Department of Health and Human Services OFFICE OF INSPECTOR GENERAL ADVERSE EVENTS IN HOSPITALS: NATIONAL INCIDENCE AMONG MEDICARE BENEFICIARIES Daniel R. Levinson Inspector General November 2010 OEI-06-09-00090 ? E X E C U T I V E S U M M A R Y OBJECTIVES To estimate the national incidence of adverse events for hospitalized Medicare beneficiaries, assess the preventability of such events, and estimate associated costs to Medicare. BACKGROUND The term "adverse event" describes harm to a patient as a result of medical care, such as infection associated with use of a catheter. The term "never events" refers to a specific list of serious events, such as surgery on the wrong patient, that the National Quality Forum (NQF) deemed "should never occur in a health care setting." The Tax Relief and Health Care Act of 2006 mandates that the Office of Inspector General report to Congress regarding the incidence of never events among Medicare beneficiaries, the payment for services in connection with such events, and the Centers for Medicare & Medicaid Services (CMS) processes to identify events and deny payment. We selected a nationally representative random sample of 780 Medicare beneficiaries from all beneficiaries discharged during October 2008. Physician reviewers determined (1) whether an adverse event occurred, (2) whether the event was on the NQF list of Serious Reportable Events or the Medicare list of hospital-acquired conditions (HAC), (3) what the level of harm was to the patient, and (4) whether the event was preventable. To establish an estimated adverse event incidence rate, we included events on the NQF and the HAC lists and events resulting in the most serious harm as defined by a patient harm index (prolonged hospital stay, permanent harm, life-sustaining intervention, or death). We also determined the cost to Medicare for hospital care resulting from the events. Lastly, we identified additional events that resulted in temporary patient harm but were not comparable to the more serious events in our overall rate and assessed their preventability and cost. FINDINGS An estimated 13.5 percent of hospitalized Medicare beneficiaries experienced adverse events during their hospital stays. Of the nearly 1 million Medicare beneficiaries discharged from hospitals in October 2008, about 1 in 7 experienced an adverse event that met at least 1 of our criteria (13.5 percent). This rate projects to an estimated OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S i ? E X E C U T I V E S U M M A R Y 134,000 Medicare beneficiaries experiencing at least 1 adverse event in hospitals during the 1-month study period. We calculated incidence rates for adverse events that met our three criteria: 0.6 percent of beneficiaries had an NQF Serious Reportable Event, 1.0 percent had a Medicare HAC event, and 13.1 percent experienced an adverse event resulting in the four most serious categories of patient harm. An estimated 1.5 percent of Medicare beneficiaries experienced an event that contributed to their deaths, which projects to 15,000 patients in a single month. An additional 13.5 percent of Medicare beneficiaries experienced events during their hospital stays that resulted in temporary harm. Temporary harm events are those that require intervention but do not cause lasting harm. Although many cases represent fairly minor occurrences, such as hypoglycemia, others were classified as temporary harm only because the patients were in the hospital for lengthy periods as a result of other, more serious, diagnoses, allowing hospitals enough time to address the harm prior to discharge. Additionally, 28 percent of beneficiaries who experienced adverse events also had temporary harm events during the same stay. Physician reviewers determined that 44 percent of adverse and temporary harm events were clearly or likely preventable. Physicians determined that 44 percent of all events were preventable and 51 percent were not preventable. (For the remaining 5 percent of events, physicians were unable to make determinations.) Events related to surgery or procedures were less likely to be preventable than other types of events, such as hospital-acquired infections. Preventable events were linked most commonly to medical errors, substandard care, and lack of patient monitoring and assessment. Physician reviewers assessed events as not preventable when they occurred despite proper assessment and care or when the patients were highly susceptible to the events due to health status. Nearly all events on the NQF and Medicare lists were assessed as preventable, a key criterion of both lists. Hospital care associated with adverse and temporary harm events cost Medicare an estimated $324 million in October 2008. Sixteen percent of sample beneficiaries in the Medicare Inpatient Prospective Payment System who experienced events incurred additional Medicare costs as a result. The added costs equate to an estimated 3.5 percent of Medicare's expenditure for inpatient care during October 2008. To give these figures an annual context, OEI-06-09-00090 ADVERSE EVENTS H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S IN ii ? E X E C U T I V E S U M M A R Y 3.5 percent of the $137 billion Medicare inpatient expenditure for FY 2009 equates to $4.4 billion spent on care associated with events. Two-thirds of Medicare costs associated with events were the result of entire additional hospital stays necessitated by harm from the events. Additionally, these Medicare cost estimates do not include additional costs required for followup care after the sample hospitalizations. RECOMMENDATIONS As the Federal Government's principal agency for protecting the health of Americans, the Department of Health & Human Services (HHS) is uniquely positioned to lead national efforts to reduce adverse events in hospitals. As part of a national strategy to improve health care quality mandated by the Patient Protection and Affordable Care Act (ACA), HHS is to identify areas that have the potential for improving health care quality. Because many adverse events we identified were preventable, our study confirms the need and opportunity for hospitals to significantly reduce the incidence of events. A number of agencies within HHS share responsibility for addressing this issue, most prominently the Agency for Healthcare Research and Quality (AHRQ) as a coordinating body for efforts to improve health care quality and CMS as an oversight entity and the Nation's largest health care payer. Therefore, we recommend the following: AHRQ and CMS should broaden patient safety efforts to include all types of adverse events. This broader definition would apply to a number of activities, including setting priorities for research, establishing guidelines for hospital reporting, developing prevention strategies, measuring health care quality, and determining payment policies. AHRQ and CMS should enhance efforts to identify adverse events. Identifying adverse events assists policymakers and researchers in directing resources to the areas of greatest need, setting clear goals for improvement, assessing the effectiveness of specific strategies, holding hospitals accountable, and gauging progress in reducing incidence. ? ? AHRQ should sponsor periodic, ongoing measurement of the incidence of adverse events. AHRQ should continue to encourage hospital participation with Patient Safety Organizations, entities intended to receive adverse OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S iii ? E X E C U T I V E S U M M A R Y event reports from hospitals, and forward the information to a national AHRQ database. ? CMS should use Present on Admission Indicators in billing data to calculate the frequency of adverse events occurring within hospitals. CMS should provide further incentives for hospitals to reduce the incidence of adverse events through its payment and oversight functions. The ACA makes several changes to the HAC policy, including allowing the Secretary of HHS to expand the list of HACs. The ACA gives the HAC policy greater significance by using the list of HACs to implement Medicare payment penalties, create performance measures, and prohibit Medicaid payments for associated care. The conditions of participation for Medicare and Medicaid require that hospitals have programs to demonstrate quality improvement where evidence shows practices can improve outcomes. ? CMS should strengthen the Medicare HAC policy, such as by expanding the policy to include more events that harm beneficiaries. CMS should look for opportunities to hold hospitals accountable for adoption of evidence-based practice guidelines. ? AGENCY COMMENTS We received comments on the draft report from AHRQ and CMS. AHRQ concurred with our recommendations, stating that adverse events affect hospital patients at an "alarming rate" and that it must continue working to improve patient safety. AHRQ stated that it intends to foster continued improvement in both identifying and reducing adverse events through operational programs, research efforts, and further collaboration with other agencies. CMS also concurred with our recommendations, stating that it is committed to the reduction of adverse events in hospitals and other health care settings and that although it has taken significant steps to address these issues, more work needs to be done. CMS stated that it will "aggressively pursue" broadening the scope and definition of patient safety efforts to be more inclusive of various types of adverse events and more closely monitor and address hospital quality of care. CMS also outlined several current and planned efforts to both create incentives and provide support for patient safety improvements by hospitals. We made minor changes to the report based on technical comments. OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S iv ? ? T A B L E O F C O N T E N T S EXECUTIVE SUMMARY .....................................i INTRODUCTION ........................................... 1 F I N D I N G S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 An estimated 13.5 percent of hospitalized Medicare beneficiaries experienced adverse events during their hospital stays. . . . . . . . . . . . . 15 An additional 13.5 percent of Medicare beneficiaries experienced events during their hospital stays that resulted in temporary harm . . . 20 Physician reviewers determined that 44 percent of adverse events and temporary harm events were clearly or likely preventable . . . . . . . 22 Hospital care associated with adverse events and temporary harm events cost Medicare an estimated $324 million in October 2008 . . . . . 27 R E C O M M E N D A T I O N S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30 Agency Comments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33 A P P E N D I X E S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35 A: Tax Relief and Health Care Act of 2006 . . . . . . . . . . . . . . . . . . . . . . 35 B: National Quality Forum Serious Reportable Events . . . . . . . . . . . . 37 C: Medicare Hospital-Acquired Conditions . . . . . . . . . . . . . . . . . . . . . . 38 D: Glossary of Selected Terms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39 E: Methodology for Identifying Events and Determining Preventability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41 F: Estimates, Confidence Intervals, and Key Statistics . . . . . . . . . . . . 46 G: Rates of Adverse Events and Temporary Harm Events by Patient Days and Hospital Admissions . . . . . . . . . . . . . . . . . . . . . . 50 H: Adverse Events and Temporary Harm Events . . . . . . . . . . . . . . . . . 51 I: Agency Comments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62 A C K N O W L E D G M E N T S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 74 OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S v ? ? I N T R O D U C T I O N OBJECTIVES To estimate the national incidence of adverse events for hospitalized Medicare beneficiaries, assess the preventability of such events, and estimate associated costs to Medicare. BACKGROUND Statutory Mandate and Office of Inspector General Response The Tax Relief and Health Care Act of 2006 (the Act) requires that the Office of Inspector General (OIG) report to Congress regarding the incidence of "never events" among Medicare beneficiaries; the extent to which the Medicare program paid, denied payment, or recouped payment for services furnished in connection with such events; and the processes that the Centers for Medicare & Medicaid Services (CMS) uses to identify such events and deny or recoup payment. 1 OIG is also to make recommendations for such legislation and administrative action as OIG determines is appropriate. (For relevant text of the Act, see Appendix A.) To meet the requirements of the Act, OIG released a series of reports beginning in 2008 and will publish additional reports based on ongoing work. 2 Adverse Events in Hospitals Following a review of Medicare policies and expenditures, as well as consultation with CMS and the Agency for Healthcare Research and Quality (AHRQ), we chose to focus our work on inpatient acute care hospitals. For fiscal year (FY) 2009, Medicare costs for inpatient care were $137 billion, constituting 28 percent of total expenditures. 3 As a condition of participation in the Medicare and Medicaid programs, Federal regulations require that hospitals develop and maintain Quality Assessment and Performance Improvement (QAPI) Programs. 4 As a in Hospitals: Overview of Key Issues, OEI-06-07-00470; Adverse Events in Hospitals: State Reporting Systems, OEI-06-07-00471; and Adverse Events in Hospitals: Case Study of Incidence Among Medicare Beneficiaries in Two Counties, OEI-06-08-00220, all published in December 2008; Adverse Events in Hospitals: Public Disclosure of Information About Events, OEI-06-09-00360, January 2010; and Adverse Events in Hospitals: Methods for Identifying Events, OEI-06-08-00221, March 2010. 1 Tax Relief and Health Care Act of 2006, P.L. 109-432 ? 203. 2 The studies in the series published to date are: Adverse Events 2009 CMS Statistics Book, Table III.6, Office of Research, Development, and Information, CMS Pub. No. 03497, December 2009, p. 30. 4 42 CFR ? 481.21. 3 CMS, OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 1 ? I N T R O D U C T I O N part of their QAPI programs, hospitals must "track medical errors and adverse patient events, analyze their causes, and implement preventive actions." 5 Federal regulations do not require specific program characteristics. The QAPI provisions also require that hospitals establish programs to demonstrate improvement in quality indicators for which there is evidence that practices will improve outcomes. 6 As an additional quality effort, Quality Improvement Organizations (QIO) contract with CMS to assist hospitals in improving the quality of care for Medicare beneficiaries, including addressing patient safety issues. 7 A variety of terms, lists, and definitions are used to identify health care events that result in patient harm. For purposes of the Act, the term "never event" means an event that is listed and endorsed as a serious reportable event by the National Quality Forum (NQF) 8 as of November 16, 2006. 9 The NQF uses the term "serious reportable events" to describe a specific list of events associated primarily with patient death or serious disability that are both egregious and preventable, concluding that they "should never occur in a health care setting." These became known as "never events." (For a list of NQF Serious Reportable Events, see Appendix B.) The NQF list is often used by patient advocates and health care payers in establishing patient safety policies. 10 The health care community now uses the term "adverse event" more commonly than "never event" to refer to harm experienced by a patient as a result of medical care. After consulting with congressional committee staff in 2007, we expanded our approach to be consistent with patient safety research and industry trends. As used in this study, an adverse event is defined as harm to a patient as a result of medical care or in a health care setting. Although an adverse event indicates that the care resulted in an undesirable clinical 5 42 CFR ? 482.21(c)(2). 6 42 CFR ? 482.21(a)(1). 7 CMS, QIO Overview, last modified January 2010. Accessed at http://www.cms.hhs.gov/QualityImprovementOrgs/ on September 29, 2010. 8 NQF is a public-private membership organization created to develop and implement a national strategy for health care quality measurement and reporting. 9 The Act, ? 203(d). The NQF list is available online at http://www.qualityforum.org. 10 As an example, The Leapfrog Group, a national nonprofit focused on patient safety issues, encourages hospitals to adopt policies to address Serious Reportable Events. Leapfrog Group Position Statement on Never Events, updated November 11, 2009. Accessed at http://www.leapfroggroup.org/for_hospitals/leapfrog_hospital_survey_copy/never_events on September 29, 2010. OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 2 ? I N T R O D U C T I O N outcome and may involve medical errors, adverse events do not always involve errors, negligence, or poor quality of care and are not always preventable. 