We are deeply concerned about a survey that focuses on measuring the "perceived life goals" of individuals on dialysis. How will this information be used to improve their care? When will it be asked? What actions will the dialysis staff take based on these survey results? Will there be follow-up to assess if patients achieve their goals? We frequently receive calls and emails from individuals on dialysis who face major challenges regarding housing, food security, and transportation, seeking assistance. By asking these questions, the dialysis facility may inadvertently raise expectations for potential support, leading to strain in patient-professional relationships.  See full commetts that explain why we came to this conclusion.  

We are deeply concerned about a survey that focuses on measuring the "perceived life goals" of individuals on dialysis. How will this information be used to improve their care? When will it be asked? What actions will the dialysis staff take based on these survey results? Will there be follow-up to assess if patients achieve their goals? We frequently receive calls and emails from individuals on dialysis who face major challenges regarding housing, food security, and transportation, seeking assistance. By asking these questions, the dialysis facility may inadvertently raise expectations for potential support, leading to strain in patient-professional relationships.  See Full comments.  Sorry if duplicate. It says "save" and not "send" so a bit confusing.  

To whom it may concern,

Attached is the letter to adopt the expanded Global Malnutrition Composite Score in the CMS
FY 2024 Hospital Inpatient Quality Reporting Program. 

Thanks. 

Patients are already dealing with survey burnout that rarely include follow up to our responses. This measure has good intentions but is misunderstanding the needs of dialysis patients. Stability and good health must be prioritized before thinking about life goals. More importantly, there is much that can be improved about overall quality of treatment and care. Perhaps thoughtful and intentional conversations by staff members could better address these needs.  

Thank you for soliciting comments on PSSM 2023-188. I have studied the measure. I am in favor of the measure in general but have these comments that would improve it:

1. I wish it weren't an attestation based measure. Those rely on honesty  and asking hospital personnel to admit their shortcomings is something that is foreign to my experience. I know that sometimes one needs to walk before one runs, but an attestation based guideline will likely not succeed well. 
2.  The goal of zero preventable harm should be front and center. It is the most important aspect that all need to be reminded of. 
3.  Domain 2, para 3, the statement is internally inconsistent. One can't have a culture that balances "no blame" and "appropriate accountability." If someone makes a big mistake that causes patient harm, there must be accountability. This is properly recognized in Domain 4, "accountability for outcomes... represents the cornerstone of a culture of safety." The "no blame" language should be eliminated. 
4.  The second and third paragraphs in Domain 4 are redundant. 
5.  Making patient safety metrics public in hospital units is helpful but not enough (Domain 4, para. 3). By then, it might be too late for the patient to move to another safer hospital (if one is available). The information should be available on the hospital's website for public access. 
6.  I applaud Domain 5 re engagement. Para 1 mentions, as it should, participation of the community. The measure does not suggest how Patient and Family Advisory Councils should be set up or organized and it should to help spur accountability. 
7.  Thank you!!

My name is Heather Gocke.  Patient safety is important to me because I work closely with hospitals and healthcare entities to embed best practices and in doing so, avoid patient harm. I am a Patient Safety Champion with Patients for Patient Safety US, which is a patient led network of people who feel that making healthcare safer is an urgent priority.  My mother was harmed in healthcare which left her brain damaged and while my life's purpose has been to prevent these errors from occurring (primarily due to well-meaning people practicing within a faulty system), I could not prevent this from happening to the most important person in my life, my mother. In addition, 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.

6.    It is a fundamental moral and ethical responsibility to deliver safe care.

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

Heather Gocke, M.S., RN

Patient and Employee Safety Advocate

Daughter, mother and grandmother

Vice President, Risk Management and Safety 

On commenting on behalf of my daughter who did dialysis for a year. Asking a patient about their life goals is a very slippery slope. How is her providers plan to improve her care with this information? If she has given up hope and is young and can't do things her friends do, will they quit trying to help her? Everyone has bad days! When you have a chronic illness you have MORE bad days!!! I hate that people living with kidney disease may be penalized or treated "less than" if they don't have a positive life goal. Sometimes, their goal is to get out of bed and get to work and then go immediately back to bed because that is all the energy she has. How about asking questions that will improve her care? How about asking her, how was your treatment today - like a Yelp review. Recording her feedback and following perceptions in her care could result in better care. Asking her "life goals" is like asking her "what do you want to be when you grow up"? It doesn't matter if she's a secretary or president of the United States. She needs to GROW UP first.

