• Letter or Testimony
  • December 24, 2013

Patient Safety Standards for Qualified Health Plans Comment Letter

The Association respectfully urges HHS to consider the following recommendations to ensure that patient safety programs do, in fact, meet the unique health care needs of children. 

Core Aspects to be Included in Hospital Patient Safety Programs

Hospital patient safety programs must be comprehensive, involve patients and families, and include appropriate expertise for the populations served by the hospital. Hospitals serving children must include pediatric expertise in the design, implementation and monitoring of their patient safety programs and ensure that safety guidelines developed for adult populations are appropriate for and/or are modified for children. 

For example, a system to ensure medication safety for children must include the capacity for weight-based dosing. A second example relates to safe practices to avoid catheter-associated bloodstream infections. Pilot survey worksheets for the Infection Control Conditions of Participation related to central venous catheters reflect the importance of compliance with an insertion bundle. Compliance with a maintenance bundle has been shown to be equally, if not more, critical in pediatrics in preventing catheter-associated blood stream infections. (Miller MR, Niedner MF, Huskins WC, et al., 2010). 

Comprehensive Hospital Discharge Planning Programs

The Association is pleased that the ACA recognizes the importance of a discharge planning program that applies to all patients. Comprehensive hospital discharge planning programs must reflect the needs of the populations (e.g., by age group) and sub-populations (e.g., by level of complexity) served by the hospital. 

Features of a comprehensive discharge planning program that may be more unique in hospitals serving children include the structure and function of the child’s family and social environment, ongoing coordination with other settings, such as schools, development of goals for the child following discharge, and recognition of the child’s developmental stage and milestones to be achieved.

Health Care Quality Improvement Activities

In general, the Association believes that hospital and plan quality improvement activities should be designed to address the aims set forth in the National Quality Strategy and that a comprehensive program should reflect the key domains of quality (safe, effective, efficient, equitable, timely and patient/family centered). 

Flexibility in identification and prioritization of activities according to the populations served by the hospital and plans and organizational performance should be allowed; however, quality improvement activities should be in place for all types of patients (newborns, children, adolescents, adults) served by the hospital. For example, involvement of parents is critical in ensuring that care is patient/family focused in pediatrics. Patients and families should be involved in the identification of priorities and in improvement activities.

Considerations of Exceptions to Patient Safety Standards

The Association recommends that the only exceptions to patient safety standards should be based on evidence that a particular standard is not appropriate for a specific group of patients. Additionally, there may be some (few) instances in which the adoption of a specific practice is unreasonably costly if the likelihood of an event is extremely low in the populations served by the hospital.

Association Contact: Liz Parry, (202) 753-5392