October 13, 2020
The AHA appreciates the opportunity to comment on the Centers for Medicare & Medicaid Services Healthcare-Associated Infections (HAIs) Requiring Hospitalizations Measure. The AHA applauds the agency for continuing to develop new measures in efforts to keep patients safe and improve the overall quality of care. There is no doubt that preventing HAIs in SNFs is a top priority, and that this measure conceptually fits CMS’ Meaningful Measure priority area of “Make Care Safer by Reducing Harm Caused in the Delivery of Care: Healthcare-associated Infections.” However, in the interest of achieving a streamlined and meaningful set of quality measures which will inform both care delivery and patient choice, we have some concerns regarding the specifications of this measure. In short, while we agree that measuring HAIs in SNFs is vital, the topic is so important and complex that CMS should develop a measure that will deliver timely, accurate and actionable information rather than this measure under consideration.