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  • Patient Safety Learning’s feedback on the Centers for Medicare and Medicaid Services Patient Safety Structural Measure

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    • Health and care staff, Patient safety leads, Researchers/academics


    This article provides an overview of the proposed Patient Safety Structural Measure on the Centers for Medicare and Medicaid Services (CMS) list of Measures Under Consideration (MUC) 2023 and summarises the public comment submitted by Patient Safety Learning on this.


    The CMS is a federal agency within the United States Department of Health and Human Services. As part of its role, it publishes a list of quality and efficiency measures that the Secretary of the Department of Health and Human Services is considering for adoption through rulemaking under Medicare.

    The CMS accepts measure submissions from the public and then evaluates all suggested measures to determine whether they would consider them for use in one or more Medicare quality reporting and value-based programmes. The measures selected by the CMS are subsequently placed on the MUC list where there is an opportunity for patients, family members, carers, specialty societies, national organisations, advocates, clinicians and healthcare providers to comment.

    Patient Safety Structural Measure

    One of the new measures published in 2023 was a proposed Patent Safety Structural Measure. This is an attestation-based measure that assesses whether hospitals demonstrate having a structure and culture that prioritises patient safety. The Patient Safety Structural Measure includes five domains, each containing multiple statements that aim to capture the most salient structural and cultural elements of patient safety:

    1. Leadership commitment to eliminating preventable harm
    2. Strategic planning & organization policy
    3. Culture of safety & learning health system
    4. Accountability & transparency
    5. Patient & family engagement.

    This Measure is designed to identify hospitals that practice a systems-based approach to safety, as demonstrated by: leaders who prioritise and champion safety; a diverse group of patients and families meaningfully engaged as partners in safety; practices indicative of a culture of safety; and continuous learning and improvement.

    Public comment by Patient Safety Learning

    In the comment we submitted as part of this process on the 21 December 2023, Patient Safety Learning set out our strong support for the proposed Patient Safety Structural Measure. We believe that this attestation-based model aligns with our organisational view that it is essential that we apply standards of good practice for patient safety in the way that we do for other issues.

    The proposed approach in the Patient Safety Structural Measure has a similar basis to our Patient Safety Standards, enabling organisations to self-assess their current patient safety performance, identifying both strengths and weaknesses. The outputs can form the basis for a comprehensive patient safety strategy, as well as the foundations for evidence-based improvement programmes. 

    Likewise, organisations are assessed in our Patient Safety Standards against each of the seven foundations, which significantly align and overlap with the five domains set out in the Patient Safety Structural Measure. In our feedback, we set out in more detail our views on each of the five domains included in the Measure. 

    You can find Patient Safety Learning’s full response attached at the bottom of this page.


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