My name is Ed Hopfer, Patient safety is important to me because as an elected board member for our local hospital I see the need for change in the healthcare system for patient protection. 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.

I support the proposed structural measures because, as a psychotherapist with specialty in trauma, I have seen the lifelong mental/emotional impact hospitals' lack of accountability, transparency, or responsibility to improve vulnerabilities has on families and patients. Healthcare is a central part of society and the way these systems manage errors has ripple effects across multiple layers of societal well-being.

My name is Tracy.  Patient safety is important to me because I was permanently disabled by a surgeon who had a track record of unsafe care. Despite me making several complaints to the state they didn't see anything wrong with the surgeon removing the wrong organ without realizing it. This has caused me extreme frustration and distrust in the medical world as well as the licensing boards and staff hired to protect the general public.  As a result I have become passionate about advocating and working towards safer care for everyone.  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.  The head administrators at the hospital where my harm occurred knew the surgeon was dangerous and did nothing to prevent him from hurting others. 
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. I don't believe the hospital that my never event happened at had a culture of safety.  If they had, my harm could have been significantly less or even avoided.  So many things were missed or ignored during my event that no one can even fathom how it happened! 
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.  It would be great if the injured or public could also learn about what was reported or the outcome, so they know what is being done to prevent future harm.  I don't know if this hospital even reported my event, and if they did, I have gained no peace of mind by because I have not been told what is being done to protect others. This is very disconcerning. 
5.     Hospitals should engage the patients and families they serve in patient safety work, including in reporting patient safety experiences and outcomes related to patient safety and discrimination.  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 partner and I have been together for 20 years, and we are still encountering anti-LGBTQ+ discrimination and unequal treatment by one of the hospitals in Manchester.  

Also, we have just moved my brother-in-law from Mass to New Hampshire into a wonderful Senior assisted housing.  The health care and social work in Mass were horrible.  I know that the health care in both states is overloaded and stretched to the max.  But something needs to be done.   Too many lower-income, elderly patients are suffering because of it.

This work is essential for this population. When it comes to medicine, in general, it is better to be proactive versus reactive. If we can be proactive in the care of 65+ year old's, then we will see them have a greater quality of life wherever they consider "home" and will see a decrease in hospitalizations and admissions to Critical Care settings, increase in patient/chosen family's overall satisfaction and overall cost savings. 

Large numbers of patients continue to suffer harm in US hospitals each year.  To "move the needle" on improving patient safety, we need large-scale, systematic efforts. I am writing in support of the Patient Safety Structural Measure (#MUC2023-188) on the CMS list of
Measures Under Consideration. The reasons I support the measure is it reflects the kinds of patient safety best practices I
believe patients in the United States deserve. 

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 engage the patients and families they serve in patient safety work, as
recommended by the President’s Council of Advisors on Science and Technology. 
 

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

I am writing in support of the proposed CMS Patient Safety Structural Measure (PSSM).  Increasingly, patient safety advocates in the U.S. are calling upon healthcare leaders to reveal how their organizations manage patient safety risks;  to demonstrate that their organizations continuously analyze qualitative and quantitative data from routine operations to identify and mitigate conditions that predispose patient or provider harm, while assuring the effectiveness of their efforts. The Patient Safety Structural Measure would support this urgently needed transparency and boost ongoing efforts to adapt, implement, and strengthen systemic management of patient and provider safety in U.S. healthcare organizations.  The inadequacy of current measures, for these purposes, is underscored by the following excerpt about patient safety “grades” from a commentary in the Betsy Lehman Center for Patient Safety’s newsletter. 