11 Research and policy to improve patient safety and reduce the incidence of adverse events often focus on identifying and addressing systemic problems that may lead to patient harm and avoid labeling the event as an outcome of negligence or poor quality. Additionally, researchers, policymakers, and health care entities sometimes adopt different standards for distinguishing between degrees of patient harm in determining whether they classify an occurrence as an adverse event. Thus, entities tracking events may find different results depending on the list used to identify and classify events. The National Coordinating Council for Medication Errors Reporting and Prevention (NCC MERP) Index for Categorizing Errors can be used to classify adverse events by level of patient harm. The NCC MERP Index was initially developed to categorize the effect of medication errors and considers whether the occurrences had an effect on the patients and, if so, how harmful they were. The index includes categories for circumstances or occurrences that presented a risk but did not cause harm, often referred to as "near misses," and those that caused harm. Table 1 shows the NCC MERP Index for Categorizing Errors. Table 1: The NCC MERP Index for Categorizing Errors Level A B C D E F G H I Description Circumstances or events occurred that had the capacity to cause error. Error occurred but did not reach the patient. Error occurred that reached the patient but did not cause patient harm. Error occurred that reached the patient and required monitoring to preclude harm or confirm that it caused no harm. Error occurred that may have contributed to or resulted in temporary harm and required intervention. Error occurred that may have contributed to or resulted in harm and required an initial or prolonged hospital stay. Error occurred that contributed to or resulted in permanent patient harm. Error occurred that required intervention to sustain the patient's life. Error occurred that may have contributed to or resulted in patient death. Harm reaches patient Harm does not reach patient Event Source: NCC MERP Index for Categorizing Errors, Press Release, Medication Errors Council Revises and Expands Index for Categorizing Errors: Definitions of Medication Errors Broadened, June 12, 2001. 11 R.M. Wachter, Understanding Patient Safety, McGraw-Hill, 2008. OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 3 ? I N T R O D U C T I O N Researchers have used the NCC MERP index for measuring and distinguishing other types of adverse events, rather than only medication errors. For example, the Institute for Healthcare Improvement (IHI), a nonprofit organization that advises hospitals regarding health care quality, uses a modified version of the NCC MERP index to measure the degree of patient harm, regardless of whether the harm was the result of an error. 12 Present on Admission Indicators and Medicare's Hospital-Acquired Conditions Policy Medicare reimbursement to acute care hospitals through the Inpatient Prospective Payment System (IPPS) is generally determined by grouping codes representing patient conditions into Diagnosis-Related Groups (DRG) based on the average cost of care for patients with similar conditions. 13 Hospitals may submit Medicare claims under IPPS using nine diagnosis codes and six procedure codes for each hospital stay. Historically, if a Medicare beneficiary experienced an adverse event that resulted in assignment of a more costly DRG, CMS paid the higher DRG. 14 Beginning October 1, 2007, hospitals are required to assign a Present on Admission (POA) Indicator to each principal and secondary diagnosis for acute IPPS claims for all discharges. 15 This was an initial step in complying with the Deficit Reduction Act of 2005 (DRA), which required CMS to select at least two hospital-acquired conditions (HAC) for which hospitals would not be paid higher Medicare reimbursement. 16 12 F.A. Griffin and R.K. Resar, IHI Global Trigger Tool for Measuring Adverse Events, Institute for Healthcare Improvement Innovation Series 2007, pp. 4-5. 13 CMS, Acute Inpatient PPS Overview, last modified Feb. 22, 2010. The ICD-9-CM system assigns diagnoses and procedure codes associated with hospital stays and is maintained jointly by CMS and the National Center for Health Statistics. Accessed at http://www.cms.gov/AcuteInpatientPPS/01_overview.asp on September 29, 2010. Eliminating Serious, Preventable, and Costly Medical Errors - Never Events, May 18, 2006. 15 CMS, CMS Manual System, Change Request 5679 (July 20, 2007). To effectuate the use 14 CMS, Press Release, of POA indicators, the FY 2008 IPPS rule implemented a more specific list of DRGs called Medicare Severity Diagnosis-Related Groups (MS-DRG). MS-DRGs split some of the prior DRGs into two or three classes based on the presence of a complication or comorbidity. FY 2008 IPPS Final Rule, 72 Fed. Reg. 47130, 47138 (Aug. 22, 2007). 16 DRA, P.L. 109-171 ? 5001(c)(1), Social Security Act (SSA), ? 1886(d)(4)(D), 42 U.S.C. ? 1395ww(d)(4)(D). OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 4 ? I N T R O D U C T I O N In response, CMS issued regulations outlining a policy to deny hospitals higher payment for hospital admissions complicated by any of 10 categories of HACs. 17 The DRA required that the conditions meet the following criteria: ? ? ? ? conditions that are high cost, high volume, or both; conditions that, when present as a secondary diagnosis, result in assignment of a case to a DRG that has a higher payment; conditions that could be reasonably prevented by using readily available evidence-based guidelines; and conditions that are identifiable based on one or more unique diagnosis codes. 18 Effective October 1, 2008, CMS began denying hospitals higher payment for care associated with these conditions. 19 Examples of HACs include catheter-associated urinary tract infections and patient injury because of a fall. For the full list of Medicare HACs, see Appendix C. Determining the Incidence of Adverse Events Research indicates that identifying adverse events retrospectively is a complex and difficult task, requiring extensive clinical knowledge, adequate documentation, and subjectivity on the part of the researcher. 20 Medical records review is often considered the most definitive method for detecting adverse events because it can provide detail about both the adverse event and the circumstances, such as the patient's condition prior to and following the event. 21 However, medical records reviews can be costly, requiring hospital staff to make records available and substantial effort by physicians or other clinicians to review them. To limit physician medical records reviews required to identify adverse events, cases can be screened to identify potential 17 FY 2008 IPPS Final Rule, 72 Fed. Reg. 47130, 47202 (Aug. 22, 2007); and FY 2009 IPPS Final Rule, 73 Fed. Reg. 48434, 48471-48491 (Aug. 19, 2008). 18 SSA, ? 1886(d)(4)(D)(iv). 19 FY 2009 IPPS Final Rule, 73 Fed. Reg. 48434, 48471-48472 (Aug. 19, 2008); CMS, CMS Manual System, Change Request 6189 (Oct. 3, 2008). 20 E.J. Thomas and L.A. Peterson, Measuring Errors and Adverse Events in Health Care, Journal of General Internal Medicine, 18(1), 2003, pp. 61-67. 21 E.J. Thomas, D.M. Studdert, and T.A. Brennan, The Reliability of Medical Record Review for Estimating Adverse Event Rates, Annals of Internal Medicine, 136(11), June 2002, pp. 812-816. OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 5 ? I N T R O D U C T I O N adverse events using other methods, such as nurse reviews of medical records and analysis of POA indicators in hospital claims data. Nurse review of medical records. Medical records screening can identify potential adverse events based on information in the medical records. The IHI Global Trigger Tool (GTT) uses a review of medical records to identify "triggers" that could signal patient harm, thereby identifying potential adverse events. A trigger could be a description of the harm itself or a reference that indicates harm occurred (such as a return to surgery). The review is designed to be completed by nurse reviewers, with the results then confirmed or refuted by a physician. Barriers to medical records screening include incomplete records and high labor costs for review. Analysis of POA indicators. Automated computer programs can review Medicare billing data, specifically the POA indicator codes assigned to each diagnosis, to identify conditions that developed during hospital stays and possibly constitute adverse events. Although these programs enable examination of large numbers of hospital stays, barriers exist to POA analysis, including inaccurate or incomplete data. CMS's POA coding requirement began in October 2007, and the accuracy and completeness of hospital coding of POA indicators have not yet been validated. Additionally, conditions can be acquired in hospitals that are not related to medical care and therefore not adverse events. OIG case study. Prior to this study, we conducted a case study of the incidence of adverse events occurring during October 2008 for a random sample of 278 Medicare beneficiaries' hospital stays in 2 counties. 22 We estimated that 15 percent of Medicare beneficiaries in the two counties experienced events meeting at least one of the following criteria: events on the NQF list of Serious Reportable Events; events on Medicare's list of HACs; or events involving prolonged hospital stays, permanent harm, life-sustaining intervention, or death (classified as F-I level of harm on the NCC MERP index). An additional 15 percent of beneficiaries experienced events involving temporary harm (classified as E level of harm on the NCC MERP index). The case study served in part to test the usefulness of various methods for identifying adverse events. We found that, combined, nurse screening of medical records and analysis 22 OIG, Adverse Events in Hospitals: Case Study of Incidence Among Medicare Beneficiaries, OEI-06-08-00220, December 2008. OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 6 ? I N T R O D U C T I O N of POA indicator codes in billing data identified 94 percent of occurrences that physicians ultimately determined to be adverse or temporary harm events. 23 Determining the Preventability of Adverse Events To provide additional context regarding adverse events, some researchers have assessed whether adverse events were preventable and described the circumstances associated with events. A 2008 review of eight preventability studies found that the median percentage of adverse events judged preventable was 43.5 percent. 24 Assessing preventability can provide greater understanding of the causes of adverse events, which can be used to develop actionable solutions to the systemic problems that lead to events. Also, preventability is a statutory criterion of Medicare's nonpayment policy for HACs; CMS was required to select only conditions that can be "reasonably prevented by using readily available evidence-based guidelines." 25 Reducing the Incidence of Adverse Events Reducing the incidence of adverse events in hospitals is a critical component of efforts to improve patient safety and quality care. The Institute of Medicine (IOM) report, To Err Is Human: Building a Safer Health System, focused widespread attention on the problem of adverse events. IOM cited two studies that used medical records reviews to identify adverse events and assess whether events were preventable. IOM concluded that preventable adverse events caused "at least 44,000 and perhaps as many as 98,000 deaths in hospitals each year" and outlined a national plan to address adverse events. 26 As part of its plan, IOM recommended the creation of a nationwide system for the collection of standardized adverse event data by State governments. As reported by OIG, 25 States and the District of Columbia had adverse event reporting systems in 2008, 11 of which 23 OIG, Adverse Events in Hospitals: Methods for Identifying Events, OEI-06-08-00221, March 2010. The Incidence and Nature of In-Hospital Adverse Events: A Systematic Review, British Medical Journal - Quality and Safety in Health Care, 17(3): 216-23, June 2008. 25 SSA, ? 1886(d)(4)(D)(iv), 42 CFR ? 412.10; FY 2008 IPPS Final Rule, 72 Fed. Reg. 47130, 47202 (Aug. 22, 2007). 26 L.T. Kohn, J.M. Corrigan, and M.S. Donaldson, eds., To Err Is Human: Building a Safer Health System, A Report of the Committee on Quality of Health Care in America, p. 102, 24 E.N. De Vries, M.A. Ramrattan, et al., IOM, National Academy Press, 2000. OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 7 ? I N T R O D U C T I O N used the NQF list of Serious Reportable Events or a modified version of the list to define what events are reportable. 27 To date, no national adverse event reporting system exists and there are no Federal standards regarding State systems. Following the IOM report, the Federal Government formed the Center for Quality Improvement and Patient Safety (CQuIPS) within AHRQ to provide national leadership in improving patient safety. In a 2009 report, AHRQ identified its core agency objectives for CQuIPS as developing a solid evidence base, designing useful tools for providers, and disseminating information for implementation. 28 As mandated by Congress, AHRQ releases an annual report to the Nation about health care quality that is produced by CQuIPS and includes measures of patient safety. 29 The National Healthcare Quality Report includes measures of the incidence of certain types of adverse events, using data from sources such as the Medicare Patient Safety Monitoring System (MPSMS), an AHRQ-CMS collaborative effort to identify adverse events through analyses of medical records and Medicare claims data for beneficiaries' hospital stays. 30 AHRQ is also responsible for implementation and oversight of the certification process for Patient Safety Organizations (PSO) created by the Patient Safety Act and Quality Improvement Act of 2005. 31 PSOs are in the early stages of development, but are intended to receive adverse event reports from hospitals and forward the information to a national AHRQ database from which CQuIPS will analyze aggregated data. AHRQ developed a set of event definitions and reporting tools known as the Common Formats, which PSOs can choose to use and which contain data elements that AHRQ determined are important for a complete and 27 OIG, Adverse Events in Hospitals: State Reporting Systems, OEI-06-07-00471, December 2008. 28 AHRQ, Advancing Patient Safety: A Decade of Evidence, Design, and Implementation, AHRQ Publication No. 09(10)-0084, November 2009. Accessed at http://www.ahrq.gov/qual/advptsafety.htm on September 29, 2010. 29 Healthcare Research and Quality Act of 1999, P.L. 106-129 ? 2(a); Public Health Service Act (PHSA), ? 913, 42 U.S.C. ? 299b-2. 30 D.R. Hunt, N. Verzier, et al., "Fundamentals of Medicare Patient Safety Surveillance: Intent, Relevance, and Transparency," Advances in Patient Safety, 2005, p. 105. Accessed at www.ahrq.gov/downloads/pub/advances/vol2/Hunt.pdf on September 29, 2010. 31 The Secretary of Health and Human Services (Secretary) delegated authority to AHRQ to make these determinations, as well as to fulfill other requirements of the Patient Safety Act. Patient Safety and Quality Improvement Act of 2005, P.L. 109-41 ? 2, PHSA, ? 924, 42 U.S.C. ? 299b-24; 73 Fed. Reg. 70732 (Nov. 21, 2008). OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 8 ? I N T R O D U C T I O N useful adverse event report. 32 A variety of organizations are eligible to become PSOs, including hospital associations, hospital chains, and patient safety consulting groups. 33 For a 2009 OIG study, staff from selected PSOs reported barriers that could limit hospital participation in PSOs and questioned the usefulness of submitting data for aggregation. 34 Finally, the American Recovery and Reinvestment Act of 2009 appropriated $300 million to AHRQ to sponsor and disseminate research that compares the effectiveness of clinical care options, the purpose of which is to promote evidence-based medical care. 35 In March 2010, Congress passed health care reform legislation in the form of the Patient Protection and Affordable Care Act (ACA). 36 The ACA includes a number of provisions to take effect over multiple years, including expanded funding and authority to the Department of Health and Human Services (HHS) to address health care quality issues. Among the initial efforts to implement the ACA, the Secretary is to establish a national strategy for quality improvement in health care by January 1, 2011. 37 The law requires that the strategy address eight national priority areas, one of which is to improve patient safety. 38 It also increases funding to CQuIPS for research grants to explore best practices. 39 Among its payment provisions, the ACA expands the Medicare HAC policy to mandate hospital payment penalties for high rates of HACs, 40 create new quality measures, 41 and require State Medicaid agencies to deny higher reimbursement for care associated with HACs. 42 Common Formats for Patient Safety Data Collection and Event Reporting, Notice of Availability: Common Formats Version 1.0, September 2, 2009. Accessed at http://www.pso.ahrq.gov/formats/commonfmtv1_0fr.htm on October 12, 2010. 33 PHSA, ? 