Hospital Letterhead

Date

Regarding CMS-1498-P

We believe that involvement with registries will reduce data burden, allowing us to sharpen our
focus on improving patient safety and quality. However, we are compelled to respond to the
proposed changes to registry requirements.

We have concerns with the proposed qualification for participating registries. The criteria
proposed which require participation by 750 hospitals as of January 1, 2010, and data collection
on the required topics for the prior three years, will create registry monopolies at a time when
healthcare reform costs to hospitals are anticipated to greatly increase. CMS should be
promoting the study of regional variation, which is feasible with state and regional registries,
enabling comparisons within systems and across systems and regions. The criterion for registry
participation should be based on how registries help hospitals capture reliable and valid data,
and provide information back to hospitals to improve performance. Indicators of registry quality
and criteria for evaluating registries have been described by the Agency for Healthcare Research
and Quality (AHRQ, Publication No.07-EHC001-1) and do not include a threshold for size or terms
of establishment. CMS should allow state, regional and national registries to participate and
promote competition as opposed to a single source, especially for the nurse sensitive measures.

We strongly believe the proposed registry criteria for volume and prior data collection should be
removed.

We are very supportive of the inclusion of nursing sensitive indicators in future national
measurements of hospital quality and safety. Specifically, we support these proposed measures:
• Hospital acquired condition rates of interest to nursing care, reported in 2011 for FY 2013
annual payment updates, including the incidence of pressure ulcers stages III and IV, falls
and trauma, vascular catheter-associated infections, catheter-associated UTI and central
line associated BSI.
• Registry based measures, reported in 2011 for FY 2013 annual payment updates, for
patient falls with injury, hospital acquired pressure ulcer prevalence, and voluntary
turnover for RN, APN, LPN and UAP.

We do not support the following proposed measures for the reasons cited below and
acknowledging that an additional 35 measures are major burden for hospitals in the current era
of healthcare reform.
• Patient Fall Rates: In developing hospital cultures that support patient safety,
responsible reporting may increase reported patient falls, a phenomenon that is believed
to be underreported now. This data is needed by hospital quality experts to design patient
safety programs to decrease falls. This number can easily be misunderstood and hospitals
could be penalized for responsible reporting. Injury fall rates are a better reflection of
patient care quality and safety.
• Skill Mix and Hours Per Patient Day, as proposed, would be reported at the facility or
hospital level and are difficult to interpret unless stratified by individual unit type (i.e.
medical, surgical, or critical care units).
• Practice Environment Scale-Nursing Work Index is an additional satisfaction survey
that will be labor intensive and expensive for hospitals to administer on a routine basis in
addition to their current surveys. This requirement is a resource burden, diverting
precious hospital dollars needed for healthcare delivery.
In addition, we are opposed to the proposed Emergency Department throughput measures.
These throughput measures are multifactorial and cannot yet be adequately interpreted to
evaluate quality. Until such measures have been standardized with NQF endorsed measure
definitions, they are premature for public reporting.

Thank you for your time and attention to this matter. We look forward to your response.

Sincerely,

Name, Title, Organization