How RLDatix Supports Readiness and Implementation of CMS Patient Safety Structure Measure

The Centers for Medicare & Medicaid Services (CMS) recently published the final rule for the Patient Safety Structural Measure (PSSM), which expects to take effect next month. The ruling reinforced the importance of connecting healthcare operations and data to prevent harm proactively, creating and sustaining a culture of transparency and continuous improvement while remaining compliant with regulatory expectations. 

This measure will require hospitals to attest to whether they have implemented a culture of safety aligning to the PSSM’s five domains. Hospitals will be scored from zero to five, with one point awarded per domain: 

  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 

Patient safety is a journey and this latest CMS measure is another opportunity for healthcare leaders to assess readiness and learn how their organization can connect actionable data and operations to take action and deliver safer care. With 25+ years in patient safety advocacy, and having served as an architect for the Agency for Healthcare Research and Quality’s (AHRQ) CANDOR toolkit, I’m pleased to help hospitals and healthcare systems further improve the quality of the patient care that they deliver. 

In this post, domain by domain, I’ll summarize: 

  • The domain’s focus
  • The domain’s key requirements
  • The RLDatix solutions that can help you positively attest to the domain 

Domain 1: Leadership Commitment to Eliminating Preventable Harm 

Domain 1 focuses on the hospital’s senior leadership and governing board’s actions in making its commitment to patient safety as its highest priority. It directs the governing board to oversee all safety activities and to hold leadership accountable for patient safety outcomes. All strategic, financial and operational decisions should have patient safety at their core. 

PSSM Domain 1 Key Requirements

  • Patient safety metrics that inform annual leadership performance reviews and compensation
  • System-wide assessment on safety and patient safety initiatives and operations with improvement plans and metrics, shared across the hospital and governing board
  • Sufficient patient safety resources (such as equipment, training, systems, personnel and technology)
  • Reporting on patient and workforce safety events and initiatives that account for at least 20% of the regular board agenda and senior governing board meeting discussion time.
  • C-Suite and the senior governing board are notified within three business days of safety events resulting in significant morbidity, mortality, or other harm 

How RLDatix Can Help You Positively Attest to PSSM Domain 1

Domain 2: Strategic Planning and Organizational Policy 

Domain 2 focuses on committing to safety as a core value, by documenting policies and protocols, and identifying goals, metrics and practices, to create accountability and transparency across the organization. It instructs hospitals to strive for, whether attainable or not, zero preventable harm, which requires continuous process improvement. Equity in care should be embedded in safety planning, goal-setting, policy and processes. 

PSSM Domain 2 Key Requirements

  • Strategic plan that outlines specific safety goals and associated metrics, with the goal of zero preventable harm
  • Safety goals that use metrics, most relevant to the patient characteristics of the populations served, to identify and address disparities in safety outcomes
  • Implementation of written policies and protocols that cultivate a just culture, balancing no-blame and appropriate accountability
  • Implementation of a patient safety curriculum and competencies, with regular assessments, for all clinical and non-clinical hospital staff
  • Action plan that includes improvement activities, metrics and trends for workforce safety 

How RLDatix Can Help You Positively Attest to PSSM Domain 2

Domain 3: Culture of Safety and Learning Health Systems 

Domain 3 focuses on integrating evidence-based practices and protocols hospital-wide, with people and systems working collaboratively, to prioritize safety and establish a learning system. It directs hospitals to seek information continuously to take a proactive approach to eliminating preventable harm. Integration of people and systems requires fostering psychological safety among staff. 

PSSM Domain 3 Key Requirements

  • Hospital-wide culture of safety survey annually, or every two years with pulse surveys during non-survey years, with results shared with the governing board and hospital staff
  • Dedicated team that conducts evidence-based event analysis of serious safety events
  • Patient safety metrics dashboard that also includes external benchmarks
  • Implementation of specific high reliability practices for improving safety culture and learning systems
  • Participation in large-scale learning network(s) for patient safety improvement, share data on safety events and outcomes with these network(s) and implement at least one learned best practice 

How RLDatix Can Help You Positively Attest to PSSM Domain 3

Domain 4: Accountability and Transparency 

Domain 4 focuses on the vitalness of accountability and transparency in building a culture of safety. It states that learning from safety events and preventing harm, through data collection and analysis, are possible only when hospitals promote event reporting without fear and hesitation. 

PSSM Domain 4 Key Requirements

  • Confidential safety reporting system that allows staff to report patient safety events, near misses, precursor events, unsafe conditions, and other concerns, and prompts a feedback loop to those who report
  • Reporting serious safety events, near misses and precursor events to a PSO listed by the AHRQ
  • Tracking and reporting patient safety metrics to all clinical and non-clinical staff publicly
  • Defined, evidence-based communication and resolution program reliably implemented after harm events
  • Tracking and reporting communication and resolution program performance with standard measures to the governing board at least quarterly 

How RLDatix Can Help You Positively Attest to PSSM Domain 4

Domain 5: Patient and Family Engagement 

Domain 5 focuses on delivering safer, better care through hospital engagement with patients, families, and caregivers. It instructs hospitals to involve these groups in safety activities, quality improvement and oversight. 

PSSM Domain 5 Key Requirements

  • Patient and Family Advisory Council that ensures patient, family, caregiver, and community input to safety-related activities, including representation at board meetings, consultation on safety goal-setting and metrics, and participation in safety improvement initiatives.
  • Patient and Family Advisory Council that is diverse and representative of the patient population.
  • Incorporating patient and caregiver input about patient safety events or issues
  • Supporting the presence of family and other designated persons as essential members of a safe care team and encourages engagement 

How RLDatix Can Help You Positively Attest to PSSM Domain 5

Assess Your Readiness for CMS Patient Safety Structure Measure 

Patient safety is a journey. 

The CMS Patient Safety Structure Measure is a terrific roadmap for us, as healthcare leaders, to follow in our pursuit of zero preventable harm. 

We can do this by continuously learning, improving and exploring how we connect data and operations to deliver safer, better care for our patients. 

To learn more about how RLDatix can help assess readiness and implementation of the CMS Patient Safety Structure Measure, connect with one of our experts. 

Headshot of Dr. Tim McDonald

Tim McDonald, MD, JD, is the Chief Patient Safety and Risk Officer at RLDatix and a Professor of Law at Loyola University, Chicago. He is a Harvard-trained anesthesiologist, pediatrician, licensed attorney, patient safety/medical liability specialist and author of articles in renowned peer-reviewed journals. His expertise has been recognized nationally and internationally, including authorship of references for the President's Council of Advisors on Science and Technology Patient Safety Report. 

Known for his TED x San Diego Talk, Tim is passionate about working with patients, families and healthcare providers, to shatter the wall of silence, by sharing stories and fostering a culture of compassionate honesty, fair accountability and patient safety transformation.

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