924(b), 42 U.S.C. ? 299b-24(b). 34 OIG, Adverse Events in Hospitals: Public 32 AHRQ, Disclosure of Information About Events, OEI-06-09-00360, January 2010. 35 American Recovery and Reinvestment Act of 2009, P.L. 111-5, Division A, Title VIII. 36 ACA, P.L. 111-148, was signed into law on March 23, 2010, after we had completed data collection and analysis for this study. 37 P.L. 111-148 ? 3011, PHSA, ? 399HH, 42 U.S.C. ? 280j. 38 P.L. 111-148 ? 3011, PHSA, ? 399HH(a)(2)(B)(vii), 42 U.S.C. ? 280j(a)(2)(B)(vii). 39 P.L. 111-148 ? 3501, PHSA, ?? 933 and 934. 40 P.L. 111-148 ? 3008(a), SSA, ? 1886(p), 42 U.S.C. ? 1395ww(p). 41 P.L. 111-148 ? 3013 inserted new section 931 of the PHSA, 42 U.S.C. ? 299b-31, and added section 1890A(e) of the SSA, 42 U.S.C. ? 1395aaa-1(e). 42 P.L. 111-148 ? 2702. OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 9 ? I N T R O D U C T I O N METHODOLOGY Scope This report estimates the national incidence of adverse events based on a representative sample of Medicare beneficiaries discharged from inpatient acute care hospitals during October 2008. Our results are projectable to all Medicare beneficiaries hospitalized during this period nationwide. To determine the estimated rate of adverse events, we used criteria developed by NQF, CMS, and NCC MERP. We included in the estimated national incidence rate all patient harm that occurred during the hospital stay, regardless of whether it was preventable. Also, the report provides a physician assessment of the extent to which identified events were preventable and analysis of billing data to estimate the cost to the Medicare program for increased reimbursement resulting from all events and preventable events. Sample Selection We selected a sample of Medicare beneficiaries from the National Claims History (NCH). Of the 999,645 beneficiaries discharged from acute care hospitals during October 2008, we selected a random sample of 785 beneficiaries. We excluded 5 beneficiaries as ineligible because the hospital was currently under OIG investigation, resulting in a sample of 780 beneficiaries. In July-October 2009, we requested and received medical records from hospitals regarding sample beneficiaries' hospital stays. Fifty-four of the beneficiaries had more than 1 hospital stay during October (50 had 2 stays and 4 had 3 stays). Combined, sample beneficiaries had 838 hospital stays with discharges in October 2008 and an average length of stay of 5.2 days. 43 Identifying Adverse Events and Determining Preventability We conducted a two-stage review to identify adverse events experienced by each beneficiary. The first stage used three screening methods to identify cases likely to include an event. This enabled us to reduce the number of cases requiring the second-stage physician review. During the first stage, we identified cases that met one or more of the following conditions: (1) certified medical coders identified codes in the Medicare claims data that were listed as not present on admission, (2) nurse reviewers found evidence of a potential adverse event in the medical 43 The average length of stay for hospitalized Medicare beneficiaries overall in 2007 was 5.6 days. CMS, 2009 CMS Statistics, Table IV.1 Medicare Short-stay Hospital Utilization, 2009, Tab 1. OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 10 ? I N T R O D U C T I O N records, or (3) the beneficiary had a hospital admission within 30 days after discharge for his or her last sample hospital stay ending in October 2008. 44 We identified 420 cases for the second stage of review, which entailed a review of the full medical records by physicians to identify events. To ensure consistency across physician reviewers, we facilitated weekly conference calls during which all physician reviewers discussed cases that either were complex or had possible implications for other cases. We included events experienced by patients during hospital stays or during prior, contiguous outpatient visits (wherein patients were transferred directly from outpatient care to inpatient care within the same facility). For example, we included in our count an adverse event that occurred in a hospital emergency department immediately preceding admission to inpatient care. We did not include events that occurred prior to a beneficiary's arrival on the hospital campus. When an initial event caused a series of related events for the same patient, we collapsed the events into a "cascade event," which counted as a single event. 45 For a glossary of selected clinical terms used to describe events, see Appendix D. As part of the structured protocol, physician reviewers also determined the extent to which the identified events were preventable. Generally speaking, physicians assessed events as preventable when they determined that harm could have been avoided through improved assessments or alternative actions. Physicians assessed an event as not preventable when they determined that harm could not have been avoided given the complexity of the patient's condition or the care required. The physician protocol used the following response scale for assessing the preventability of events: clearly preventable, likely preventable, clearly not preventable, likely not preventable, and unable to determine. Physicians used their clinical experience and judgment to make preventability determinations. They considered all evidence in 44 We reviewed records for admissions that occurred within 30 days of the last beneficiary discharge. Therefore, the 30-day window for reviewing readmissions did not span a fixed timeframe but began on the unique final discharge date for each beneficiary with the last possible admission occurring on November 30, 2008 (30 days following the final possible October 31, 2008, discharge). 45 Based on OIG interviews with IHI staff, IHI defines a cascade event as one in which an initial event causes a series of related events for the same patient and advocates collapsing these into a single event. OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 11 ? I N T R O D U C T I O N the medical records, including the actions of hospital and medical staff and the patient's condition. Assessing an event as clearly preventable or clearly not preventable required a greater degree of certainty on the part of the reviewer. For detailed information about the methodology for identifying events and determining preventability, see Appendix E. Data Analysis We performed analysis and generated estimates about adverse events for three categories: incidence of events, preventability of events, and Medicare cost associated with events. We also calculated separate estimates regarding these categories for temporary harm events. For estimates and corresponding 95-percent confidence intervals for all statistical analyses, see Appendix F. Adverse event incidence analysis. We calculated the estimated national adverse event incidence rate as the percentage of Medicare beneficiaries with at least one adverse event. We defined adverse events as events that met at least one of the following criteria: 1. the event was on the NQF list of Serious Reportable Events, as the Act mandates; 2. the event was on Medicare's list of HACs for which it denies higher payment; or 3. the event resulted in one of the four most serious categories on the NCC MERP index (classified on the index as F-I): - prolonged hospital stay, - permanent harm, - life-sustaining intervention, or - death. We also calculated individual rates for adverse events on the NQF list, the Medicare HAC list, and events classified as F-I on the NCC MERP index. The overall adverse event incidence rate does not include events that physician reviewers identified as temporary harm events, defined as events that required intervention but did not cause lasting harm (classified as E level harm on the NCC MERP index). We excluded these temporary harm events from our overall rate because we determined, in consultation with physician reviewers, that the effect of these events was not comparable to the more serious events meeting the three criteria. We calculated a separate incidence rate for beneficiaries who experienced only temporary harm events. We projected incidence rates to the population of Medicare beneficiaries discharged from inpatient acute care hospital stays during October 2008. OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 12 ? I N T R O D U C T I O N As an additional measure of adverse event rates, we calculated 2 ratios of adverse event incidence density: events per 1,000 patient days and events per 100 hospital admissions. These measures are commonly used by hospitals and medical researchers. 46 For the resulting metrics and an explanation of the calculation method, see Appendix G. Preventability analysis. The findings related to preventability are based on determinations made by the physician reviewers for each adverse event and temporary harm event. We calculated percentages for each preventability classification and for different types of events, the results of which are projectable to the population. We also conducted statistical tests to identify differences in preventability rates between adverse events and temporary harm events and across various categories of adverse events, such as medication-related and infection-related events. Medicare cost analysis. We estimated the cost to Medicare resulting from care associated with adverse events and temporary harm events. This analysis included only Medicare claims that were paid under the IPPS and were subject to the Medicare HAC policy (84 percent of sample beneficiaries). 47 Certified medical coders reviewed the medical records, the medical review protocols, and the associated Medicare claims to identify diagnosis and procedure codes that would not have been included in the claims if the events had not occurred. We then used CMS's MS-DRG Grouper and Medicare Code Editor Version 27 (Grouper) to determine the DRG for the claims and used the FY 2009 IPPS personal computer Pricer (Pricer) to determine the resulting Medicare reimbursement amounts. 48 For each claim, we calculated the DRG and reimbursement amount, including information from the 46 K.M. Arias, Outbreak Investigation, Prevention, and Control in Health Care Settings, Second Edition, Jones and Bartlett Publishers, 2009, pp. 330-331. 47 The cost analysis does not include claims for beneficiaries whose Medicare coverage is not paid under the IPPS. This includes Medicare managed care organizations and care provided at hospitals excluded from the Medicare IPPS system, including hospitals in the State of Maryland and some specialty hospitals nationwide, such as cancer treatment centers and critical access hospitals. CMS, HAC Fact Sheet. Accessed at http://www.cms.gov/HospitalAcqCond/Downloads/HACFactsheet.pdf on September 29, 2010. 48 The Grouper software classifies hospital claims into MS-DRG categories expected to have similar hospital resource requirements. MS-DRGs are based on the nine diagnoses associated with HACs and corresponding POA indicators, six procedure codes, and demographic data contained in the NCHs. MS-DRGs typically split into two or three individual classes based on the presence of a complication or comorbidity. This software was developed by CMS and 3M and is sold by the National Technical Information Service. Accessed at http://www.ntis.gov on September 29, 2010. OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 13 ? I N T R O D U C T I O N hospital Medicare claim. We then calculated the reimbursement amount excluding diagnosis and procedure codes that coders determined were the direct result of any adverse event or temporary harm event experienced by the beneficiary. We projected the difference between the two hospital reimbursement amounts to estimate the additional cost to Medicare for care associated with events. When an entire hospital stay was the result of an adverse event, we included the total reimbursement amounts indicated by the Pricer as the cost of the adverse event. Limitations Beyond the challenges associated with identifying adverse events and assessing preventability, the methodology presents two specific limitations. First, it is unlikely that the study identified all adverse and temporary harm events within the sample. To the extent that the study did not identify an event, it was likely because the three screening methods failed to flag the case for physician review or because documentation in the medical records was incomplete. Second, cost estimates did not include all costs of care associated with events, excluding stays not covered under the Medicare IPPS, additional hospital stays caused by sample events but occurring after October 2008, additional care outside the hospital (such as followup physician office visits or rehabilitation services), and changes in Medicare outlier payments. 49 Standards This study was conducted in accordance with the Quality Standards for Inspections approved by the Council of the Inspectors General on Integrity and Efficiency. 49 Medicare outlier payments are supplemental payments to hospitals for patients who incur extraordinarily high costs. Outlier payments are based on the degree to which costs on a claim exceed specific hospital and MS-DRG fixed-loss thresholds and fluctuate depending on the MS-DRG to which the claim is grouped. The Pricer analysis involved a revision of the MS-DRG. This revision resulted in new outlier payments for three sample cases and increased outlier payments for two sample cases. The revised outlier payments decreased the cost attributed to adverse events in our estimate. OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 14 ? ?I F F ID NI D G N G S I S N N Of the nearly 1 million Medicare beneficiaries discharged from hospitals in October 2008, about 1 in 7 experienced an adverse event (13.5 percent), defined as an event that met at least 1 of the following 3 criteria: the event was on the NQF list of Serious Reportable Events; the event was on Medicare's list of HACs; or the event resulted in 1 of the 4 most serious categories on the NCC MERP index (prolonged hospital stay, permanent harm, life-sustaining intervention, or death). This incidence rate projects to approximately 134,000 Medicare beneficiaries experiencing at least 1 adverse event in hospitals during the study period. Table 2 lists the incidence rate for each of the three criteria. An estimated 13.5 percent of hospitalized Medicare beneficiaries experienced adverse events during their hospital stays Table 2: Estimated National Incidence of Adverse Events Among Medicare Beneficiaries Discharged in October 2008 Category of Events Estimated Percentage of Medicare Beneficiaries 0.6% 1.0% 13.1% (1.3%) 13.5%*** Estimated Number of Medicare Beneficiaries 6,367 10,187 129,890 (12,734) 133,710 NQF Serious Reportable Events* Medicare HACs* NCC MERP F-I Level Events (Overlap)** Total See Appendix F for confidence intervals. *Given the small proportions, confidence intervals for projected numbers exceed 50-percent relative precision. **The 1.3 percent represents beneficiaries who experienced adverse events in more than one category. We counted these beneficiaries only once in determining the overall incidence rate. ***Column does not sum to 13.5 percent because of rounding. Source: OIG analysis of hospital stays for 780 Medicare beneficiaries discharged in October 2008. We classified the identified adverse events into four clinical categories: events related to medication (31 percent), events related to ongoing patient care (28 percent), events related to surgery or other procedures (26 percent), and events related to infection (15 percent). Table 3 lists the 128 adverse events found in the sample within these categories. See Appendix H for a list of the events with more complete descriptions, the level of harm patients incurred, and indications of whether the events were on the NQF and HAC lists. OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 15 ? F I N D I N G S Table 3: Adverse Events Identified Among Sample Medicare Beneficiaries by Clinical Category (n=128) Types of Adverse Events Number of Events and Percentages of Total Events Events Related to Medication Excessive bleeding Delirium or change in mental status Hypoglycemic event Acute renal insufficiency (kidney failure) Severe hypotension Respiratory complications Severe allergic reactions 31% (40) 12 7 6 4 4 4 3 Events Related to Patient Care Intravenous volume overload Aspiration Deep vein thrombosis or pulmonary embolism Exacerbation of preexisting medical condition Stage III pressure ulcer Breakdown of surgical wound Congestive heart failure Hypoxia (oxygen deficiency) Patient fall with injury Prolonged weakness and dizziness 28% (36) 10 8 5 5 3 1 1 1 1 1 Events Related to Surgery or Other Procedures Excessive bleeding Severe hypotension Respiratory complication Iatrogenic pneumothorax Postoperative ileus Postoperative urinary retention Acute coronary syndrome Blood clot and other occlusion Cardiac complication Cardiac dysrhythmia Delay in surgery because of equipment malfunction Hemorrhage at surgical site Seroma (fluid) following stomach resection Urinary catheter-associated trauma 26% (33) 5 4 4 3 3 3 2 2 2 1 1 1 1 1 Events Related to Infection Urinary tract infection Vascular catheter-associated infection (central or peripheral line) Other bloodstream infection Respiratory infection Surgical or procedural site infection Source: OIG analysis of hospital stays for 780 Medicare beneficiaries in October 2008. 