CMS HOSPITAL CONDITIONS OF PARTICIPATION (COPS) 2014

PI Standards and PI Worksheet

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Speaker Sue Dill Calloway RN, Esq.

CPHRM, CCMSCP

AD, BA, BSN, MSN, JD

President of Patient Safety and Education Consulting

Board Member Emergency Medicine Patient Safety Foundation at www.empsf.org

614 791-1468

sdill1@columbus.rr.com22

You Don’t Want One of These

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Regulations first published in 1986

Manual updated January 31, 2014 and 456 pages

Tag number 0001 through 1164 and PI starts at tag 263

First regulations are published in the Federal Register then CMS publishes the Interpretive Guidelines and some have Survey Procedures 2

Hospitals should check this website once a month for changes

1www.gpoaccess.gov/fr/index.html 2www.cms.hhs.gov/SurveyCertificationGenInfo/PMSR/list.asp

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The Conditions of Participation (CoPs)

Location of CMS Hospital CoP Manuals

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CMS Hospital CoP Manuals new addresswww.cms.hhs.gov/manuals/downloads/som107_Appendixtoc.pdf

CMS Hospital CoP Manual June 7, 2013

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CMS Hospital CoP Manual

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CMS Survey and Certification Website

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www.cms.gov/SurveyCertificationGenInfo/PMSR/list.asp#TopOfPage

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Access to Hospital Complaint Data CMS issued Survey and Certification memo on

March 22, 2013 regarding access to hospital complaint data

Includes acute care and CAH hospitals

Does not include the plan of correction but can request

Questions to bettercare@cms.hhs.com

This is the CMS 2567 deficiency data and lists the tag numbers

Will update quarterly Available under downloads on the hospital website at www.cms.gov

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Number of Deficiencies for PI CMS issued its first deficiency report in March of

2013

CMS plans to update quarterly

Issued reports in June and November of 2013

Issues report in January of 2014

Reports lists the name and address of all hospitals receiving deficiencies

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Access to Hospital Complaint Data

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Deficiency Data January 2014Tag Number

Section Number

263 QAPI 77

270 Provision of Services 13

271 & 272 Patient Care Policies 22

273 Data Collection and Analysis 142

274 Policy Emergency Services 4

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Deficiency Data January 2014Tag Number

Section Number

276 Policies Drug Management 6

277 Policies Med Errors & ADR 2

278 Policies Infection Control 11

279 Policies Nutrition 3

280 Patient Care Policies 6

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Deficiency Data January 2014Tag Number

Section Number

280 Patient Care Policies 6

281-282 Patient Services 9

283 QI Activities 145

284 Patient Services 1

286 Patient Safety 191

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CMS issued new hospital COPs memo for QA and Performance Improvement (QAPI)

CMS issues Memo March 15, 2013 on AHRQ Common FormatsHospitals are required to track adverse events for PI

Starts with tag number 0263

Short section because the hospital compare program is not part of the CMS CoPHospital compare is the indicators that must be sent to

CMS to receive full reimbursement rates

Hospital CoPs for QAPI

Report Adverse Events to PI

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Adverse Event Reporting Hospitals are required to track AE (adverse events)

Several reports show that nurses and others were not reporting adverse events and not getting into the PI system

OIG recommends using the AHRQ common formats to help with the tracking

States could help hospitals improve the reporting process

Encouraged all surveyors to develop an understanding of this tool

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Adverse Event Reporting IOM report discussed the need for comprehensive

patient safety reporting to address the alarming high incidence of AE occurring in hospitals (Pg. 2)

OIG report November, 2010 “AE in Hospitals: National Incidence Among Medicare Beneficiaries” encouraged internal reporting of all AE, whether preventable or not

OIG issues report in January 2012 “Hospital Incident Reporting Systems Do Not Capture Most Patient Harm”

86% of AE are never reported to the PI program

44% are considered preventable19

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http://oig.hhs.gov/oei/reports/oei-06-09-00091.asp

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http://oig.hhs.gov/oei/reports/oei-06-09-00090.pdf

Adverse Event Reporting CMS PI section requires hospital to track AEs and

analyze the causes and implement actions to prevent in the future

Need to include near misses

The internal hospital reporting system represents a foundational capability to determine if the hospital can maintain compliance with the CoPs

The AHRQ Common Formats are evidenced based

Common Formats allow for identification and reporting of any AE even if rare and includes NQF 29 never events such as falls and medication errors