“ .. a hospital’s ‘A’ safety rating reveals that it can manage reported measures of safety, but not its ability to manage risk and safety. Prospective patients might assume two facilities that earn ‘A’ ratings are equivalent, although only one may meaningfully attend to unsafe conditions that are not measured as part of achieving that grade. We need to move from weak proxies for an organization’s “safety health” toward measures and ratings that reveal the relative power of an organization’s philosophy and methods for safety management, which operate in the background, invisible to the public.”

Despite more than two decades of improvement efforts we continue to experience horrific rates of preventable patient injury and death, largely due the failure to compel implementation of systemic safety management structures and practices within U.S. healthcare organizations. The Patient Safety Structural Measure will provide critical leverage in efforts nationwide to foster and strengthen the work of establishing systems-based safety management as the norm in U.S. healthcare organizations.  

My name is John Laurence Adams. Six years ago I lost my wife of 25 years to a medical error and was appalled by the suppression of information by hospitals and their lack of transparency.  Our grief was exacerbated by our lack of information.  I am so pleased with the PSSM measures and fully support them since hospital boards and executives will have to finally address their hidden patient safety problems in a systematic way.  

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.
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. In addition, the PSSM aligns with other national guidance such as the Safer Together: The National Action Plan to Advance Patient Safety, the CMS National Quality Strategy, and the September 2023 Report to the President: A Transformational Effort on Patient Safety, issued by the President’s Council of Advisors on Science and Technology.
For all these reasons I strongly support the Patient Safety Structural Measure. Thank you for this opportunity to make this public comment.

My goals

Feel better

Enough money to pay bills

Kidney transplant 

Find a life partner 

Good mental health 

1. Does CMS intend to use this new composite to replace the current Care Transitions Sub Measure and/or the Discharge Information Sub Measure, OR is this intended to be an additional Sub Measure? We ask because this proposed Sub Measure has overlap with both of those two existing Sub Measure, as well as overlap with the new proposed Information About Symptoms sub measure.  Specifically the measures asking about what happens after leaving the hospital.  All questions that relate to discussions with the patient and their caregivers about the post-discharge experience should be part of a single Sub Measure, rather than spread across multiple sub-measures.   
2. We do appreciate the addition of the first two Care Coordination Sub Measures as we think collaboration is an important aspect of high quality care. 

I am writing to advocate for acceptance of  MUC2023-188, The Patient Safety Structural Measure

Increasingly, patient safety advocates in the U.S. are calling upon healthcare leaders to reveal how their organizations manage patient safety risks;  to demonstrate that their organizations continuously analyze qualitative and quantitative data from routine operations to identify and mitigate conditions that predispose patient or provider harm, while assuring the effectiveness of their efforts. The Patient Safety Structural Measure would support this urgently needed transparency and boost ongoing efforts to adapt, implement, and strengthen systemic management of patient and provider safety in U.S. healthcare organizations.  The inadequacy of current measures, for these purposes, is underscored by the following excerpt about patient safety “grades” from a commentary in the Betsy Lehman Center for Patient Safety’s newsletter. 

“ .. a hospital’s ‘A’ safety rating reveals that it can manage reported measures of safety, but not its ability to manage risk and safety. Prospective patients might assume two facilities that earn ‘A’ ratings are equivalent, although only one may meaningfully attend to unsafe conditions that are not measured as part of achieving that grade. We need to move from weak proxies for an organization’s “safety health” toward measures and ratings that reveal the relative power of an organization’s philosophy and methods for safety management, which operate in the background, invisible to the public.”

Despite more than two decades of improvement efforts we continue to experience horrific rates of preventable patient injury and death, largely due the failure to compel implementation of systemic safety management structures and practices within U.S. healthcare organizations. The Patient Safety Structural Measure will provide critical leverage in efforts nationwide to foster and strengthen the work of establishing systems-based safety management as the norm in U.S. healthcare organizations.   