15% (19) 5 4 4 4 2 Of beneficiaries who experienced adverse events, 18 percent had more than one adverse event. Most of the beneficiaries who experienced multiple events had two events, but others had as many as three OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 16 ? F I N D I N G S unrelated events in the same hospitalization. For example, an elderly heart patient with a history of mental illness experienced three adverse events of different types, including two events that prolonged hospitalization and a third that required life-sustaining intervention. (This beneficiary also experienced three temporary harm events associated with patient care.) Less than 1 percent of Medicare beneficiaries experienced an event on the NQF list of Serious Reportable Events An estimated 0.6 percent of Medicare beneficiaries experienced an event on the NQF list, which projects to approximately 6,400 beneficiaries nationally for the study period. The low number of NQF events in the sample is notable because of the prominence of the list as a measure of patient harm and its use by a number of State adverse event reporting systems and other entities. We identified a total of five NQF events in the sample: two medication-related deaths and three Stage III pressure ulcers. 50 One of the medication-related deaths illustrates the nature of the NQF list as a measure of the most egregious preventable outcomes. In this case, a disabled Medicare beneficiary with muscular dystrophy affecting the respiratory system entered the hospital for signs of respiratory failure. Medical staff at the hospital gave the beneficiary a medication known to further suppress respiration, resulting in progressive respiratory distress and subsequent death. Physician reviewers concluded that medical staff administered the wrong medication because they lacked clinical understanding of the patient's unique condition. Many serious events that we identified were not on the NQF list of Serious Reportable Events, including some events that resulted in patient deaths and serious disability. The NQF list focuses largely on serious disability or death, but is restricted to a specific set of events. Of the 18 adverse events that physician reviewers found to result in serious disability or patient death, only 2 were on the NQF list (i.e., the medication errors resulting in death). The three Stage III pressure ulcers identified in the sample were sufficiently treated prior to 50 Pressure ulcers are classified into four stages by the National Pressure Ulcer Advisory Panel (NPUAP): Stage I is intact skin with nonblanchable redness; Stage II is a shallow ulcer or blister indicating damage to the epidermis; Stage III is damage extending through all the layers of the skin; and Stage IV is damage through all the layers of the skin and underlying muscle, tendons, or bone. NPUAP, Pressure Ulcer Stages Revised by NPUAP. Accessed at http://www.npuap.org on November 12, 2009. OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 17 ? F I N D I N G S discharge from the hospital and determined by physicians to have caused only temporary harm. Medicare HACs rarely occurred, affecting just 1 percent of beneficiaries An estimated 1 percent of hospitalized Medicare beneficiaries experienced Medicare HACs, which projects to approximately 10,000 beneficiaries nationally. We identified a total of nine Medicare HACs experienced by beneficiaries in the sample: five catheter-associated urinary tract infections, two vascular catheter-associated infections of the central line, one patient fall resulting in injury (a compression fracture), and one Stage III pressure ulcer. One beneficiary experienced two of these events, resulting in a total of eight sample beneficiaries with Medicare HACs. Two catheter-associated urinary tract infections caused more substantial harm than is typically associated with this condition: one resulted in a prolonged hospital stay and the other in permanent harm. The two vascular catheter-associated infections of a central line resulted in prolonged hospital stays. None of the nine Medicare HACs identified by physicians on the medical records were included in the associated Medicare claims. In four of the nine cases (all catheter-associated urinary tract infections), diagnosis codes on the claims identified the infections, but they were not the precise codes that CMS uses to identify these HACs. The other five claims had no diagnosis codes related to the HACs. Therefore, the HACs were not identifiable through the claims data that CMS uses to implement the HAC policy. Thirteen percent of Medicare beneficiaries experienced adverse events classified in the most serious categories on the NCC MERP harm index Based on our physician medical review, 13.1 percent of Medicare beneficiaries experienced adverse events classified in the four most serious harm categories on the NCC MERP harm index: events resulting in prolonged hospital stay, events resulting in permanent harm, events requiring life-sustaining intervention, and events contributing to death. This rate projects nationally to approximately 130,000 beneficiaries experiencing such adverse events during the study period. Often, adverse events within the same clinical category, such as infection, resulted in a different level of harm depending on the intervention required and the condition of the patient. Table 4 lists the percentage of adverse events in the sample that were classified in the four most serious harm categories and the projected national numbers of events by level of patient harm. OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 18 ? F I N D I N G S Table 4: Adverse Events Classified as F-I on the NCC MERP Patient Harm Index by Level of Harm Level of Harm F level: Requiring prolonged hospital stay G level: Permanent harm* H level: Life-sustaining intervention required I level: Contributing to death* See Appendix F for confidence intervals. *Given the small proportions, confidence intervals for projected numbers exceed 50-percent relative precision. Source: OIG analysis of hospital stays for 780 Medicare beneficiaries discharged in October 2008. Percentage of Adverse Events 62% 5% 23% 10% An estimated 1.5 percent of hospitalized Medicare beneficiaries experienced events that contributed to their deaths Among the 128 adverse events that we identified in the sample, 12 events (9 percent of 128 events) contributed to the deaths of beneficiaries. This projects to an estimated 1.5 percent of hospitalized Medicare beneficiaries experiencing events that contributed to death or approximately 15,000 beneficiaries during the study period. Seven of the twelve deaths were related to medication, either the result of improper administration of medication (wrong drug or wrong dosage) or inadequate treatment of known side effects. The most common type of medication-related death (five deaths) involved excessive bleeding from blood-thinning medication. The two other medication-related deaths involved inadequate insulin management resulting in hypoglycemic coma and respiratory failure resulting from oversedation. Of the five non-medication-related deaths, two were from bloodstream infections; two involved aspiration (which led to pneumonia and cardiac arrest, respectively); and the other involved a ventilator-associated pneumonia. As stated previously, only 2 of the 12 adverse events that contributed to death were on the NQF list and none were Medicare HACs. Twenty-seven percent of beneficiaries who experienced adverse events had at least one "cascade" event, wherein multiple, related events occurred in succession The sample included a total of 28 cascade events, defined as adverse events that included a series of multiple, related events. We counted these as single events. These cascade events were some of the most serious adverse events identified in the sample, with nine cases requiring life-sustaining intervention and six cases contributing to death. The most common type of cascade events were events related to OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 19 ? F I N D I N G S surgery and other procedures (nine events). Two of these events began with excessive bleeding following surgery or a procedure. For example, one beneficiary had excessive bleeding after his kidney dialysis needle was inadvertently removed, which resulted in circulatory shock, a transfer to the intensive care unit, and emergency insertion of a tube into the trachea (windpipe) to ease breathing. When the tube was removed the following day, the patient aspirated (inhaled foreign material into his lungs), which required a life-sustaining intervention. An additional 13.5 percent of Medicare beneficiaries experienced events during the study period classified as E level harm on the NCC MERP index, defined as events that required medical intervention but did not cause lasting harm. This rate projects to approximately 134,000 Medicare beneficiaries experiencing temporary harm events during the study period. Of these beneficiaries, 22 percent had more than one unrelated event (the highest occurrence was five unrelated events in a single hospital stay). Additionally, 28 percent of beneficiaries who experienced adverse events (and are included in our primary rate) also had temporary harm events during the same stay. An additional 13.5 percent of Medicare beneficiaries experienced events during their hospital stays that resulted in temporary harm Events classified as temporary harm represented a wide array of conditions, such as prolonged vomiting and hypoglycemia (see Table 5). The most common events related to medication (42 percent). Although many cases of temporary harm represented fairly minor occurrences, we classified others as temporary because the patients were in the hospital for a lengthy period because of other, more serious, diagnoses, allowing the hospital enough time to address the harm prior to discharge. Physician reviewers indicated that many temporary harm events could have developed into more serious adverse events, but hospitals provided timely intervention. For example, Stage I or Stage II pressure ulcers can escalate quickly to Stage III or Stage IV without proper care 51 and episodes of hypoglycemia can lead to stroke and even death. 52 51 J.L. Zeller, C. Lynm, and R.M. Glass, Pressure Ulcers, Journal of the AMA, 296(8), August 23/30, 2006, p. 1020. Accessed at http://jama.ama-assn.org on December 1, 2009. 52 P. Mandava and T. Kent, Metabolic Disease & Stroke: Hyperglycemia/Hypoglycemia, Journal of Diabetes Science and Technology, 17, April 4, 2006, p. 8. Accessed at http://emedicine.medscape.com on December 1, 2009. OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 20 ? F I N D I N G S Table H-2 in Appendix H contains a list of the 174 temporary harm events identified in the sample with more complete descriptions. Table 5: Temporary Harm Events Identified Among Sample Medicare Beneficiaries by Clinical Category (n=174) Types of Temporary Harm Events Number of Events and Percentage of Total Events Events Related to Medication Delirium or change in mental status Hypoglycemic event Thrush and other opportunistic infection Allergic reaction or side effect related to skin Gastrointestinal complication Hypotension Dysrhythmia Excessive bleeding Severe headache or dizziness Acute renal failure or insufficiency Allergic reaction to blood or related products Respiratory complication Other events related to medication 42% (73) 22 11 7 6 5 5 3 3 3 2 2 2 2 Events Related to Patient Care Stage I, Stage II, or unstaged pressure ulcer Intravenous volume overload Skin tear, laceration, abrasion, or other breakdown Intravenous infiltrate with symptoms Patient fall with injury Aspiration Failure to treat constipation or obstipation Tachycardia or dysrhythmia 36% (63) 20 15 9 6 5 3 3 2 Events Related to Surgery or Other Procedures Urinary retention Excessive bleeding Cardiac complication Surgical tear or laceration Urinary catheter-related trauma Prolonged nausea and vomiting Postoperative or postprocedural hypotension Respiratory complication Other events related to surgery or other procedures 18% (32) 8 6 4 3 3 2 2 2 2 Events Related to Infection Surgical site infection Bacterial infection Respiratory infection Urinary tract infection Vascular catheter-associated infection Source: OIG analysis of hospital stays for 780 Medicare beneficiaries in October 2008. 4% (6) 2 1 1 1 1 OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 21 ? F I N D I N G S Physician reviewers determined that 44 percent of adverse events and temporary harm events were clearly or likely preventable Physician reviewers assessed the extent to which events were preventable based on information in the medical records, their clinical experience with similar circumstances, research literature about the preventability of specific events, and group discussion to reach consensus. Combining adverse events and temporary harm events, physicians determined that 44 percent were preventable and 51 percent were not preventable. 53 (There was no statistically significant difference between the preventability rates of adverse events and temporary harm events.) 54 For the remaining 5 percent of events, physicians were unable to make determinations because of incomplete documentation in the medical records or extreme complexities in the patients' conditions or in the hospital care provided. Table 6 provides the percentage of events by the physician preventability assessment. Table 6: Events by Physician Preventability Assessment Preventability Assessment Preventable--Harm could have been avoided through improved assessment or alternative actions Clearly preventable Likely preventable Not preventable--Harm could not have been avoided given the complexity of the patient's condition or care required Clearly not preventable Likely not preventable Unable To Determine Preventability Source: OIG analysis of hospital stays for 780 Medicare beneficiaries discharged in October 2008. Percentage of Events 44% 9% 35% 51% 18% 33% 5% Physician reviewers assessed the preventability of events similarly for three of the four clinical categories (medication, patient care, and infections). However, events related to surgery and other procedures were significantly less likely to be determined preventable than events in the other three clinical categories; only 17 percent of surgical events were 53 The preventability rate of 44 percent is similar to the rate of 43.5 percent found by a 2008 review of 8 adverse event preventability studies previously referenced on p. 7. 54 The Cochran-Mantel-Haenszel chi square test was not significant at the 95-percent confidence level (p=0.0568). See Appendix F for detailed preventability statistics for adverse events and temporary harm events. OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 22 ? F I N D I N G S preventable in contrast to 50 percent or more in each of the other three groups. 55 Physician reviewers indicated that the reasons surgical events were more likely to be assessed as not preventable were the high level of complexity in both the care involved and the patients' conditions. Table 7 provides the percentage of preventable events by clinical category. Table 7: Preventable Events Within Clinical Categories Clinical Category Infection Medication Patient care Surgery and other procedures Source: OIG analysis of hospital stays for 780 Medicare beneficiaries discharged in October 2008. Percentage of Events Assessed as Preventable 60% 50% 51% 17% Within the clinical categories, physician reviewers sometimes gave the same preventability assessment for events with similar characteristics. For example, they assessed 10 of 12 events related to allergic reactions as not preventable. But for other types of events, preventability determinations for similar events differed based on the patients' conditions and risk factors. For example, in two cases of excessive stomach bleeding caused by blood thinners, physicians assessed one event affecting a relatively healthy patient as preventable and the other event affecting a patient with stomach ulcers as not preventable because of the patient's susceptibility. In another case, physician reviewers determined that some pressure ulcers were not preventable because of the poor conditions of the patients and because documentation in the medical records showed that the hospital staff employed appropriate preventive care. However, physicians assessed another pressure ulcer case as preventable because the medical staff declined to order a specialty mattress for an at-risk bedridden patient until after the pressure ulcer had developed, even though the medical record indicated that the specialty bed was available. 