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Events That Should be Reported

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9 Modules in the Common Formats1. Blood or Blood Product

2. Device or Medical/Surgical Supply, including Health Information Technology (HIT)

3. Fall

4. Healthcare-associated Infection

5. Medication or Other Substance

6. Perinatal

7. Pressure Ulcer

8. Surgery or Anesthesia

9. Venous Thromboembolism

10. Other (allows collection of information on all other types of events)24

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https://psoppc.org/web/patientsafety

Hospital Common Formats

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The Conditions of Participation (CoPs) The manual is known as the conditions of

participation or the CoPs for short

The CoP sections are called tag numbers

When IG are final they are printed in a transmittal

All the sections contain a tag number so it is easy to go back and look up that section if you want to read more about it

There are currently 456 pages in the current manual

There were many changes in the manual effective June 7, 2013 but none to the PI section

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Transmittals

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www.cms.gov/Transmittals/01_overview.asp

Feb 4, 2013 Proposed Changes CMS issues 114 pages related to proposed

changes to the CMS CoP but none in PI section

Hospital privileges for RD to write diet orders

Board must consult with chief medical officer for each individual hospital regarding quality of medical care provided in the hospital

Confirmed each hospital must have separate medical staff

MS can include PharmD, dieticians, PA, NP, etc.

No requirement for board to include MD/DO29

Feb 4, 2013 Proposed Changes Allow practitioners not on MS to order outpatient

services

Allow in-house preparation of radiopharmaceuticals on off hours without a physician or a pharmacist being present

3 changes for hospitals that are transplant centers

ASC change for radiology services incident to the surgery

Swing beds move to Part D so accreditation organizations can survey

CAH P&P committee deleted requirement for non staff member requirement

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Feb 4, 2013 Proposed Changes

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www.ofr.gov/inspection.aspx

CMS WorksheetsInfection Control, Discharge Planning and PI

CMS Hospital Worksheets Third Revision October 14, 2011 CMS issues a 137 page memo in the

survey and certification section

Memo discusses surveyor worksheets for hospitals by CMS during a hospital survey

Addresses discharge planning, infection control, and QAPI (performance improvement)

It was pilot tested in hospitals in 11 states and on May 18, 2012 CMS published a second revised edition

Piloted test each of the 3 in every state over summer 2012

November 9, 2012 CMS issued the third revised worksheet which is now 88 pages

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CMS Hospital Worksheets This is the third and final pilot and in 2014 will be

slightly revised

Will use whenever a validation survey or certification survey is done at a hospital by CMS

Third pilot is non-punitive and will not require action plans unless immediate jeopardy is found

Hospitals should be familiar with the three worksheets

Already assigned the number of hospitals to do in 2014

Has money in the budget for states that want to do more

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Third Revised Worksheets

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www.cms.gov/SurveyCertificationGenInfo/PMSR/

list.asp#TopOfPage

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CMS Hospital Worksheets Goal is to reduce hospital acquired conditions

(HACs) including healthcare associated infections

Goal to prevent unnecessary readmission and currently 1 out of every 5 Medicare patients is readmitted within 30 days

Many hospitals (66%) financially penalized after October 1, 2013 because they had a higher than average rate of readmissions

Forfeited 280 million dollars in 2013 and 216 million in2014

The underlying CoPs on which the worksheet is based did not change

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CMS Hospital Worksheets However, some of the questions asked might not be

apparent from a reading of the CoPs

A worksheet is a good communication device

It will help clearly communicate to hospitals what is going to be asked in these 3 important areas

Hospitals might want to consider putting together a team to review the 3 worksheets and complete the form in advance as a self assessment

Hospitals should consider attaching the documentation and P&P to the worksheet

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CMS Hospital Worksheets This would impress the surveyor when they came to

the hospital

The worksheet is used in new hospitals undergoing an initial review and hospitals that are not accredited by TJC, DNV, CIHQ, or AOA who have a CMS survey every three or so years

The Joint Commission (TJC), American Osteopathic Association (AOA) Healthcare Facility Accreditation Program, CIHQ, (Center for Improvement in Healthcare Quality) or DNV Healthcare

It would also be used for hospitals undergoing a validation survey by CMS

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CMS Hospital Worksheets The regulations are the basis for any deficiencies

that may be cited and not the worksheet per se

The worksheets are designed to assist the surveyors and the hospital staff to identify when they are in compliance

Will not affect critical access hospitals (CAHs) but CAH would want to look over the one on PI and especially infection control

Questions or concerns should be addressed to Mary Ellen Palowitch at PFP.SCG@cms.hhs.gov

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CMS Hospital Worksheets First part of the pilot program draft version included

identification information

Name of the state survey agency which in most states is the department of health under contract by CMS

In Kentucky it is the OIG or Office of Inspector General

It will ask for the name and address of the hospital, CCN number, number of surveyors, time spent on completing the tool, date of survey etc.

