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Experts urge embedding patient‑safety measurement into alternative payment models
Summary
Panelists at a PTEC public meeting recommended integrating patient‑reported safety measures into APMs, using digital measures and AI for real‑time signals, and coupling incentives with support for low‑performing providers to reduce diagnostic and transition‑of‑care harms.
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A panel convened by PTEC heard experts Wednesday on how alternative payment models can better prevent patient harm by measuring safety directly, elevating patient‑reported experience and outcome measures, and using digital tools to deliver near‑real‑time signals to clinicians and systems.
Ms. Susan Sheridan, president and CEO of Patients for Patient Safety US, opened with a personal account of two diagnostic errors in her family that left one child with permanent disability and cost the family financially. She said diagnostic errors are “the most common, the most costly, and the most catastrophic,” and told the committee that “it is estimated that it's costing our country annually $200 billion.” Sheridan described Project Pivot, a multi‑stakeholder effort that produced candidate patient‑reported outcome and experience measures (PROMs/PREMs) now being piloted with Press Ganey and intended for integration into ACOs and other APMs.
"What patients experience is not peripheral to safety. It is safety," Sheridan said, urging that patients’ voices be measured, learned from and rewarded.
Dr. Michelle Schreiber, Deputy Director of the Center for Clinical Standards and Quality at the Centers for Medicare & Medicaid Services (CMS), described CMS’s measurement portfolio and its transition to digital and electronic clinical quality measures so organizations can act on data more quickly. She noted recent CMS action to reduce star ratings by one star for facilities that fall in the lowest quartile for patient safety — a change that affected 14 hospitals this year and is expected to affect roughly 450 next year — and said CMS is exploring ways to align measures, reporting and payment to drive accountability.
"Doing no harm is the fundamental principle of health care," Schreiber said, and told the committee that digital measures and partnerships across CDC, AHRQ and ONC are part of CMS’s approach to surface safety problems faster.
Dr. Suzanna Brunheim, chief medical officer at the CMS Innovation Center (CMMI), outlined CMMI authorities to test payment waivers and new care arrangements, and gave examples of how models can embed safety requirements. She pointed to GUIDE, an ambulatory model for dementia that uses medication reconciliation and navigator supports to reduce polypharmacy risk, and LEAD, a forthcoming ACO model that tests CMS‑administered risk arrangements and the RISE episode to support fall prevention through home‑based occupational therapy and nursing.
"We don't have a patient safety model," Brunheim acknowledged, but she emphasized that safety can be integrated across CMMI’s portfolio by using model levers to drive coordination and patient empowerment.
From the health‑system side, Dr. Jason Mitchell, executive vice president and chief medical officer at Geisinger, pressed for stronger ambulatory metrics and financial alignment to support "zero harm." He recommended safety composites for ACOs, gating financial benefits on safety performance, and broader bundling that tracks post‑acute patient safety measures beyond readmissions.
"Safety matters, period. And zero harm is possible," Mitchell said, and urged a national framework for ambulatory safety metrics, with attention to frailty, fall prevention and medication safety.
Dr. Dhirendra Groupola of ECRI urged rewarding reporting of safety signals and near misses rather than only punishing harm. He summarized ECRI analyses of 10,000 reported events showing that transitions of care account for a large share of medication reconciliation failures and that many institutions underreport near misses. He and others warned that as systems turn on digital surveillance and AI overlays, organizations must have the capability to prioritize the high volume of signals or risk being overwhelmed.
Panelists discussed program design for reaching low performers. Options included targeted Quality Improvement Organization (QIO) support, multi‑year pre‑implementation funding, earn‑back models that withhold funds but allow providers to reinvest withheld amounts into improvement, and shared‑savings approaches to pay for safety gains rather than imposing flat penalties on resource‑constrained providers.
Experts also explored technical and equity issues: validating AI overlays that extract unstructured EHR data, preventing reporting burden from falling more heavily on under‑resourced providers, ensuring EHR vendors support embedded eCQMs for smaller practices, and tailoring PROMs/PREMs for behavioral‑health populations.
The session closed with panelists urging integration of patient voice into measurement and APM design, expanded use of digital measures for near‑real‑time learning, and payment designs that both incentivize safety and support capability building in low‑resourced settings. The committee recessed for a break and planned a second session on measuring patient safety in value‑based care.

