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CMS proposes the Patient Safety Structural Measure to strengthen systems for safety

Safe, high-quality care and positive patient outcomes are a result of the high reliability processes and systems that hospitals and health systems have in place. The Centers for Medicare & Medicaid Services (CMS) is now considering a new quality measure to assess how well hospitals have implemented strategies and practices to strengthen systems for safety.

In the proposed fiscal year (FY) 2025 Hospital Inpatient Prospective Payment System (PPS) rule, CMS proposes to adopt the Patient Safety Structural Measure (PSSM) for the Hospital Inpatient Quality Reporting (IQR) Program and the PPS-Exempt Cancer Hospital Quality Reporting (PCHQR) Program beginning with the CY 2025 reporting period (FY 2027 payment determination). The PSSM was developed by a Technical Expert Panel, which was comprised of safety experts, hospital leaders, researchers, and patient advocates, including myself. The PSSM was also informed by "Safer Together: The National Action Plan to Advance Patient Safety," developed by the National Steering Committee for Patient Safety (which I co-chaired).

The PSSM is an attestation-based measure that assesses whether hospitals demonstrate having a structure and culture that prioritizes patient safety. The PSSM 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 and organizational policy
  3. Culture of safety and learning health systems
  4. Accountability and transparency
  5. Patient and family engagement

Affirmative attestation to all statements within a domain will be required for the hospital to receive a point for the domain. At 1 point per domain, hospitals affirmatively attesting to all statements will receive the maximum of 5 points. CMS proposes to publicly report the hospital’s measure performance score, which would range from 0 to 5 points, annually on Care Compare starting in fall 2026.

As safety and quality leaders across the country review this measure and what it means for their organizations, leaders should approach this as an opportunity for improvement. I recommend continuing to focus on implementing and taking action on evidence-based approaches that we know work to consistently deliver safe care.

Why propose a patient safety structural measure?

This measure reflects an important evolution in how hospitals and health systems should approach safety and quality reporting. Traditionally, we've measured some safety outcomes. As a participant on the Technical Expert Panel that developed this measure—and as a result of the work on the National Action Plan and other initiatives—we know we have to go upstream and measure structure/process, which will then help achieve those safety outcomes. It PSSM is also very aligned with HRO principles/practices, which we also know improve safety.

As safety and quality leaders across the country review this measure and what it means for their organizations, leaders should approach this as an opportunity for improvement. I recommend continuing to focus on implementing and taking action on evidence-based approaches that we know work to consistently deliver safe care.

Press Ganey has a deep bench of technologies, tools, and expertise dedicated to advancing patient safety-first initiatives and hardwiring best practices to help organizations of all kinds achieve their patient and workforce safety goals.

I’ve worked with my team of patient safety and regulatory experts to summarize the PSSM's five domains and recommend ways that Press Ganey solutions can help your organization implement high reliability best practices and align with the PSSM domains.

1. Leadership commitment to eliminating preventable harm

This domain addresses how the hospital's senior governing board prioritizes safety. It also holds leadership teams accountable for providing resources to support safety initiatives and keeping safety-related topics and metrics top of mind, as well as transparent, across the entire organization. Some of the components of the domain include integrating patient safety metrics into annual performance reviews, C-suite oversight of system-wide safety assessments and initiatives, sharing plans and metrics widely, and reporting serious safety events to the C-suite and board members within three business days.

How Press Ganey can help:

2. Strategic planning and organizational policy

This domain addresses how the hospital's strategic plan emphasizes patient safety as a core value, aiming for "zero preventable harm" and addressing safety disparities. It includes components like policies that promote a just culture, distinguishing between human error, at-risk behavior, and recklessness. All staff, including executives and board members, undergo patient safety training with regular competency assessments and action plans. Workforce safety initiatives target areas like fall prevention, safe patient handling, violence prevention, and psychological safety, supported by metrics and improvement activities. 

How Press Ganey can help:

3. Culture of safety and learning health system

This domain addresses practices in place that improve safety culture and provide ongoing learning opportunities for the system. Organizations can fulfill this requirement by effectively using safety culture surveys and sharing the results with both staff and the governing board to inform interventions. A dedicated team analyzes serious safety events using evidence-based approaches like root cause analysis. A patient safety dashboard tracks metrics and benchmarks against external standards, guiding improvement efforts for issues like medication errors and infections. High reliability practices include safety huddles, leadership rounding, data infrastructure for event tracking, technology integration, improvement methodologies, staff training, and participation in safety improvement networks.

How Press Ganey can help:

  • Safety culture survey
  • Consulting: Cause analysis, process improvement, universal skills, and huddles 
  • Patient Safety Organization (PSO)
  • HRP
  • Digital rounding 

4. Accountability and transparency

The fourth domain focuses on how the organization operates with accountability and transparency as it relates to safety. This includes requirements like operating a confidential safety reporting system, which enables staff to report events and concerns, with a feedback loop. Serious events, near misses, and precursors are reported to a Patient Safety Organization listed by AHRQ. Patient safety metrics are tracked and publicly displayed. An evidence-based communication and resolution program, like AHRQ's CANDOR toolkit, is implemented post-harm, covering event identification, communication with patients, investigation, caregiver support, and reconciliation. Program performance is measured and reported quarterly to the governing board.

How Press Ganey can help:

5. Patient and family engagement

The PSSM also recognizes the importance of engaging the patient and family in safety initiatives. It recommends practices like ensuring diverse representation on the hospital's Patient and Family Advisory Council and integrating community input into safety-related activities, including board representation, goal setting, and improvement initiatives. The council’s participants should reflect the patient population and local community. Patients have access to their medical records and are encouraged to review and submit comments for correction, with culturally and linguistically appropriate support. Patient input on safety events and discrimination is incorporated in quality improvement. The hospital supports family involvement in care activities and encourages 24-hour visitation where feasible. 

How Press Ganey can help: 

  • Community Advisor patient and family advisory council solution 
  • Safety/bias questions on patient surveys

To learn more about PSSM, as well as how Press Ganey can help improve patient and workforce safety at your hospital, reach out to a safety and high reliability expert.  

About the author

As Chief Safety and Transformation Officer, Dr. Gandhi, MPH, CPPS is responsible for improving patient and workforce safety, and developing innovative healthcare transformation strategies. She leads the Zero Harm movement and helps healthcare organizations recognize inequity as a type of harm for both patients and the workforce. Dr. Gandhi also leads the Press Ganey Equity Partnership, a collaborative initiative dedicated to addressing healthcare disparities and the impact of racial inequities on patients and caregivers. Before joining Press Ganey, Dr. Gandhi served as Chief Clinical and Safety Officer at the Institute for Healthcare Improvement (IHI), where she led IHI programs focused on improving patient and workforce safety.

Profile Photo of Dr. Tejal Gandhi, MPH, CPPS