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CMS Hospital Worksheets Questions or concerns should be addressed to

PFP.SCG@cms.hhs.gov

First part of the pilot program draft version included identification information

Name of the state survey agency which in most states is the department of health under contract by CMS

In Kentucky it is the OIG or Office of Inspector General

It will ask for the name and address of the hospital, CCN number, number of surveyors, time spent on completing the tool, date of survey etc.

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CMS Worksheet QAPI

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CMS Hospital Worksheets CMS uses the term “tracers” for the first time

The first worksheet is on QAPI which stands for Quality Assessment Performance Improvement

CMS previously called it Quality Assurance Performance Improvement and changed June 7, 2013

The worksheet is a document that the surveyor will sit down with the hospital and fill out

The first column includes the elements to be assessed and there are boxes to fill in

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Quality Indicator Tracers

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PI Tracer Data Collection & Analysis This section is 21 pages long

First select three quality indicators related to PI activities or projects

An example might be the timing of medications and PI data to show medication was given on time and number of medication errors or missed or omitted doses

Number of catheter associated UTIs

Write the quality indicator at the top and answer the following questions for each one

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PI Tracer Data Collection & Analysis Hospitals collect all kind of data

TJC requires data to be collected in a number of areas

Data on medication management (ADR, medication errors), FMEA, patient flow, staff compliance with employee health screening requirements, patient satisfaction, pediatric asthma, ED measures, infection control surveillance data

Data on R&S use, patient perception of care, organ donation, blood transfusion reactions, ORYX data, medical record deficiency data, staffing, data on how patient communication needs are met, race and ethnicity etc.

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PI Tracer Data Collection & Analysis CMS has hospital compare with data on number of

MI patients who get thrombolytics timely or pneumonia patients who get their antibiotics timely

Measure patient experience or patient satisfaction data

Measure some or all of the AHRQ patient safety indicators

National Quality Forum includes lists of quality indicators that are evidence based that hospital may measure

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PI Tracer Data Collection & Analysis

Can you show evidence that each quality indicator is related to improved health outcomes?

Based on QIO, national guidelines, evidence based studies etc.

Is the scope of data collection appropriate to the indicator

Hand hygiene would require data from multiple parts of the hospital

ED or L&D might be specific to date from that area such as the average LOS in the ED or the number of elective C-sections performed with premature infants

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PI Tracer Data Collection & Analysis Is the method and frequency of data collection

specified?

Such as chart reviews or monthly observations

Is the data collected in the manner specified and it is done as often as specified such as will do 30 charts per month for ED documentation criteria

If unit staff play a role in data collection then is the data collection consistent with the specifications

Example OR staff complete a data collection tool with number of cases time out is taken and documented, H&P and consent on chart before surgery, etc.

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PI Tracer Data Collection & Analysis Are data collected aggregated in accordance with

hospital methodology specified for this indicators

Is the data analyzed?

If indicator is type that measures rate are the rates calculated for points in time and compared to benchmark data set out by national organizations when available?

Pneumonia patients should get their first dose of antibiotics within 6 hours or MI patients thrombolytics in 30 minutes

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PI Tracer Data Collection & Analysis Is data broken down into subsets that allow for

comparison among hospital units

Such as hand hygiene or the fall rate

If data identified area that needs improvement then is there evidence the issue was addressed

Such as an infant abduction risk, high fall rate, high medication error rate

Are the interventions evaluated for success?

If not, what did the hospital do?

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PI Tracer Data Collection & Analysis

Does PI focus on high risk, high volume, or problem prone areas?

Orthropedic hospital does lots of Orthropedic projects or hospital that does CABG do PI on these

Can hospital prove it conducts distinct PI projects?

Should of course be reflected in the PI minutes

Every department should participate in PI process

Is number of projects proportional to the scope and complexity of the hospital’s service and operations

Larger hospital expected to do more projects54

PI Tracer Data Collection & Analysis Can hospital show evidence of why each project

was selected?