Quality measures for two common oral diseases, caries and periodontal disease, should be included for a patient or population, as part of MUC, CBE ID 2517 :  Oral Evaluation, Dental Services https://p4qm.org/measures/2517, including prevalence at evaluation and incidence at follow-up.  These two diseases are among the most common causes causing morbidity, including pain, and function, among Americans and can impact malnutrition. Both the ICDAS measurement system for caries assessment, based on the anatomy of three layers of the tooth, and the consensus American Academy of Periodontology definition of periodontal disease should be used for baseline and follow-up assessment for quality measures, along with qualitative assessment of dry mouth to ensure comfort in eating for the MUC for 2024. Since the population prevalence for caries is nearly universal over a lifetime, more than 90%, and over 45 million adult Americans over 35 have periodontal diseases, it is essential that baseline and follow-up quality measures for caries and periodontal assessments become part of oral evaluation, and quality measures. It is puzzling why they are not included in these important patient-centered health outcomes, as oral disease is among the leading causes of morbidity among Americans.       

I just completed my 4th time on dialysis which was 6 years  while battling metastatic melanoma. I received my 2nd transplant last year. 

I have a lot of concerns with "life goals". To start with we are regular people who happen to be on dialysis. Many patients are battling several other comorbidities. I would say most patients life goals are to complete treatment each day, be able to put food on the table and pay for all their medications. What is your goal with our goal? How will this help improve our care? Once patients have met their basic needs and are stable and feeling ok on dialysis then perhaps discuss some life goals. 

See attachment

see attachment

The measure assesses hospital commitment to improving care for patients >= 65 years of age receiving services in the hospital, operating room, or emergency department.  To the extent that this is a hospital measure and includes development of protocols to implement several individual measures, please consider a requirement for Domain 5 (Age-Friendly Care Leadership) that a geriatrician be required at the hospital to lead the work. 

 I am attaching a letter of support for Policies-and-Procedures-for-Pre-Rulemaking-Measure-Review and-Measure-Set-Review being considered by CMS.

Please consider the attached letter of support for CMS measures.

My name is Sue Sheridan.  Patient safety is important to me because my family experienced 2 separate medical errors that resulted in the permanent brain damage of my newborn son and the death of my late husband.  I was so let down by the healthcare system that I once trusted implicitly.  Through those experiences there were many lessons learned. Among many, I learned that no-one was in charge of patient safety at the leadership level and that patient safety was not a priority at the governance level.  I learned the chilling truth - that truth telling was not mandatory and disclosing to patients and families when harm occurred was “optional”. I know of no other industry or professional where honesty was “optional”. I learned that well known evidence-based practices are often not followed or even implemented. I learned that there was no mechanism in place for me to report the harms for learning purposes to help prevent other babies and daddies from suffering the same harm.

Given the above, 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.  I expect:

• The C-suite and the governing board to be “in charge” and held accountable for reducing harm to patients
• Absolute transparency. I ALWAYS expect to be told the truth about the events that led to harm of our loved ones and that Communication and Resolution Programs are mandatory in all institutions 
• Health care systems to invite diverse patients, families, communities, and civil society into their world to help redesign equitable, safe care that aligns with what matters most to them.
• Health care systems to learn from the experiences and outcomes of patients who are harmed and there are reporting and learning systems to which   patients and families can report. 
• Evidence based practices known to prevent high harms are implemented and enforced.
• Reporting of harm to state, federal and accrediting bodies ….and the public 

The harms that occurred to my family were 28 and 22 years respectively, however, I have not seen the robust urgent changes in our healthcare system that we all deserve. It is more than disappointing. For all these reasons I strongly support the Patient Safety Structural Measure.  Thank you for this opportunity to make this public comment.

Sue Sheridan

Patients for Patient Safety US

As the care partner for my husband who is on in center hemodialysis, i want to comment on the “regular person vs. those persons on dialysis”statement. This dichotomy is stigmatizing as it makes dialysis patients feel like they’re “ not regular or normal” people.. This should be excluded from the Life Goal statement and replaced with a correct statement. 