55 The Cochran-Mantel-Haenszel chi square test was significant at the 95-percent confidence level for the overall relationship between preventability and clinical category (p<0.0001) as well as for each set of pair-wise comparisons between the surgical category and each of the other three clinical categories (p<0.01 for each pair). Preventability rates were 62 percent for infections, 50 percent for medication, and 50 percent for patient care. OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 23 ? F I N D I N G S Counting only preventable events, the estimated national incidence rate of adverse events among Medicare beneficiaries would be 7.4 percent The estimated adverse event incidence rate of 13.5 percent is based on all adverse events' meeting one of the three criteria, regardless of whether the events were preventable. Including only the adverse events determined by physician reviewers to be clearly or likely preventable, the estimated incidence rate of adverse events among Medicare beneficiaries would be 7.4 percent. The 13.5 percent rate of additional beneficiaries experiencing temporary harm events would be 6.3 percent if only preventable events were included. Eleven of the thirteen NQF Serious Reportable Events and Medicare HACs in the sample were preventable, a key criterion of both lists Although we found few in the sample, all but two adverse events on the NQF and HAC lists were assessed as clearly or likely preventable. 56 After the adverse events on each list were separated, four of the five events on the NQF list were preventable and eight of the nine Medicare HACs were preventable (one event was on both lists). A key criterion of both lists is that the events be largely preventable. The two events on the lists that physicians assessed as not preventable were (1) an NQF event consisting of a pressure ulcer that progressed from Stage I to Stage III in a chronically ill patient with multiple complications and susceptibility to skin breakdown and (2) a Medicare HAC consisting of a compression fracture incurred during a fall by a morbidly obese patient. Preventable events were most commonly linked to medical errors, substandard treatment, and inadequate patient monitoring or assessment Physician reviewers selected one or more rationales to support each preventability determination from a list developed by the physician panel. To develop these rationales, physicians gleaned information from medical records, such as clinical staff actions, hospital environmental factors, and patient condition unrelated to the event. Among events assessed as preventable, 58 percent were linked to errors by clinical staff in medical judgment, skill, or patient management. Such errors often involved prescribing or administering the wrong medication. Nearly half of preventable events (46 percent) involved care provided in a substandard way, most frequently because of delay in diagnosis or 56 The number of NQF and HAC events was too small to test the preventability measure for statistical significance with an acceptable degree of precision or to project the measure to the national sampling frame. OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 24 ? F I N D I N G S treatment. Table 8 provides physician preventability rationales for events within each assessment category. Table 8: Events by Physician Preventability Rationales Preventability Rationale Preventable Events (n=133) Error was related to medical judgment, skill, or patient management Appropriate treatment was provided in a substandard way The patient's progress was not adequately monitored The patient's health status was not adequately assessed Necessary treatment was not provided Event rarely happens when proper precautions and procedures are followed** Communication between caregivers was poor** Facility's patient safety systems and policies were inadequate or flawed** Breakdown in hospital environment occurred (equipment failure, etc.)** Nonpreventable Events (n=155) Event occurred despite proper assessment and procedures followed Patient was highly susceptible to event because of health status Care provider could not have anticipated event given information available Patient's diagnosis was unusual or complex, making care difficult Harm was anticipated but risk considered acceptable given alternatives** See Appendix F for confidence intervals. *Percentages do not add to 100 because physician reviewers often selected more than 1 rationale. **Given the small percentages, confidence intervals for projected numbers exceed 50-percent relative precision. Source: OIG analysis of hospital stays for 780 Medicare beneficiaries discharged in October 2008. Percentage of Events* 58% 46% 38% 23% 17% 14% 8% 3% 2% 62% 50% 35% 29% 14% Other common factors associated with preventable events were inadequate monitoring of patients (38 percent) and inadequate assessment of patients (23 percent). These factors often led to delays in treatment and worsening of patient conditions. In several of these cases, patients displayed symptoms of infection but were not given antibiotics until they reached the point of sepsis. In one case, the patient exhibited signs of shock upon arrival at the hospital, but clinical staff did not monitor the patient's blood pressure for the first 8 hours and did not provide related treatment for another 16 hours. This delay caused the patient to experience severe hypotension, requiring life-sustaining intervention. OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 25 ? F I N D I N G S Physician reviewers assessed events as clearly or likely not preventable when the events occurred despite proper procedures or when the patients were highly susceptible to the events For 62 percent of the nonpreventable events in our sample, physician reviewers found that care was rendered according to accepted standards of practice. In these cases, physicians determined that the care provided was sufficient and appropriate and that there was no evidence of errors or other problems. This rationale was often given in combination with the second most common factor--that the patients' other conditions made them highly susceptible to the event (50 percent of nonpreventable events). For example, one beneficiary, admitted to the hospital with a bowel obstruction, experienced a surgical cut of the intestine that would have been difficult to avoid because of significant damage to the bowel from prior surgery. Other common rationales for assessing events as not preventable also focused on the difficulty of providing care. For 35 percent of nonpreventable events, physicians determined that the medical and hospital staff could not have anticipated the events given information available about the patients at the time of care delivery. For 29 percent of nonpreventable events, physicians determined that the patients' diagnoses were unusual or complex, making care particularly difficult. Finally, in 14 percent of nonpreventable cases, the adverse events were anticipated by caregivers, but the harm associated with the adverse events was considered less harmful than not providing care. For example, in four sample cases, patients experienced harm as a result of an overload of intravenous fluid, yet the medical review found that the patients were in such dire need of fluids (e.g., at risk for hypoglycemic shock) that caregivers had little choice but to execute vigorous intravenous fluid replacement despite the risk of overload. OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 26 ? F I N D I N G S Hospital care associated with adverse events and temporary harm events cost Medicare an estimated $324 million in October 2008 Sixteen percent of sample beneficiaries under the Medicare IPPS who experienced events incurred additional Medicare hospital costs as a result. Most of the additional costs (87 percent) resulted from care associated with adverse events, with temporary harm events generating the remaining costs. 57 These additional costs project to an estimated $324 million, which equates to 3.5 percent of the $9.2 billion that Medicare spent for inpatient care during October 2008. 58 To give these figures an annual context, 3.5 percent of the $137 billion Medicare inpatient expenditure in FY 2009 equates to $4.4 billion spent on care associated with adverse events. 59 Costs associated with preventable events accounted for an estimated $119 million of the $324 million additional cost, equating to 1.3 percent of the $9.2 billion Medicare inpatient expenditures for the month or about $1.8 billion annually. Despite this outlay, most events did not affect Medicare costs; none of the Medicare HACs resulted in a higher reimbursement Of beneficiaries who experienced adverse events or temporary harm events in hospitals covered under the Medicare IPPS, 84 percent did not incur additional costs for care associated with the events. This occurred primarily because many Medicare claims for beneficiaries who experienced events did not include diagnosis or procedure codes relating to the events. When Medicare claims included codes associated with the events, the codes often had no effect on costs because the claims included other costly diagnoses or procedure codes that elevated the reimbursement to equivalent or higher amounts. 57 One Medicare claim included codes for two events--one adverse event and one temporary harm event--and incurred an identical payment impact. This claim overlaps both groups and consequently the percentages do not total 100 percent: 87 percent of costs resulted from care associated with adverse events and 15 percent of costs resulted from care associated with temporary harm events. 58 These cost estimates include only claims under the IPPS, representing 708 sample Medicare claims (85 percent), but do not include costs for the remaining 130 sample beneficiaries (15 percent) who had sample admissions not covered under IPPS. 59 The annual cost estimate of $4.4 billion is 3.5 percent of the $137 billion Medicare inpatient costs for FY 2009, which assumes the same proportion of costs for adverse events for the other 11 months that we found in October 2008. Annual Medicare inpatient cost figures are from CMS, 2009 CMS Statistics Book, Table III.6, Office of Research, Development, and Information, CMS Pub. No. 03497, December 2009, p. 30. OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 27 ? F I N D I N G S None of the nine Medicare HACs identified in the sample resulted in a higher level of Medicare reimbursement. Although the Medicare HAC policy is intended to limit costs associated with the specified events, our review showed that none of the HACs in the sample would have invoked a higher Medicare reimbursement. None of the associated Medicare claims included the specific diagnosis codes that CMS uses to identify HACs. However, even if the codes had been included on the claims, the HAC policy would still not have resulted in payment reductions for these cases because other diagnosis or procedure codes would have elevated the reimbursement to a higher amount. Two-thirds of Medicare costs associated with events were the result of additional hospital stays necessitated by harm from events Sixty-five percent of the additional costs to Medicare ($210 million of the $324 million) were the result of entire, additional hospital stays required to treat the harm resulting from the adverse events. In some of these cases, the events occurred during outpatient services at the hospital (such as an emergency room visit or an outpatient surgery) and necessitated unplanned admissions to the inpatient facilities. In other cases, the events occurred during inpatient care and the beneficiaries were released from the hospital, but the aftereffects of the events necessitated subsequent hospital stays within the study period. The average Medicare cost of these additional hospital stays for sample beneficiaries was $13,745, compared with an average additional cost of $5,601 for event-related care that hospitals provided during the initial hospital stay in situations that did not necessitate additional stays. 60, 61 Medicare cost estimates do not include additional costs required for followup care after the sample hospitalization Because our cost analysis included only hospital stays that ended during October 2008, Medicare costs associated with care resulting from adverse events and temporary harm events are greater than our estimate. Beneficiaries may have had additional event-related hospital stays beyond our study period and may have incurred expenses to Medicare or personal expenses for followup care not reflected in inpatient claims, such as physician office visits, medication, and rehabilitation services during and after our study period. 60 Averages reflect only costs greater than zero. 61 The Student's T-test comparing difference of means was significant at the 95-percent confidence level (p=0.0104). OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 28 ? F I N D I N G S As an example of an event resulting in subsequent Medicare costs not captured by our cost analysis, one sample beneficiary was initially admitted to the hospital in mid-October 2008 for a stroke. During this hospital stay, he experienced an allergic reaction to medication and was discharged with no additional cost associated with the event. However, following discharge, the allergic reaction progressed to a life-threatening condition known as Stevens-Johnson Syndrome. 62 The beneficiary returned to the hospital during October for treatment, incurring the cost of an entire hospital stay as a result of the event, but was misdiagnosed and again discharged. The patient then incurred two additional hospital stays within the next 30 days to correctly diagnose and treat the condition. The total estimated inpatient cost to Medicare for the latter three hospital stays was $43,050, all necessitated by the event. Only $10,982 of this amount was incurred during the study period and included in our cost estimate. Physician reviewers determined that the medication-related event was preventable because the medication was known to be highly reactive and the condition was not diagnosed correctly, delaying treatment. 62 This condition typically begins with a skin rash and fever and, if untreated, progresses to an array of conditions constituting serious harm, such as lung damage and renal failure. OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 29 ? ? R E C O M M E N D A T I O N S In the decade since the IOM report, the need to improve patient safety has received much attention from Federal and State governments, advocacy groups, and the health care industry. Despite this attention, we found that 13.5 percent of Medicare beneficiaries experienced adverse events during their hospital stays in October 2008, most of which resulted in prolonged hospital stays, permanent harm, life-sustaining interventions, or death. An additional 13.5 percent of beneficiaries experienced temporary harm as the result of events. Physician reviewers determined that 44 percent of events were preventable and that preventable events often involved medical errors, substandard care, and inadequate monitoring or assessment of patients. We found that in addition to causing the harm to patients, adverse events and temporary harm events increased costs to Medicare by an estimated $324 million in a single month, or 3.5 percent of Medicare inpatient expenditures, suggesting potential savings from reducing the incidence of events. As the Federal Government's principal agency for protecting the health of Americans, 63 HHS is uniquely positioned to lead national efforts to reduce adverse events in hospitals. As part of the national strategy to improve health care quality mandated by the ACA, HHS is to "identify areas in the delivery of health care services that have the potential for rapid improvement in the quality and efficiency of patient care." 64 Because many adverse events that we identified were preventable, our study confirms the need and opportunity for hospitals to significantly reduce the incidence of events. A number of agencies within HHS share responsibility for addressing this issue, most prominently AHRQ as a coordinating body for efforts to improve health care quality and CMS as the Nation's largest health care payer and an oversight entity. Therefore, we recommend the following: AHRQ and CMS should broaden patient safety efforts to include all types of adverse events Efforts to improve patient safety often focus on a small subset of events that harm hospital patients. For example, NQF Serious Reportable Events or Medicare HACs represented only a fraction of HHS Agency Mission Statement, updated February 2004. Accessed at http://www.hhs.gov/about/ on March 23, 2010. 64 P.L. 111-148 ? 3501. 