March 2, 2018


The Alliance expressed its concern about CMS’ Hospital Harm- Hospital-Acquired Condition -Pressure Injury measure. While the Alliance supports and encourages the continued development of quality measures that assess wound care outcomes, the Alliance flagged that the intended objective will not be achieved the way this measure has been crafted. Overall, the specific language as well as the numerator and denominator, contained within this document are not accurate, wrote the Alliance in its comments. Furthermore, there are scientifically incorrect statements within this proposed measure.  “It is very concerning that CMS has tied a Pressure Injury Measure to Hospital Harm. As stated throughout our comments – it is possible for a patient to develop or have a pressure ulcer without any harm. If this measure continues as a quality indicator to measure harm, there will be unintended consequences - either an increase in the number of lawsuits, or an increased likelihood that hospitals will be unable to defend themselves against frivolous litigation - despite the best care being provided.”

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