CMS then has a section on patient safety that discusses adverse events (AE) and medical error

This part is to evaluate the hospital’s leadership expectation for patient safety

Is there staff training or communications related to expectation for patient safety to all staff?

Is there a P&P on non-punitive approach to staff reporting medical errors which includes near misses?

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PI Patient Safety AE and Medical Errors

Can staff on each unit explain hospital’s expectation for their role in promoting patient safety?

Is there a systematic process to identify medical errors which include near misses and AEs

On every unit, can the staff describe what is a medical error?

Can they explain how to report?

Does hospital employ other methods to find medical errors such as trigger tools, chart reviews, review of claims, patient grievances, interview patients etc.

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Patient Safety LD, AE and Medical Error

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PI Patient Safety AE and Medical Errors

Can hospital provide evidence of medical errors and AEs identified through staff reports?

Is there a PI program with the infection preventionist (IP) to track avoidable HAI?

IC section requires this and starts at tag 747

Are problems identified by the IP addressed through PI?

Does the PI program track medication errors and ADE and drug incompatibilities

Tag 508 revised May 20, 2011 to require this58

PI Patient Safety AE and Medical Errors

Is there a process to report blood transfusion reaction and determine if due to medical error?

Did the survey team have prior knowledge of any serious AE that the hospital failed to identify?

Were any identified by the surveyors?

Has a RCA been done on all serious preventable AEs?

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PI Causal Analysis Tracers Part 5

The next question discuss the causal analysis tracers

Causal analysis searches for the cause and effect or causes of the particular event or adverse outcome

More commonly referred to as a RCA or root cause analysis

The surveyor will select three causal analysis done for single event or near miss

Were underlying causes identified?60

Causal Analysis Tracers

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PI Causal Analysis Tracers

Was preventive actions developed based on the RCA?

TJC has a matrix which contains elements that must be included in a reviewable sentinel event

Has the hospital evaluated the impact of the preventable actions including tracking a reoccurrences or near misses?

Has the hospital implemented the preventable actions found to be effective unless there is a documented reason for not doing so?

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TJC Framework for Conducting RCA

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www.jointcommission.org/sentinel_event.aspx

TJC Sentinel Event Policy with Matrix

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www.jointcommission.org/Sentinel_Event_Policy_and_Proc

edures/

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Broad PI Requirements & Leadership Part 6 addresses broad PI requirements and

leadership responsibilities

Does the hospital have a formal PI program?

Most hospitals have a PI plan that discusses the PI program

Is there a written P&P on the PI program?

Is there budgeted resources so staff can attend education programs and data can be collected?

Is there responsible staff to do PI

Is the PI program approved by MS, CEO, and the board?66

Broad PI Requirements and Leadership

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Broad PI Requirements and Leadership Is there evidence of PI review for contracted services?

Is there evidence that the board, CEO, MS leadership and senior leaders have a role in PI planning and implementation?

Is there evidence of PI review in the board minutes?

Does the board approve the PI program quality indicators and how often the data is collected?

Determine how many projects for next year?

Does board hold CEO accountable for effectiveness of PI program?

CMS Board section starts at tag 3868

CMS HOSPITAL CONDITIONS OF PARTICIPATION (COPS) 2014

What PPS Hospitals Need to Know About the QAPI Section

CMS CoP PI Section Starts at Tag 263

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QAPI stands for quality assessment performance improvement

Use to stand for Quality Assurance and Performance Improvement but changed June 7, 2013

Referred to in short as PI

Must have PI program that is ongoing, hospital-wide, data driven, and effective

The board must make sure the program reflects the complexity of the hospital’s services

Hospital CoPs for PI 263

Hospital CoPs for PI Includes all departments even if contracted services

Must focus on indicators related to improve health outcomes

How do you improve outcomes in the patient with hyponatremia?

How to improve outcomes in the diabetic patient admitted with hyperosmolar syndrome?

Must focus on the prevention and reduction of medical errors

What do you to prevent medical errors such as medication errors which is the most common type?

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Program Scope 264 Standard: The hospital must ensure that the

program scope requirements are met

So what is the scope of activities of your PI program?

Is the scope your PI program to include an overall assessment of the efficacy of the PI activities with a focus on continually improving the care provided at your hospital?

Does it look at indicators for both process and outcome?

Are the indicators objective, measurable, and based on current knowledge and experience?