Are these new measures are intended to be in addition to measures that measure the similar or same contract that are part of the current CAHPS Hospice Survey, or are they intended to replace them?  Specifically:

1. The question “Did the hospice team make an effort to listen to the things that mattered most to you or your family?“ sounds very similar to Q14 (“How often did the hospice team listen carefully to you when you talked with them about problems with your family member’s hospice care?”) that is part of the current Communication with Family Composite.

2. The question “Did the hospice team provide care that respected your family member’s wishes?” sounds similar to Q11 (“While your family member was in hospice care, how often did the hospice team treat your family member with dignity and respect?) that is part of the current Treating Patient with Respect Composite.

Thank you.

The John A. Hartford Foundation and our partners write to express support for the inclusion of the Age-Friendly Hospital measure in the CMS Hospital Inpatient Quality Reporting (IQR) Program. This new type of measure, a “programmatic composite” measure, 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.

We appreciate the opportunity to share our strong support for the Age-Friendly Hospital measure for inclusion in the CMS Hospital IQR program. The measure is a critical piece in the optimization of care for older patients using a holistic approach to create a quality program that better serves the needs of this unique population. We believe these measures will help build a better, safer environment for the geriatric patient, and when the information is shared publicly, it will help patients and caregivers know where to get best care that is in line with their values.

My name is  Thomas J. Dammrich.  I am an advocate for Patient safety which is important to me because of an experience with my brother.  A routine laminectomy turned into 30 days in the hospital and a total lack of regard for patient safety nearly killed 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:
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 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 focusing 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
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.

On behalf of the Collaborative for Accountability and Improvement, I am writing in support of the Patient Safety Structural Measure (#MUC2023-188) on the CMS list of Measures Under Consideration. 

Having this measure in place would shine a light on the range of critical actions that organizations can take to ensure patient safety, including:

1. Actively engaging hospital leaders and boards of directors to prioritize patient safety and make sure the right safety practices are in place. 
2. Supporting hospitals in adopting “zero preventable harm” as their patient safety strategic goal, as recommended in the CMS National Quality Strategy. 
3. Advancing the importance of a culture of safety that engages all 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. Ensuring that hospitals have systems in place for reporting harm events and being open and honest with patients and the public when harm events occur. 
5. Engaging patients and families in meaningful ways that improve patient safety for all.

In particular, I write in support of Domain 4: Accountability and Transparency which would require hospitals to attest to having a defined, evidence-based communication and resolution program that is reliably implemented after harm events. When something goes wrong during healthcare, the best response is timely and compassionate, and promotes healing for all involved. CRPs guide this response, seeking to meet the current and future needs of patients and families through transparent and ongoing communication about what went wrong and an exploration of what will lead to resolution and healing. CRPs promote healing and diminish provider trauma and burnout by proactively offering support following an unintended harm event. Increasingly viewed as the future of healthcare, CRPs are integral to improving patient safety and preventing unintended harm, and are endorsed and adopted by leading national organizations and health systems.

The Collaborative for Accountability and Improvement: A Program of UW Medicine is dedicated to accelerating the spread of effective CRPs to healthcare organizations everywhere.

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

Leilani Schweitzer

President, CAI Board of Directors

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.

see attached for both

Pain Management for Breast Cancer Treatment (MUC2023-162) and 

Fatigue Management for Breast Cancer Treatment.(MUC2023-190) 

Please find attached comment letter. 

Please find attached comment letter.

On behalf of our 40,000 members, the American College of Emergency Physicians (ACEP) appreciates the opportunity to comment on the 2023 Measures Under Consideration list. Our comments, attached in the document below, are limited to the measures specifically pertinent to emergency medicine. 

On behalf of our 40,000 members, the American College of Emergency Physicians (ACEP) appreciates the opportunity to comment on the 2023 Measures Under Consideration list. Our attached comments are limited to the measures specifically pertinent to emergency medicine. 