63 HHS, OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 30 ? R E C O M M E N D A T I O N S the adverse events we identified in this report. Additionally, patient safety provisions in the ACA often refer specifically to reducing medical errors, rather than to the broader range of adverse events. AHRQ and CMS should avoid focusing patient safety efforts too narrowly on a small list of specific events, possibly failing to address the wider array of events that lead to most instances of patient harm. Rather, AHRQ and CMS should promote a definition of adverse events that more fully encompasses harm resulting from medical care. This broader definition would apply to a number of patient safety activities, including setting priorities for research, establishing guidelines for hospital reporting of events, developing prevention strategies, measuring health care quality, and determining payment policies. AHRQ and CMS should enhance efforts to identify adverse events Identifying adverse events assists policymakers and clinical researchers in directing prevention resources to the areas of greatest need, setting clear goals for improvement, assessing the effectiveness of specific strategies, holding hospitals accountable, and gauging progress in reducing incidence. ? AHRQ should sponsor periodic, ongoing measurement of the incidence of adverse events. To facilitate measurement, AHRQ should establish a standard protocol for identifying events and analyzing information about incidence and causes. AHRQ should also consider providing hospitals with methods for measuring their incidence of events, goals for incidence reduction, and benchmarks or other means for comparing rates among providers. AHRQ should continue to encourage hospitals to report to PSOs. Hospital reporting of adverse event information to PSOs can provide AHRQ with aggregated data about the nature and causes of events. To maximize the usefulness of PSO-reported data for national measurement and analysis, AHRQ should continue working toward establishing standard adverse event definitions and reporting formats and encouraging hospital reporting. CMS should use POA indicators in hospital billing data to calculate the frequency of adverse events occurring within hospitals. These POA indicator data represent a rich source of information for identifying certain adverse events in claims data. CMS should establish routine methods for using POA indicators to guide patient safety improvement efforts. For example, CMS could direct that IN ? ? OEI-06-09-00090 ADVERSE EVENTS H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 31 ? R E C O M M E N D A T I O N S QIOs use POA indicators to monitor hospital rates of specific conditions. CMS should provide further incentives for hospitals to reduce the incidence of adverse events through its payment and oversight functions CMS, as both a payer and an oversight entity, is positioned to influence hospitals to provide high-quality care. CMS should explore avenues to reduce the incidence of adverse events through both program participation and payment policy. ? CMS should strengthen the Medicare HAC policy. We found that HACs represent a small proportion of preventable events and that they are not always coded as such in Medicare claims. The ACA makes several changes to the HAC policy, including allowing the Secretary to expand the list of HACs. The law also gives the HAC policy greater significance by using the list of HACs to implement Medicare payment penalties, create performance measures, and prohibit Medicaid payments for associated care. Given their low incidence, continued use of the 10 HACs already established by CMS may limit the intended effect of the statute. To strengthen the policy, CMS should consider expanding the list of Medicare HACs to include more conditions that may result in harm to beneficiaries. CMS should also take additional steps to ensure that hospitals accurately code Medicare claims to show when HACs occur, as recommended in our prior report. 65 CMS should look for opportunities to hold hospitals accountable for adoption of evidence-based practice guidelines. The conditions of participation for Medicare and Medicaid require that hospitals have programs to demonstrate quality improvement where evidence shows practices can improve outcomes. CMS should further influence hospitals to reduce adverse events through enforcement of the conditions of participation. This could include more closely examining patient safety issues through the survey and certification process, as recommended in our prior report. 66 This could also include encouraging hospitals to adopt evidence-based practices shown to prevent adverse events. ? 65 OIG, Adverse Events in Hospitals: Methods for Identifying Events, OEI-06-08-00221, March 2010. 66 Ibid. OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 32 ? R E C O M M E N D A T I O N S AGENCY COMMENTS We received comments on the draft report from AHRQ and CMS. AHRQ. AHRQ concurred with our recommendations, stating that adverse events affect hospital patients at an "alarming rate" and that it must continue working to improve patient safety. In response to our recommendation to broaden patient safety efforts to include all types of adverse events, AHRQ noted that the types of events vary widely and that efforts should be broadened beyond prescribed lists of adverse events. AHRQ stated that it has sponsored efforts to address specific types of adverse events and to address causes that contribute to a wide variety of adverse events. AHRQ also cited the recent development of its Common Formats, a set of event definitions and reporting forms not limited to a specific list of events designed for hospitals to use to report events to PSOs. In response to our recommendation to enhance efforts to identify adverse events, AHRQ stated that it intends to foster continued improvement in both identifying and reducing adverse events through operational programs, research efforts, and further collaboration with other agencies. Specifically, AHRQ noted that the Common Formats facilitate identification of events for both internal hospital purposes and reporting to PSOs. AHRQ also cited a continued commitment to its Patient Safety Indicators methodology as a way to identify events in administrative data and a planned expansion of the MPSMS program, which identifies adverse events in medical records acquired through CMS. AHRQ plans to expand the MPSMS by broadening the areas of clinical investigation, seeking to address all patient populations rather than only Medicare beneficiaries, and working toward sharing the MPSMS methodology with other organizations. CMS. CMS concurred with our recommendations and stated that it is committed to the reduction of adverse events in hospitals and other health care settings. CMS provided details about current activities and future plans to reduce adverse events, concluding that although it has taken significant steps to address these issues, more work needs to be done. In response to our recommendation to broaden patient safety efforts to include all types of adverse events, CMS stated that it will "aggressively pursue" broadening the scope and definition of patient safety efforts to be more inclusive of various types of adverse events. As an example, OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 33 ? R E C O M M E N D A T I O N S CMS noted that it is expanding hospital reporting of quality data to include more measures of adverse events. In response to our recommendation to enhance efforts to identify adverse events, CMS stated that it will continue to use POA indicators in implementing its Medicare HAC policy. CMS also referenced the use of POA indicators by QIOs to assist hospitals in reducing high-risk pressure ulcers and indicated that it is assessing the broader use of POA indicators by QIOs to assess the incidence of adverse events and assist hospitals in developing quality improvement plans. In response to our recommendation to provide further incentives for hospitals to reduce the incidence of adverse events through payment and oversight, CMS stated its commitment to more closely monitor and address hospital quality of care. Specifically, CMS plans to strengthen the Medicare HAC policy by considering the appropriateness of expanding the conditions included, applying the policy to more health care settings, and working to improve the coding and reporting of POA indicators. CMS also stated that it is working toward improving evaluation of the hospital conditions of participation related to patient safety, developing interpretive guidelines and training for surveyors, and tasking QIOs with greater responsibility to address adverse events in hospitals. Further, CMS points to opportunities presented by the ACA, including implementation of the Hospital Value-Based Purchasing Program, which will use hospital performance as a basis for incentive payments; and creation of the Center for Medicare & Medicaid Innovation, which will address improvement in patient safety and reduction of adverse events. For the full text of AHRQ and CMS comments, see Appendix I. We made minor changes to the report based on technical comments. OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 34 ? ? A P P E N D I X ~ A Tax Relief and Health Care Act of 2006 P.L. No. 109-432 ? 203 DIVISION B - MEDICARE AND OTHER HEALTH PROVISIONS TITLE II--MEDICARE BENEFICIARY PROTECTIONS SEC 203 OIG STUDY OF NEVER EVENTS (a) Study.-- (1) In general.--The Inspector General in the Department of Health and Human Services shall conduct a study on-- (A) incidences of never events for Medicare beneficiaries, including types of such events and payments by any party for such events; (B) the extent to which the Medicare program paid, denied payment, or recouped payment for services furnished in connection with such events and the extent to which beneficiaries paid for such services; and (C) the administrative processes of the Centers for Medicare & Medicaid Services to detect such events and to deny or recoup payments for services furnished in connection with such an event. (2) Conduct of study.--In conducting the study under paragraph (1), the Inspector General-- (A) shall audit a representative sample of claims and medical records of Medicare beneficiaries to identify never events and any payment (or recouping of payment) for services furnished in connection with such events; (B) may request access to such claims and records from any Medicare contractor; and (C) shall not release individually identifiable information or facilityspecific information. (b) Report.--Not later than 2 years after the date of the enactment of this Act, the Inspector General shall submit a report to Congress on the study conducted under this section. Such report shall include recommendations for such legislation and administrative action, such as a noncoverage policy or denial of payments, as the Inspector General determines appropriate, including-- OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 35 ? A P P E N D I X ~ A (1) recommendations on processes to identify never events and to deny or recoup payments for services furnished in connection with such events; and (2) a recommendation on a potential process (or processes) for public disclosure of never events which-- (A) will ensure protection of patient privacy; and (B) will permit the use of the disclosed information for a root cause analysis to inform the public and the medical community about safety issues involved. (c) Funding.-- Out of any funds in the Treasury not otherwise appropriated, there are appropriated to the Inspector General of the Department of Health and Human Services $3,000,000 to carry out this section, to be available until January 1, 2010. (d) Never Events Defined.--For purposes of this section, the term "never event" means an event that is listed and endorsed as a serious reportable event by the National Quality Forum as of November 16, 2006. OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 36 ? ? A P P E N D I X ~ B National Quality Forum Serious Reportable Events Table B-1: The National Quality Forum (NQF) List of Serious Reportable Events Surgical Events A. B. C. D. E. A. B. C. A. B. C. Surgery performed on the wrong body part Surgery performed on the wrong patient Wrong surgical procedure performed on a patient Unintended retention of foreign object in a patient after surgery or procedure Intraoperative or immediately postoperative death Patient death or serious disability associated with use of contaminated drugs, devices, or biologics provided by the health care facility Patient death or serious disability associated with use or function of a device in patient care in which the device is used or functions other than as intended Patient death or serious disability associated with intravascular air embolism that occurs while being cared for in a health care facility Infant discharged to the wrong person Patient death or serious disability associated with patient elopement Patient suicide, or attempted suicide resulting in serious disability, while being cared for in a health care facility Patient death or serious disability associated with a medication error Patient death or serious disability associated with a hemolytic reaction because of administration of incompatible blood or blood products Maternal death or serious disability associated with labor or delivery in a low-risk pregnancy while cared for in a health care facility Patient death or serious disability associated with hypoglycemia, the onset of which occurs while patient is being cared for in a health care facility Death or serious disability associated with failure to identify and treat hyperbilirubinemia in neonates Stage III or Stage IV pressure ulcers acquired after admission to a health care facility Patient death or serious disability because of spinal manipulative therapy Artificial insemination with the wrong donor sperm or wrong egg Patient death or serious disability associated with an electric shock while being cared for in a health care facility Any incident in which a line designated for oxygen or other gas to be delivered to a patient contains the wrong gas or is contaminated by toxic substances Patient death or serious disability associated with a burn incurred from any source while being cared for in a health care facility Patient death or serious disability associated with a fall while being cared for in a health care facility Patient death or serious disability associated with the use of restraints or bedrails while being cared for in a health care facility Care provided by someone impersonating a health care provider Abduction of a patient of any age Sexual assault on a patient within or on the grounds of a health care facility Death or significant injury resulting from a physical assault that occurs within or on the grounds of the facility Product or Device Events Patient Protection Events Care Management Events A. B. C. D. E. F. G. H. A. B. C. D. E. A. B. C. D. Environmental Events Criminal Events Source: NQF, Serious Reportable Events in Health Care 2006 Update: Consensus Report, NQF, Washington, DC, 2007, p. 7. OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 37 ? ? A P P E N D I X ~ C Medicare Hospital-Acquired Conditions Table C-1: Medicare Hospital-Acquired Conditions Conditions 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. Foreign object retained after surgery Air embolism Blood incompatibility Pressure ulcers (stages III and IV) Falls A. Fracture B. Dislocation C. Intracranial injury D. Crushing injury E. Burn F. Electric shock Manifestations of poor glycemic control A. Hypoglycemic coma B. Diabetic ketoacidosis C. Nonkeototic hyperosmolar coma D. Secondary diabetes with ketoacidosis E. Secondary diabetes with hyperosmolarity Catheter-associated urinary tract infection Vascular catheter-associated infection Deep vein thrombosis/pulmonary embolism associated with the following A. Total knee replacement B. Hip replacement Surgical site infection A. Mediastinitis after coronary artery bypass graft B. Associated with certain orthopedic procedures involving the a. Spine b. Neck c. Shoulder d. Elbow C. Associated with certain bariatric surgical procedures for obesity a. Laparoscopic gastric bypass b. Gastroenterostomy c. Laparoscopic gastric restrictive surgery Source: Fiscal Year 2009 Final Inpatient Prospective Payment System Rule, 73 Fed. Reg. 48434, 48471 (Aug. 19, 2008). OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 38 ? ? A P P E N D I X ~ D Glossary of Selected Terms 67 Acute coronary syndrome--Condition in which the heart does not receive enough oxygen-rich blood, often marked by severe chest pain, unstable angina, and/or heart attack. Acute renal insufficiency--Sudden loss of the kidneys' ability to remove waste, also referred to as acute kidney failure. Adverse event--Harm to a patient as a result of medical care. For purposes of this study, we defined adverse events as events that met at least one of the following criteria: an event on the National Quality Forum list of Serious Reportable Events; an event on Medicare's list of hospital-acquired conditions (HAC) for which it denies higher payment; or an event resulting in one of the four most serious categories on a patient harm index (classified on the index as F-I): prolonged hospital stay, permanent harm, life-sustaining intervention, or death. Anticoagulant--Medication that hinders blood coagulation, typically used to avoid blood clots and referred to as blood-thinning medication. Aspiration--Accidental inhalation of foreign material into the lungs. Congestive heart failure--Condition in which the heart is unable to maintain adequate circulation of blood in the tissues of the body. Deep vein thrombosis (DVT)--Formation of a thrombus (blood clot) within a deep vein (as of the leg or pelvis) that is life threatening if dislodgment results in blockage to the pulmonary (lung) artery. Delirium--Mental disturbance characterized by confusion, disordered speech, and hallucinations. Dialysis--Medical procedure to remove wastes and toxins from the blood, and to adjust fluid and electrolyte imbalances. Dysrthymia--Condition of abnormal cardiac (heart) rhythm. Hypoglycemia--Condition of abnormally low blood sugar (glucose) level. Hypotension--Condition of abnormally low blood pressure. 