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What is the Scope of Your PI Program? Threats to patient safety

–Eg. falls, patient identification, injuries

Medication therapy/medication use

–Includes medication reconciliation

–Includes the use of dangerous abbreviations

Infection control system, including healthcare associated infections (HAI)

Utilization Management System

Patient experience or satisfaction74

What is the Scope of Your PI Program? Discrepant pathology reports

Unanticipated deaths, adverse and/or sentinel events

Adverse event/near miss

Physical Environment Management Systems

Operative and invasive procedures

– Including wrong site/wrong patient/wrong procedure surgery

Anesthesia/moderate sedation

Blood and blood components

Restraint use/seclusion75

What is the Scope of Your PI Program? Effectiveness of pain management system

Patient flow issues, to include reporting of patients held in the Emergency Department in excess of four hours

Other adverse events

Critical and/or pertinent processes, both clinical and supportive

Medical record delinquency

Other aspects of performance that assess process of care, hospital service and operation

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What’s in Your PI Plan?

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Scope of Activities of the PI Plan

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Scope of PI Plan and Program

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Board is Responsible for Quality of Care

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Role of MEC in PI Plan and Program

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Hospital Uses PDCA and FOCUS

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Focus on High Risk and High Volume

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Collect Data and Monitor

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Identify Change and Implement

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Ongoing Program 265 Standard: The PI program must include an ongoing

program

The program must show measurable improvements in indicators for which there is evidence that it will improve health outcomes

Hospitals has improved patient flow and admitted patients now get to their bed in four hours or less

Patients get their antibiotics timely in the OR now

Patients with pneumonia now get their antibiotics within the six hour window

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Identify and Reduce Medical Errors 266 Standard: The PI program needs to identify and

reduce medical errors

First, the hospital need to identify that there is a medical error

– It needs to be reported into the PI system

– Risk management and hospital staff cannot fix a problem they do not know exists

Second, the hospital evaluates it to determine what processes can be put in place to prevent it from occurring

RCA and FMEA are two tools that can be used90

Identify and Reduce Medical Errors 266

Medical errors may be difficult to detect in hospitals and are under reported

Make sure incident reports filled out for errors and near misses

Are there any diagnostic errors, equipment failures, blood transfusion injuries, or medication errors

Trigger tools by IHI can assist in finding medical errors and opportunities for improvement Classen DC, Resar R, Griffin F, et al. Global Trigger Tool shows that

adverse events in hospitals may be ten times greater than previously measured. Health Affairs. 2011 Apr;30(4):581-589.

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IHI Global Trigger Tool wwww.ihi.org

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Trigger Tool for Adverse Drug Events

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Resources Griffin FA, Classen DC. Detection of adverse events in

surgical patients using the Trigger Tool approach. Quality and Safety in Health Care. 2008 Aug;17(4):253-258.

Classen DC, Lloyd RC, Provost L, Griffin FA, Resar R. Development and evaluation of the Institute for Healthcare Improvement Global Trigger Tool. Journal of Patient Safety. 2008 Sep;4(3):169-177.

Resar RK, Rozich JD, Simmonds T, Haraden CR. A trigger tool to identify adverse events in the intensive care unit. Joint Commission Journal on Quality and Patient Safety. Oct 2006;32(10):585-590.

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Track Quality Indicators 267Standard: the hospital must measure, analyze, and track quality indicators, including adverse events

This includes adverse patient events

This includes other aspects of performance that assess processes of care, hospital service, and operation

Want to focus on aspects and processes that related to the health and safety of patient care services

Look at what could result in a sentinel event if not properly managed

TJC has a sentinel event policy and lists reviewable SE95

TJC Revised Sentinel Event Policy

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www.jointcommission.org/

Sentinel_Event_Policy_and_Procedures/

Reviewable Sentinel Events

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QAPI StandardsStandard: Program Data (Tag 273)

Hospital must ensure that the program data requirements are met

Standard: The PI program must incorporate quality indicator data including patient care data (Tag 274)

For example, information submitted or received from the QIO

QIO stands for Quality Improvement Organization and every state has one under contract by CMS

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CMS QIO Website

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www.cms.gov/Medicare/Quality-Initiatives-Patient-

Assessment-Instruments/

QualityImprovementOrgs/index.html?

redirect=/qualityimprovementor

gs

List of QIOs

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http://www.qualitynet.org/dcs/ContentServer?