The St. Louis Area Business Health Coalition represents employers and purchasers of health care and strongly supports patient-reported outcome measures, including this measure for fatigue management in oncology patients. Purchasers believe PROMs are an essential element in the new CMS Enhancing Oncology Model. Keeping the patient at the center of care, especially oncology care, is essential to tracking overall quality of life and care as treatment progresses. Adoption of PROMs presents an opportunity to advance patient-centered priorities and address overall quality of life while patients manage the side effects of various treatment regimens. While there are quality measures for palliative and end of life care, few oncology measures address quality of care during curative treatment or other patient-centered elements, such as effective symptom management related to overall function. The measure being considered directly addresses this concern related to fatigue in patients undergoing breast cancer treatment. It would provide a standard way for the care team to assess and track patient fatigue and adjust management strategies accordingly. On a broader scale, eliciting and quantifying patient ratings of symptom management can improve health equity by helping patients articulate their priority symptoms to their doctors. 

The St. Louis Area Business Health Coalition represents employers and purchasers of health care and strongly supports patient-reported outcome measures, including this measure for pain management in oncology patients. Purchasers believe PROMs are an essential element in the new CMS Enhancing Oncology Model. Keeping the patient at the center of care, especially oncology care, is essential to tracking overall quality of life and care as treatment progresses. Adoption of PROMs presents an opportunity to advance patient-centered priorities and address overall quality of life while patients manage the side effects of various treatment regimens. While there are quality measures for palliative and end of life care, few oncology measures address quality of care during curative treatment or other patient-centered elements, such as effective symptom management related to overall function. The measure being considered directly addresses this concern related to pain in patients undergoing breast cancer treatment. It would provide a standard way for the care team to assess and track patient pain and adjust management strategies accordingly. On a broader scale, eliciting and quantifying patient ratings of symptom management can improve health equity by helping patients articulate their priority symptoms to their doctors. 

The Center to Advance Palliative Care (CAPC) is pleased to submit these comments in support for the Age-Friendly Hospital Measure and its inclusion in the Hospital Inpatient Quality Reporting Program. Please contact us if you have any questions.

I support Patient Safety Structural Measure Number MUC2023-188.

Florence LeCraw MD Georgia State University & Northside Hospital Healthcare System

Encompass Health appreciates the opportunity to respond to the Partnership for Quality Measurement (“PQM”) 2023 measures under consideration list.  Encompass Health is one of the nation’s leading providers of post-acute care (“PAC”). We provide inpatient rehabilitation services to thousands of Medicare beneficiaries every day, operating 161 freestanding medical rehabilitation hospitals (referred to by Medicare as inpatient rehabilitation facilities, or “IRFs”) in 37 states and Puerto Rico. We provide critical medical and rehabilitation services to patients enrolled in Medicare Advantage (“MA”) and the traditional Medicare fee-for-service (“FFS”) programs. In 2022, Encompass Health’s rehabilitation hospitals discharged 211,103 patients from our hospitals, 128,098 of whom were Traditional Medicare beneficiaries and 32,068 of whom were MA enrollees.

            Our comments focus on the Level 1 Denials Upheld Rate for Medicare Part C & D (MUC2023-212).

Level 1 Denials Upheld Rate for Medicare Part C & D (MUC2023-212)

Encompass Health supports the inclusion of the Level 1 Denials Upheld Rate for the Medicare Part C and D plans in Star Ratings.  This measure, which would give the percentage of level 1 appeals where a plan’s determination to deny coverage was “upheld” by the plan out of all reconsideration requests made, would increase transparency around MA plans’ decisions to deny coverage of care.  This would build upon the current measure in the Stars program, which looks at the care denial decisions upheld by an independent review entity (“IRE”), a level 2 appeal.  Understanding how often MA plans uphold their initial denials will help beneficiaries understand if their MA plan may be denying necessary, and sometimes critical care, care at high rates if it shows that MA plans have a low rate of upholding their initial denial.  Denying a request for coverage which is subsequently overturned on a level 1 appeal impacts the quality of care a beneficiary receives by causing unnecessary delays in care. 

