New ‘structural’ patient safety measure for hospitals: What to know

Most U.S. hospitals will soon be required to report whether they follow 25 best practices to ensure patient safety, to deflate preventable harms that swelled during the pandemic.

Unlike outcomes metrics like infections or falls, CMS's new Patient Safety Structural Measure, which takes effect Oct. 1, assesses whether hospitals take a range of steps such as:

• Addressing safety topics at governing board meetings.
• Tracking safety disparities.
• Maintaining a communication and resolution program.

That holistic approach marks "a shift to leading indicators from lagging indicators," Tejal Gandhi, M.D., M.P.H., chief safety and transformation officer for Press Ganey Associates, a company that provides tools and insights to improve patient experiences, said via email. She added: "This is pushing organizations to have the foundational structures and processes in place that will drive the outcomes."

For journalists and other members of the public, the measure promises to shed some light on hospital operations. The first scores will be reported in the fall of 2026.

"These best practices aren't new, but patients don't know which ones are and which ones are not in place in the hospitals we use," Beth Daley Ullem, co-founder of the advocacy group Patients for Patient Safety US (PFPS US), said in a news release. She added that at this point, "CMS, the Joint Commission, and state licensing bodies do not know either."

How the measure will work

The measure consists of 25 statements across five domains:

• Leadership commitment to eliminating preventable harm.
• Strategic planning and organization policy.
• Culture of safety & learning health system.
• Accountability and transparency.
• Patient and family engagement.

Hospitals must affirmatively attest to all statements in a domain to receive a point, for a total score of 0 to 5 points.

Hospitals will not be penalized for low scores, but Medicare payments will be reduced starting on Oct. 1, 2027, for hospitals that do not submit their data. The measure applies to hospitals that participate in CMS's Hospital Inpatient Quality Reporting Program and the PPS-Exempt Cancer Hospital Quality Reporting Program. Children's hospitals, inpatient psychiatric hospitals, long-term care hospitals, and rehabilitation hospitals are excluded.

CMS will publicly report each hospital's overall score (0-5) annually on its consumer-friendly Care Compare website and its Provider Data Catalog. In response to a query, CMS's media relations staff said via email that the agency does not plan to publicly report domain-level scores or responses to the 25 attestation statements.

Gandhi suggested that reporters reach out directly to hospitals, many of which "are likely to be proud of the steps they'retaking to enhance patient safety and may be willing to share insights into their programs."

Will this help patients?

Despite limited transparency, several patient safety groups have praised the measure, which reflects recommendations in a landmark 2020 document, "Safer Together: The National Action Plan to Advance Patient Safety," and in a report issued last year by the President's Council of Advisors on Science and Technology.

Besides PSPS US, other organizations have weighed in:

• Massachusetts' Betsy Lehman Center called the measure "an endorsement of the robust 'systems approach' to safety that has proven more effective over the past 25 years than piecemeal efforts to mitigating risks in hospitals."
• The Leapfrog Group said it "will make a profound difference in hard-wiring patient safety into hospitals throughout the country."
• Marcus Schabacker, M.D., Ph.D., president and CEO of ECRI, a nonprofit patient safety consulting organization, said: "Most adverse events are caused by system failures. Healthcare providers struggle to make progress - and sustain it - when they troubleshoot safety hazards in silos, reactively,"

However, the American Hospital Association (AHA) objected to the measure, saying it duplicates or contradicts other regulations and hasn't been sufficiently tested. The association also opposed CMS's new Age-Friendly Hospital Structural Measure.

The AHA said it prefers measures of patient outcomes, which "give hospitals the flexibility to design interventions that lead to higher levels of achievement, rather than locking them into practices that may not have a strong tie to outcomes."

In a 2018 document, CMS said structural measures indicate an organization's "capacity to provide for high-quality care" but acknowledged that "implementation of structural measures is key" to ensure that they are meaningful to patients.

Resources

• CMS IQR Measures page - contains a downloadable file with Patient Safety Structural Measure specifications.
• Measures Management System: Structural Measures - CMS document explaining structural measures.