The Centers for Medicare and Medicaid Services (CMS) recently released an announcement seeking input from stakeholders on a new electronic clinical quality measure under development titled, “Hospital Harm – Hospital-Acquired Pressure Injury.”

This measure assesses the proportion of hospitalized patients 18 years and older who develop a new stage 2-4 pressure ulcer, deep tissue injury, unstageable pressure ulcer, or experience worsening of any of the above during their hospitalization.

We read the full description of the measure and provided the following feedback on behalf of APWCA membership:

• Concern that the denominator has no exclusions; made the point all pressure ulcers are not preventable
• Responded to one of the questions posed by the measure authors by explaining protocols may change for end-of-life or hospice patients who have comfort care-only orders

-- Clarified this could be difficult to track because comfort care-only orders may not be captured in some EHR systems and some hospitals are still not using a fully functional EHR

• Suggested denominator exclusions be added to this measure, including:
  

-- Palliative care
-- End-of-life care
-- Metastatic malignancies
-- Septic shock

This is just one example of how APWCA advocates for our members.  To learn more about your membership and benefits visit www.apwca.org.

If you would like to submit comments on your own, follow these instructions provided by the Alliance of Wound Care Stakeholders:

• Current JIRA users with an active account select “Log In” at top right corner at http://jira.oncprojectracking.org

• If you do not have a JIRA account, select “Sign up” at http://jira.oncprojectracking.org/login.jsp

              1. Select “Projects” at top middle on home screen
              2. Select “View All Projects”
              3. Select “Quality-Measures” on left-side of screen
              4. Select “Comments on eCQMs under development” project
              5. To enter comments, select “Create” (orange button) at the top middle of the screen
              6. Select the type of issue from the “Issue Type” drop-down menu
              7. In “Summary” field, type the following title: 
                  Hospital Harm – Hospital Acquired Pressure Injury
              8. Select the measure name for comment on from the “Draft Measures” drop-down: 
                  Hospital Harm – Hospital Acquired Pressure Injury
              9. Fill out fields labeled “Contact name,” “Contact email,” and “Contact phone”
            10. Enter comments in the “Description ”field or upload an attachment under the “attachment” field
            11. Select “Create” at the bottom left to submit comments
            12. For additional comments, select “Create another” and then “Create”