As the MA program continues to grow, now covering more than half of beneficiaries enrolled in Medicare, it is important to provide information to judge the quality of care they may receive from an MA plan and this measure will provide additional insight into MA plans’ prior authorization and coverage of care processes.  Right now, MA plans are required to submit aggregate organization determination data to CMS, but this data is not publicly shared in a manner that would be usable by MA beneficiaries to compare MA plan quality. According to an analysis of this MA data from 2021 by KFF, just 11 percent of prior authorization denials were appealed, but the vast majority of those (82 percent) were fully or partially overturned by the MA plan.  By including this measure in the Medicare Part C and D Star ratings it will help beneficiaries differentiate among MA plans on their quality of providing timely access to care.  While we support this measure, we also believe additional service-specific data on prior authorizations is needed to fully understand which items and services MA plans may be denying more frequently and then overturning upon appeal.  Having this specific data rather than aggregate totals would provide further clarity for beneficiaries on MA plan quality surrounding access to care for specific items and services beneficiaries may need. 

Conclusion

Thank you for your time and attention to our comments in support of the Level 1 Denials Upheld Rate for Medicare Part C & D measure under consideration. Should you wish to discuss the issues or suggestions raised herein in further detail, please feel free to contact me via phone (202) 368-3752 or email [email protected].

I am advocating for a strict measure of knowing a patient's goals by measuring the percentage of patients with filed Advanced directives and secondly, measure how often they were activated in a timely manner and followed from one setting to the next, i.e., from hospital to rehab to nursing home.  The same would be true for a POLST form if applicable.

My name is Christy Jerz. I am writing in support of the Patient Safety Structural Measure (#MUC2023-188) on the CMS list of Measures Under Consideration. Patient safety is important to me because a dear friend lost a child due to a series of mistakes at two different hospitals. 

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 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.

Dear MUC reviewers,

My name is Sigall Bell. I am writing as a physician and 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 have been working in patient safety for nearly two decades and during that time I have learned that patients provide a critical and complementary perspective to help improve patient safety. Particularly in ambulatory care, where events transpire in the space between visits, in addition to during care episodes themselves, patients often observe key issues relevant to their safety that clinicians and organizations may not observe. In our research we have discovered that patients can identify these critical "blindspots," such as omissions, breakdowns or delays in tests or referrals, errors in documentation, etc. Some patients only discovered blindspots after reading their notes because they had no other way of knowing that their providers recorded the wrong symptoms or history, or missed the main concern altogether.  In other words, sharing notes is a critical way for patients to gain context about what providers know and then help to fill in gaps.  

This structural measure includes important steps in helping to standardize the ability for patients to become supported safety partners. This cannot be done without transparent information sharing and mechanisms to receive and respond to patient feedback, as specified in the patient engagement section of the measure.

In the future even more specified metrics will be needed to fully operationalize the vast potential impact of patients reading notes and sharing feedback. For example, beyond organizational attestation, establishing numerators and denominators that account for actual finding and reading of notes through the patient portal or alternate mechanisms for sharing electronic health information will be additionally meaningful, and reflective of organizational support and encouragement for transparent informaiton.  These measures should also account for equity concerns by enabling translation of notes and support for digital literacy.

Thank you for considering this important structural measure and for the opportunity for public comment.

Phreesia is a healthcare technology company that supports patients in taking a more active role in their care to help improve outcomes that matter. We serve as the measure steward for the Patient Activation Measure – Performance Measure (PAM-PM), which was recently included in the 2024 Physician Fee Schedule for inclusion in MIPS, 18 specialty measure sets, and 5 MIPS Value Pathways. Phreesia thanks the Partnership for Quality Measurement and the Centers for Medicare and Medicaid Services (CMS) for continuing to advance patient reported outcome (PRO) measures generally, and specifically MUC2023-162 (Patient-Reported Pain Interference Following Chemotherapy among Adults with Breast Cancer) and MUC2023-190 (Patient-Reported Fatigue Following Chemotherapy among Adults with Breast Cancer) on the 2023 MUC List. These PRO-Performance Measures (PRO-PMs) advance the goal of patient-centered care, while also supporting accountability and value-based payment. 