c=Page&pagename=QnetPublic%2FPage

%2FQnetTier2&cid=1144767874793

http://www.qualitynet.org/dcs/ContentServer?

c=Page&pagename=QnetPublic%2FPage

%2FQnetTier2&cid=1144767874793

Outpatient Data Collection

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Hospital uses data to monitor the effectiveness and safety of services and quality of care (275)

Hospital identify opportunities for improvement (276)

Board determines frequency and detail of data collection (277)

Hospital ensures that the program activities are met (283)

Hospital sets priorities and focuses on high risk, high volume, or problem prone (285) Considers incidence and severity of problems

CMS Hospital CoPs QAPI

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Must not only track medical errors and adverse events but also analyze their causes (287, 288)

RCA is one tool to analyze causes

Includes preventive actions and learning throughout

Hospital must take action based on data (289) and measure its success (290)

Example; process hospitals took to get MI patient timely thrombolytics and timely antibiotics and blood culture for pneumonia patients

TJC has accountability measures and CMS has value based purchasing (VBP)

QAPI

CMS VBP Website

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www.cms.gov/Medicare/Quality-Initiatives-Patient-

Assessment-Instruments/hospital-

value-based-purchasing/index.html?redirect=/hospital-value-based-

purchasing/

VBP Fact Sheet

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VBP Clinical Process of Care Measures

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CMS Hospital Compare

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www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HospitalQualityInits/

HospitalCompare.html

CMS Outcome Measure Hospital Compare

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Hospital needs to document and track performance to make sure improvements are sustained (291)

Continue to track antibiotics given timely in the OR before surgical procedure and prophylactic treatment to prevent DVT/PE in major surgery patients

Number of PI projects depends on scope and complexity of hospital services so large hospital doing CABG would measure indicators on this (298)

Hospital may want to develop and implement IT system to improve patient safety and the quality of care (299)

QAPI

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Hospital must document what PI projects are being done (300) and the reason for doing them (301) and progress on it (302)

The hospital is not required to participate in the QIO projects but its own projects are required to be of comparable effort (303)

Board, MS, and administration are responsible for and accountable for ongoing program (309)

These 3 must make sure the following are done

That an ongoing program for PI is defined, implemented and maintained (310)

QAPI

QAPIThat there is an ongoing program for patient safety that includes reduction of medical errors

Decide which are priorities and that all improvement actions are evaluated (312)

Hospital must address issues to improve patient safety (313)

Clear expectations for patient safety are established (314)

Need adequate resources for PI and patient safety (315, 316) and number of projects is conducted annually (317)

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This means people who can attend meetings, data so analysis can be made and other resources

Safer IV pumps, new anticoagulant program, implement central line bundle, sepsis, and VAP bundle, preventing inpatient suicides, wrong site surgery, retained FB, new processes for neuromuscular blocker agents, implement policy on Phenergan administration and Fentanyl patches

So what’s in your PI and Safety Plans?

QAPI Patient Safety

National Quality Forum NQF NQF is an excellent resource

Has the ABCs of measurement

A list of NQF endorsed standards

A list of consensus projects

Resources

Can do a search of measures such as AAA repair mortality rate, accidental puncture or laceration rate, 30 day post hospital MI discharge care transition rate, stroke mortality rate, adherence to medication for diabetic patients, etc.

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AHRQ Has Excellent Resources

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Quality Indicator Toolkit

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www.ahrq.gov/legacy/qual/qitoolkit/

Patient Safety Indicators

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Types of Indicators; Inpatient, PS, Peds,

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List of NQF Measures

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National Quality Forum NQF

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www.qualityforum.org/Home.aspx

TJC Performance Measurement

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http://www.jointcommission.org/performance_measurement.aspxhttp://www.jointcommission.org/

performance_measurement.aspxwww.jointcommission.org/

performance_measurement.aspxwww.jointcommission.org/

performance_measurement.aspxwww.jointcommission.org/

performance_measurement.aspx

Hospital Quality Alliance

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www.hospitalqualityalliance.org/hospitalqualityalliance/index.html

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The End! Questions?? Sue Dill Calloway RN, Esq.

CPHRM, CCMSCP

AD, BA, BSN, MSN, JD

President of Patient Safety and Education Consulting

Board Member Emergency Medicine Patient Safety Foundation at www.empsf.org

614 791-1468

sdill1@columbus.rr.com

Call with questions, No emails, Thanks124124