Patient-reported outcome measures should be considered the gold standard for understanding patients’ experience of many symptoms that may be associated with the side effects of cancer treatment. Especially for important symptoms like pain interference and fatigue, for which there exist no lab tests, asking patients directly about their experience is the best way to understand the impact of their cancer treatment. In Phreesia’s experience, patient activation (a patient’s knowledge, skills and confidence to self-manage their healthcare) helps to provide person-centered care; we support the inclusion of other such outcome measures that prioritize the patient’s voice. These PRO-PMs help patients to assume a more active role in their care and helps both providers and patients achieve the outcomes that matter for overall health, quality of life, recovery, and survivorship in cancer care. 

Phreesia has extensive experience collecting patient-reported information and deploying screening tools across multiple conditions. Administering PROs and then using those data to guide care can lead to improved outcomes, such as reduced symptom burden and increased survival and life quality. PRO-PMs like MUC-2023-162 and MUCH2023-190 hold promise to improve patient-provider communication and data-driven care management plans, which in turn can lead to improved patient experience and health equity.  

Thank you for the opportunity to comment and for considering these important PROM-PMs.

Phreesia is a healthcare technology company that supports patients in taking a more active role in their care to help improve outcomes that matter. We serve as the measure steward for the Patient Activation Measure – Performance Measure (PAM-PM), which was recently included in the 2024 Physician Fee Schedule for inclusion in MIPS, 18 specialty measure sets, and 5 MIPS Value Pathways. Phreesia thanks the Partnership for Quality Measurement and the Centers for Medicare and Medicaid Services (CMS) for continuing to advance patient reported outcome (PRO) measures generally, and specifically MUC2023-162 (Patient-Reported Pain Interference Following Chemotherapy among Adults with Breast Cancer) and MUC2023-190 (Patient-Reported Fatigue Following Chemotherapy among Adults with Breast Cancer) on the 2023 MUC List. These PRO-Performance Measures (PRO-PMs) advance the goal of patient-centered care, while also supporting accountability and value-based payment. 

Patient-reported outcome measures should be considered the gold standard for understanding patients’ experience of many symptoms that may be associated with the side effects of cancer treatment. Especially for important symptoms like pain interference and fatigue, for which there exist no lab tests, asking patients directly about their experience is the best way to understand the impact of their cancer treatment. In Phreesia’s experience, patient activation (a patient’s knowledge, skills and confidence to self-manage their healthcare) helps to provide person-centered care; we support the inclusion of other such outcome measures that prioritize the patient’s voice. These PRO-PMs help patients to assume a more active role in their care and helps both providers and patients achieve the outcomes that matter for overall health, quality of life, recovery, and survivorship in cancer care. 

Phreesia has extensive experience collecting patient-reported information and deploying screening tools across multiple conditions. Administering PROs and then using those data to guide care can lead to improved outcomes, such as reduced symptom burden and increased survival and life quality. PRO-PMs like MUC-2023-162 and MUCH2023-190 hold promise to improve patient-provider communication and data-driven care management plans, which in turn can lead to improved patient experience and health equity.  

Thank you for the opportunity to comment and for considering these important PROM-PMs.

The attached statement is for Patient Safety Structural Measure (#MUC2023-188).

Respectfully,

Carole Hemmelgarn

I want to record my support for the Patient Safety Structural Measure (MUC2023-188). This will create opportunity to transcend the ineffectual management of safety and quality that has left systemic conditions for patient harm largely untouched in U.S. Healthcare organizations over the past two decades. Please take this important step toward patient and family-engaged, systemic safety management in U.S. Healthcare organizations.