67 Clinical definitions adapted from the National Institutes of Health, U.S. National Library of Medicine, Medline Plus Medical Dictionary, updated February 2003. Accessed at http://www.nlm.nih.gov on January 7, 2009. OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 39 ? A P P E N D I X ~ D Iatrogenic pneumothorax--Condition induced by therapeutic intervention in which air or other gas occurs in the pleural cavity. Ileus--Partial or complete obstruction of the bowel, marked by a painful distended abdomen, vomiting, toxemia, and dehydration. Intravenous (IV) infiltrate--Condition in which fluids administered by entering a vein accidentally enter the surrounding tissue. Intravenous (IV) volume overload--Condition in which fluid is given by vein at a higher rate or larger volume than can be absorbed or excreted. Obstipation--Condition of severe constipation (abnormally delayed passage of dry, hardened feces) that can result in bowel obstruction. Pressure ulcer--Ulceration of tissue deprived of adequate blood supply by prolonged pressure, also called decubitus ulcer and bedsore. Pressure ulcers are classified into four stages: Stage I is intact skin with nonblanchable redness; Stage II is a shallow ulcer or blister indicating damage to the epidermis; Stage III is damage extending through all the layers of the skin; and Stage IV is damage through all the layers of the skin and underlying muscle, tendons, or bone. 68 Pulmonary embolism--Obstruction of a pulmonary (lung) artery, often marked by shortness of breath; chest pain with inhalation; and, in severe cases, low blood pressure and death. Sepsis--Systemic response to a serious, usually localized infection of bacterial origin, such as systemic inflammatory response syndrome. Tachycardia--Condition of rapid heart rate. Temporary harm event--Harm to patient that required intervention but did not cause lasting harm, classified as E level on patient harm index. Thrush--Inflammation of the mouth and throat, caused by fungus. Urinary tract infection (UTI)--Infection of the tract through which urine passes and can include the kidney, ureters, bladder, and/or urethra. Ventilator-associated pneumonia (VAP)--Disease of the lungs characterized by inflammation of lung tissue and caused chiefly by infection that enters the lungs through a ventilator. Pressure Ulcer Stages Revised by NPUAP. Accessed at http://www.npuap.org on November 12, 2009. 68 National Pressure Ulcer Advisory Panel (NPUAP), OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 40 ? ? A P P E N D I X ~ E Methodology for Identifying Events and Determining Preventability Screening for Potential Adverse Events We conducted a two-stage review to identify adverse events. The first stage included three screening methods designed to identify beneficiaries who appeared likely to have experienced adverse events. A beneficiary was considered likely to have experienced an adverse event if any screening method found at least one potential adverse event during any of the beneficiary's hospital stays. The screening process enabled us to reduce the number of cases requiring second-level review of the full medical records by a physician. Additionally, physician reviewers indicated that the results of the screening methods helped them to more readily identify potential adverse events for consideration. The screening methods included: ? analysis by certified medical coders of Present on Admission (POA) Indicators included in Medicare claims data to identify any diagnoses that were acquired during the hospital stay; screening of medical records by nurse reviewers using a modified version of the Institute for Healthcare Improvement's Global Trigger Tool (IHI GTT) for triggers that could indicate an event, such as laboratory test results indicating an infection; and identification of any beneficiaries who were readmitted to the hospital within 30 days after their October 2008 hospital discharges. ? ? Analysis of POA Indicators. Using data from the National Claims History file, certified medical coders reviewed the POA indicator data included in hospital Medicare claims for each sample beneficiary. A recent addition required of Medicare Part A claims, the POA indicator codes require hospitals to make a clinical distinction about whether diagnoses are present at the time of admission. The coders first verified the accuracy of each POA indicator by reviewing the medical records and then flagged each diagnosis that had a POA indicator of "N" (not present on admission), "W" (clinical staff unable to determine), or "U" (documentation insufficient to determine). Analysis of POA indicators identified 297 beneficiaries for the second stage of the review. Nurse reviews of medical records. Contracted registered nurses conducted a preliminary review of medical records for each sample beneficiary to identify potential adverse events. Reviewers used a OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 41 ? A P P E N D I X ~ E modified version of the IHI GTT protocol, in which reviewers identified triggers in the medical records possibly indicative of adverse events and then explored the records further to determine whether events occurred and the resulting level of harm. Medical records screening identified 372 cases for inclusion in the second stage of review. Readmissions. We identified 92 sample beneficiaries who were readmitted to the hospital within 30 days after their discharges in October 2008 and included these cases in the second stage of review. We reviewed records for admissions that occurred within 30 days of the beneficiaries' last discharges; therefore, the 30-day window for reviewing readmissions did not span a fixed timeframe but began on the discharge date for each beneficiary. Flagged hospital stays. We identified 420 beneficiaries for the second stage of review, a review of the hospital medical records by physicians. Of the 420 beneficiaries, we identified 391 with the 3 screening methods and 29 from additional analysis. In the 29 additional cases, the beneficiaries were not flagged on the 3 screening methods, but staff involved in the screening process (nurses, coders, or analysts) believed complexities in the cases warranted physician review. Identifying Events Within Flagged Cases Five contracted physicians conducted medical records review of the 420 cases identified by the screening methods. Physician reviewers represented a variety of specializations and experience: an infectious disease specialist, a cardiologist, an orthopedic surgeon, an intensivist (intensive care specialist), and an internist. All five had many years of clinical experience, as well as prior experience in detecting adverse events in medical records. Three of the five served as physician reviewers for a 2008 Office of Inspector General (OIG) case study. 69 Over 12 weeks, the physician reviewers examined hospital medical records for each of the 420 cases. 70 Physician reviewers used a structured medical review protocol that required them to describe each adverse event; identify the medical record documentation that led to 69 OIG, Adverse Events in Hospitals: Case Study of Incidence Among Medicare Beneficiaries in Two Counties, OEI-06-08-00220, December 2008. 70 These included medical records for all hospital stays for sample beneficiaries ending with October 2008 discharges. Additionally, physicians reviewed records for any readmissions of sample beneficiaries that occurred within 30 days after their final October discharges to look for evidence of events that occurred during the October 2008-discharged stays. OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 42 ? A P P E N D I X ~ E their identification of the event; and specify the level of harm experienced by the patient, with harm categorized in accordance with the National Coordination Council for Medication Errors Reporting and Prevention Index of Categorizing Medication Errors. Throughout our study preparation, medical records review, and analysis, we facilitated 22 weekly conference calls during which the physician reviewers discussed the review protocol and sample cases that either were complex or had possible implications for other cases. These calls assisted in making determinations for difficult cases and helped achieve consistency across reviewers. The physicians determined that the following types of cases would require group discussion: events assessed as clearly preventable; events contributing to death; and cases involving respiratory failure, hypoglycemia, hypotension, urinary tract infections, and complex and/or lengthy surgeries. Physicians also often brought cases to group discussion if they involved care specific to a specialization of another physician. We documented the discussions and conclusions made during these weekly calls, continually revising a written physician guidance document to further promote consistency. The physicians discussed 162 of the 302 events (54 percent) and other cases that the group ultimately determined did not include events. Determining Preventability for Each Event As part of the structured medical review protocol, reviewers also assessed the likelihood that the events were preventable. In collaboration with the physicians, we created an initial response scale: ? Preventable--Patient harm could have been avoided through improved assessment or alternative actions. Not preventable--Patient harm could not have been avoided given the complexity of the patient's condition or the care required. Unable to determine--Physicians were unable to determine preventability because of incomplete documentation or case complexity. ? ? Through the pretest process, we expanded the scale to enable physicians to more precisely gauge the extent to which an event was preventable. The expanded scale divided the preventable and nonpreventable responses with the descriptors clearly and likely. Assessing an event as clearly preventable or clearly not preventable required a greater degree of certainty on the part of the reviewer. The expanded scale enabled OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 43 ? A P P E N D I X ~ E physicians to make more precise determinations, while our primary statistics continued to collapse clearly and likely. To make distinctions about the circumstances in each case, physicians used their clinical experience and judgment. They considered all evidence in the medical records, including staff actions and the patient's condition. Physicians also used information about accepted standards of care, the frequency with which certain events occurred despite appropriate assessment and care, the physicians' individual clinical experiences, guidance developed during the review process, and group discussion of cases. Using a list of contributing factors gleaned from prior research, physicians indicated the rationale for each determination and provided a narrative description for each case. To improve consistency, physician reviewers used a uniform method for reviewing preventability. Reviewers developed a decision algorithm during practice reviews consisting of a series of questions that led the reviewers to a suggested response. Questions addressed issues such as whether there was a medical error, whether the event could have been anticipated, and how frequently the event occurred given proper care. Physicians did not automatically accept the suggested response, but assessed whether it was appropriate for each case. In completing the rationale section of the protocol, physicians assessed contributing factors. The list of contributing factors included broad concepts from the decision algorithm, such as errors, and more nuanced factors, such as whether the patient was monitored or was susceptible to the event. We required that physicians discuss all clearly preventable determinations during group meetings (as they required greater certainty), and encouraged them to bring other cases for discussion if they had difficulty or felt the cases would inform other determinations. Figure E-1 illustrates the preventability review process. Physician Review of Findings Following the medical records review, we analyzed the identified events, harm levels, and preventability determinations to identify any inconsistencies and discussed these with the full physician group. This process resulted in some changes to the initial determinations, such as collapsing a series of events into a single cascade event. 71 71 Based on OIG interviews with IHI staff, IHI defines a cascade event as one in which an initial event causes a series of related events for the same patient and advocates collapsing these into a single event. OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 44 ? A P P E N D I X ~ E Figure E-1: Physician Review Process for Determining Preventability Part I - Decision Algorithm To Determine Suggested Response Q1: Was an identifiable error or system failure documented in the medical record? No Q2: Could the care provider have anticipated this event with the information available at the time? Yes Yes Q3: Were appropriate precautions taken to prevent this event? Unable to determine Q4: How frequently does this type of adverse event occur when proper preparation and procedures are in place? Rarely Clearly or likely preventable Clearly or likely not preventable No Yes Clearly or likely preventable Clearly or likely not preventable No Clearly or likely preventable Occasionally Clearly or likely not preventable Part II - Rationale List To Evaluate Suggested Response Consider the rationale list for the suggested response: Preventable medical error substandard treatment inadequate monitoring inadequate assessment necessary treatment not provided event rarely happens poor communication flawed safety systems breakdown in environment Not Preventable proper procedures followed patient highly susceptible could not have anticipated patient's condition complex Unable To Determine poor or absent documentation medical care complex patient's condition complex Yes Do you feel confident that the suggested response is appropriate? Make selection in protocol No Request group discussion Source: OIG illustration of physician medical record review process for determining preventability. OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 45 ? ? A P P E N D I X ~ F Estimates, Confidence Intervals, and Key Statistics We computed incidence rates and corresponding 95-percent confidence intervals using the computer program Sudaan. Sudaan is a statistical analysis program with appropriate standard statistical formulas for calculating correct standard errors for complex sampling designs. Table F-1: Estimates, Confidence Intervals, and Key Statistics Estimated Percentage of Beneficiaries 95-Percent Confidence Interval Lower Upper Bound Bound Estimated Number of Beneficiaries 95-Percent Confidence Interval Lower Upper Bound Bound n Event Experiences for All Beneficiaries (n=780) Experienced adverse events ? National Quality Forum Serious Reportable Events* ? Medicare hospital-acquired conditions* ? F-I level adverse events ? Events that overlap at least two categories* ? Events that overlap all three categories* Experienced temporary harm events Experienced only preventable adverse events Experienced only preventable temporary harm events Experienced adverse events that contributed to death* Experienced multiple adverse events Experienced temporary harm in addition to adverse events Experienced cascade events 105 5 8 102 9 1 105 58 49 12 13.46% 0.64% 1.03% 13.08% 1.15% 0.13% 13.46% 7.44% 6.28% 1.54% 11.24% 0.27% 0.51% 10.88% 0.60% 0.02% 11.24% 5.79% 4.78% 0.87% 16.05% 1.53% 2.04% 15.63% 2.20% 0.91% 16.05% 9.50% 8.22% 2.69% 133,710 6,367 10,187 129,890 11,461 1,273 133,710 73,859 62,398 15,281 111,644 2,682 5,066 108,069 5,960 199 111,644 57,511 47,479 8,642 159,421 15,197 20,263 155,249 21,852 9,039 159,421 94,361 81,647 26,719 Beneficiaries Who Experienced at Least One Adverse Event (n=105) 19 29 18.10% 27.62% 11.84% 19.91% 26.66% 36.94% 24,195 36,929 15,831 26,622 35,647 49,392 28 26.67% 19.08% 35.93% 35,656 25,512 48,042 Beneficiaries Who Experienced at Least One Temporary Harm Event (excluding those who experienced adverse events) (n=105) Experienced multiple temporary harm events 23 21.90% 15.00% 30.83% 29,289 20,057 41,223 Beneficiaries Who Experienced Events and Were Covered Under the Inpatient Prospective Payment System (IPPS) (n=171) Incurred additional costs Did not incur additional costs 28 143 16.37% 83.63% 11.54% 77.29% 22.71% 88.46% 35,656 182,101 25,129 168,304 49,453 192,628 *Given the small proportions, confidence intervals for projected numbers exceed 50-percent relative precision. Source: Office of Inspector General (OIG) analysis of hospital stays and Medicare claims for 780 Medicare beneficiaries discharged in October 2008. OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 46 ? A P P E N D I X ~ F Table F-2: Estimates, Confidence Intervals, and Key Statistics 95-Percent Confidence Interval n Percentage Estimate Lower Bound Upper Bound Preventability Classification for All Adverse Events and Temporary Harm Events (n=302) All adverse and temporary harm events ? Preventable events o Clearly preventable events o Likely preventable events 302 133 28 105 155 55 100 14 100% 44.04% 9.27% 34.77% 51.32% 18.21% 33.11% 4.64% NA 38.06% 6.53% 29.20% 45.22% 13.92% 27.59% 2.80% NA 50.19% 13.01% 40.79% 57.39% 23.47% 39.14% 7.59% ? Not preventable events o Clearly not preventable events o Likely not preventable events ? Unable to determine* Clinical Category for All Adverse Events (n=128) All clinical categories ? Medication ? Patient care ? Surgery and other procedures ? Infection 128 40 36 33 19 100% 31.25% 28.13% 25.78% 14.84% NA 23.35% 20.92% 18.77% 9.64% NA 40.41% 36.66% 34.31% 22.18% Clinical Category for All Temporary Harm Events (n=174) All clinical categories ? Medication ? Patient care ? Surgery and other procedures ? Infection 174 73 63 32 100% 41.95% 36.21% 18.39% NA 34.74% 29.09% 12.92% NA 49.53% 43.98% 25.50% 6 3.45% 1.58% 7.36% Harm Level for All National Coordinating Council Medication Errors Reporting and Prevention Index for Categorizing Errors F-I Level Events (n=122)** All NCC MERP harm levels ? Harm F ? Harm G* ? Harm H ? Harm I* 122 76 6 28 12 100% 62.30% 4.92% 22.95% 9.84% NA 53.42% 2.22% 16.15% 5.75% NA 70.41% 10.54% 31.54% 16.33% Preventable Adverse and Temporary Harm Events Within Each Clinical Category ? Infection (n=25) ? Medication (n=113) ? Patient care (n=99) ? Surgery and other procedures (n=65) 15 57 50 11 60.00% 50.44% 50.51% 16.92% 39.72% 40.98% 40.47% 9.51% 77.35% 59.87% 60.50% 28.30% continued on next page *Given the small proportions, confidence intervals for projected numbers exceed 50-percent relative precision. ** National Coordinating Council for Medication Errors Reporting and Prevention Index for Categorizing Errors (NCC MERP). OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 47 ? A P P E N D I X ~ F Table F-2: Estimates, Confidence Intervals, and Key Statistics (Continued) 95-Percent Confidence Interval n Percentage Estimate Lower Bound Upper Bound Physician Rationale for All Preventable Events (n=133) Error related to medical judgment, skill, or patient management Appropriate treatment was provided in a substandard way Patient's progress was not adequately monitored Patient's health status was not adequately assessed Necessary treatments were not provided Event rarely happens when proper precautions and procedures are followed Poor communication between caregivers* Facility's patient safety systems and policies were inadequate or flawed* Breakdown in hospital environment occurred (equipment failure, etc.)* 77 61 50 30 22 18 10 4 2 57.89% 45.86% 37.59% 22.56% 16.54% 13.53% 7.52% 3.01% 1.50% 49.04% 37.64% 29.76% 15.87% 11.10% 8.46% 3.86% 1.12% 0.38% 66.27% 54.33% 46.14% 31.02% 23.92% 20.95% 14.14% 7.81% 5.80% Physician Rationale for All Nonpreventable Events (n=155) Event occurred despite proper assessment and procedures followed Patient was highly susceptible to event because of health status Care provider could not have anticipated event given information available Patient's diagnosis was unusual or complex, making care difficult Harm was anticipated but was considered acceptable given alternatives* 96 77 54 45 21 61.94% 49.68% 34.84% 29.03% 13.55% 52.82% 41.34% 27.54% 21.67% 8.75% 70.28% 58.04% 42.92% 37.70% 20.40% *Given the small proportions, confidence intervals for projected numbers exceed 50-percent relative precision. Source: OIG analysis of hospital stays for 780 Medicare beneficiaries discharged in October 2008. Table F-3: Statistical Test Results for Preventability Subanalysis Statistical Test Test for relationship among preventability determinations and harm events (i.e., adverse event or temporary harm event) Test for relationship between preventability determinations and clinical categories (e.g., surgical event, medication event, patient care event, or infection) Test for difference between preventability determinations ? ? ? Surgical events versus infection events Surgical events versus medication events Surgical events versus patient care events P-Value for Difference in Proportions 0.0568 <0.0001* 0.0013* <0.0001* <0.0001* 0.0104* Test for difference of means between average additional costs incurred by entire stays and average additional costs attributed to events within the initial hospital stays Note: Weighted chi square and Cochran-Mantel-Haenszel chi square produced similar results. * P-values are statistically significant at the 95 precent confidence level. Source: OIG analysis of hospital stays and Medicare claims for 780 Medicare beneficiaries discharged in October 2008. OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 48 ? A P P E N D I X ~ F Table F-4: Projections and Confidence Intervals for Analysis of Medicare Costs Associated With Adverse Events and Temporary Harm Events 95-Percent Confidence Interval Projected Population Medicare Inpatient Costs for Projected Population (n=657) Estimate of Medicare inpatient costs 836,646 $9,167,576,966 $8,505,456,013 $9,829,697,918 Projected Cost Estimate Lower Bound Upper Bound Medicare Inpatient Costs for Projected Population Associated With Adverse and Temporary Harm Events (n=657) Costs associated with all events Costs associated with preventable events 836,646 836,646 $324,155,814 $118,720,272 $161,745,099 $33,915,875 $486,566,529 $203,524,670 Source: OIG analysis of hospital stays and Medicare claims for 780 Medicare beneficiaries discharged in October 2008. * Medicare costs are calculated based on the 657 sample cases in the IPPS. Table F-5: Projections and Confidence Intervals for Average Additional Medicare Costs Associated With Adverse Events and Temporary Harm Events Events Resulting in Increased Medicare Costs Events resulting in increased costs for additional hospital stays (n=12) Events resulting in increased costs for initial hospital stays (n=16) Projected Average Additional Cost $13,745 $5,601 95-Percent Confidence Interval Lower Bound $7,760 $3,889 Upper Bound $19,730 $7,313 Source: OIG analysis of hospital stays and Medicare claims for 780 Medicare beneficiaries discharged in October 2008. Table F-6: Percentage Estimates and Confidence Intervals for Medicare Costs Associated With Adverse Events and Temporary Harm Events Percentage Estimate Percentage of Total Medicare IPPS Costs All adverse and temporary harm events Preventable adverse and temporary harm events 3.54% 1.30%* 1.82% 0.38% 5.26% 2.21% 95-Percent Confidence Interval Lower Bound Upper Bound Percentage of Medicare IPPS Costs Attributed to Adverse Events and Temporary Harm Events Associated with adverse events Associated with temporary harm events Associated with entire additional hospital stays 87.48% 14.93%* 64.80% 73.70% 0.34% 43.82% 100.00% 29.52% 85.77% *Given the small proportions, confidence intervals for projected numbers exceed 50-percent relative precision Source: OIG analysis of hospital stays and Medicare claims for 780 Medicare beneficiaries discharged in October 2008. . OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 49 ? ? A P P E N D I X ~ G Rates of Adverse Events and Temporary Harm Events by Patient Days and Hospital Admissions Hospitals commonly measure adverse events by incidence density, which takes into account the period during which patients are observed. For example, incidence density is often used in measuring hospitalacquired infections because risk can increase with the length of exposure to the health care environment. 72 The Institute for Healthcare Improvement (IHI), a nonprofit advisory group to hospitals, cites advantages to using incidence density metrics over standard incidence rates that measure the number of events per patient. 73 IHI reports that measuring total events by patient days or hospital admissions enables hospitals to count multiple events experienced by the same beneficiary. The sample of 780 Medicare beneficiaries discharged during October 2008 included 838 total hospital stays (admissions) and a total of 4,354 days in the hospital (patient days). We calculated patient days by subtracting the admission date for each hospital stay from its discharge date. 74 Table G-1 provides ratios for adverse events and temporary harm events in the sample per 1,000 patient days and per 100 admissions. Table G-1: Rates of Adverse and Temporary Harm Events in the Sample by Patient Days and Hospital Admissions Category Adverse events Temporary harm events Adverse events and temporary harm events combined Per 1,000 Patient-Days 29 40 69 Per 100 Admissions 15 21 36 Source: Office of Inspector General analysis of hospital stays for 780 Medicare beneficiaries in October 2008. 72 K.M. Arias, Outbreak Investigation, Prevention, and Control in Health Care Settings, Second Edition, 2009, Jones and Bartlett Publishers, pp. 330-331. 73 IHI, IHI Global Trigger Tool for Measuring Adverse Events, Second Edition, 2009, p. 13. 74 In consultation with physician reviewers, we excluded the seven patients admitted and discharged on the same day (these patients did not experience temporary harm or adverse events). IHI recommends selecting patient records for only hospital stays of at least 24 hours. OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 50 ? ? A P P E N D A P P E N D I X I X ~ A ~ H Adverse Events and Temporary Harm Events Tables H-1 and H-2 contain information about adverse events and temporary harm events identified in the sample, including National Quality Forum (NQF) Serious Reportable Events and Medicare hospital-acquired conditions (HAC). Table H-1 contains information about adverse events (128 adverse events). 75 Table H-2 contains information about temporary harm events (174 events). The event descriptions vary somewhat depending upon the language the physician reviewers used to describe the event and the level of detail included in their notes. Table H-1: Adverse Events by Clinical Category, Harm Level, Preventability, and Whether the Events Were NQF Serious Reportable Events or Medicare HACs (n=128) Adverse Event Events Related to Medication (40) Excessive bleeding (12) 1. Abdominal bleeding secondary to anticoagulant given for deep vein thrombosis (enoxaparin) 2. Brain hemorrhage secondary to anticoagulants (aspirin and clopidogrel) 3. Cascade event in which delay in care and administration of aspirin to patient with low platelet count led to pulmonary hemorrhage 4. Cascade event in which gastrointestinal bleeding and hematoma associated with aspirin and anticoagulant (clopidogrel) given following coronary stent placement resulted in acute blood loss 5. Hematuria secondary to anticoagulant (warfarin) 6. Retroperitoneal hemorrhage secondary to anticoagulant (warfarin) 7. Gastrointestinal bleeding secondary to anticoagulant (enoxaparin) 8. Gastrointestinal bleeding secondary to anticoagulant (warfarin) 9. Gastrointestinal bleeding secondary to anticoagulants (aspirin, clopidogrel, and enoxaparin) 10. Gastrointestinal bleeding secondary to anticoagulants (aspirin, clopidogrel, and eptifibatide) 11. Gross hematuria secondary to anticoagulants (aspirin and clopidogrel) 12. Hematoma secondary to anticoagulant (heparin) Harm Level Preventability NQF HAC I F I I F I I F F F F F CNP CNP CP CNP LP CP CNP LP CNP CNP LNP LP continued on next page ? 75 The harm level is classified according to the National Coordinating Council for Medication Errors Reporting and Prevention (NCC MERP) Index for Categorizing Errors (E-I). Preventability determination is reflective of the physician review index: CP = clearly preventable, LP = likely preventable, LNP = likely not preventable, CNP = clearly not preventable, and UTD = unable to determine. OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 51 ? A P P E N D I X ~ H Table H-1: Adverse Events by Clinical Category, Harm Level, Preventability, and Whether the Events Were NQF Serious Reportable Events or Medicare HACs (n=128) (Continued) Adverse Event Events Related to Medication (continued) Delirium or change in mental status (7) 1. Cascade event in which narcotic analgesic (hydromorphone) induced delirium, which led to use of physical restraints, patient pulling out IVs, and patient fall 2. Cascade event in which narcotic analgesic (oxycodone) induced delirium and resulted in patient fall 3. Confusion secondary to narcotic analgesics (dextropropoxyphene with acetaminophen) 4. Delirium secondary to sedative (benzodiazepine) 5. Hallucinations and delirium secondary to antiwithdrawal medication (naloxone) 6. Hallucinations and delirium secondary to narcotic analgesic (hydromorphone) 7. Mental status change due to narcotic analgesic (morphine) Hypoglycemic event (6) 1. Episode of severe hypoglycemia secondary to insulin management 2. Hypoglycemic coma secondary to insulin management 3. Hypoglycemic coma secondary to insulin management 4. Hypoglycemic coma and permanent brain injury secondary to insulin management in patient with anoxic encephalopathy following cardiac arrest 5. Multiple episodes of severe hypoglycemia secondary to insulin management 6. Recurrent hypoglycemia secondary to diabetes medication (glipizide) Acute renal insufficiency (kidney failure) (4) 1. Acute renal failure secondary to antihypertensives and diuretics (unspecified) 2. Acute renal failure secondary to blood pressure medication (enalapril) 3. Acute renal failure and permanent decrease of renal function secondary to dehydration from diuretic (furosemide) 4. Severe acute renal insufficiency and dehydration secondary to diuretics (bumetanide and spironolactone) Severe hypotension (4) 1. Hypotension secondary to narcotic analgesic (hydromorphone) 2. Hypotension secondary to diuretics (unspecified) 3. Hypotension secondary to multiple psychiatric medications (mirtazapine, risperidone, and sertraline) 4. Hypotension secondary to multiple sedatives (ketamine, lorazepam, and propofol) Respiratory complication (4) 1. Acute hypercarbic respiratory failure (excess oxygen) 2. Cascade event in which narcotic analgesic (hydromorphone) led to respiratory failure and recurrent somnolence 3. Respiratory depression secondary to antianxiety medication (lorazepam) and narcotic analgesic (morphine) 4. Respiratory failure secondary to sedative (benzodiazepine) Severe allergic reaction (3) 1. Failure to diagnose Stevens-Johnson Syndrome secondary to anticonvulsants (carbamazepine and phenytoin) 2. Hives and shortness of breath due to allergic reaction to antibiotic 3. Throat swelling due to allergic reaction to blood transfusion Harm Level Preventability NQF HAC F F F F F F F H H I G H F CP CP CP CNP CNP LP CP LNP LP LP CP CP CP F F G F F F F H H H H I F F H LNP LP LP LNP LP LP LP CNP LP LP LP CP LP CNP CNP continued on next page ? OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 52 ? A P P E N D I X ~ H Table H-1: Adverse Events by Clinical Category, Harm Level, Preventability, and Whether the Events Were NQF Serious Reportable Events or Medicare HACs (n=128) (Continued) Adverse Event Events Related to Patient Care (36) Intravenous (IV) volume overload (10) 1. Cascade event in which cessation of diuretic (furosemide) and administration of excess saline led to acute pulmonary edema 2. Cascade event in which IV volume overload led to mild congestive heart failure and subsequent treatment with diuretic (furosemide) led to hypokalemia 3. Hypoxic respiratory failure secondary to IV volume overload 4. Hypoxic respiratory failure secondary to IV volume overload 5. IV volume overload with associated leg edema and complicated by preexisting pneumonia 6. Pleural effusions and intermittent dyspnea secondary to IV volume overload 7. Pulmonary edema and effusions secondary to IV volume overload 8. Pulmonary edema and respiratory distress secondary to IV volume overload 9. Respiratory failure secondary to IV volume overload 10. Respiratory insufficiency and reintubation secondary to IV volume overload Aspiration (8) 1. Aspiration associated with feeding tube placement 2. Aspiration pneumonia associated with food intake 3. Aspiration pneumonia associated with unspecified infiltrate 4. Aspiration pneumonia associated with unspecified infiltrate 5. Aspiration pneumonitis associated with unspecified infiltrate 6. Cascade event in which aspiration led to respiratory failure, acute renal failure, shock, and cardiac arrest 7. Cascade event in which recurrent aspiration led to infection 8. Cascade event in which episode of vomiting led to aspiration pneumonia in patient with congestive heart failure Venous thrombosis or pulmonary embolism (5) 1. Bilateral deep venous thrombosis 2. Bilateral pulmonary emboli 3. Deep venous thrombosis secondary to central catheter 4. Multiple pulmonary emboli (right pulmonary artery) 5. Venous thrombosis (saphenous vein) Exacerbation of preexisting medical condition (5) 1. Cascade event in which failure to diagnose hypotension and septic shock led to severe hypotension 2. Cascade event in which failure to diagnose postoperative bowel distension led to toxic megacolon, bowel perforation, abdominal sepsis, and shock 3. Progressive respiratory difficulties resulting from failure to complete congestive heart failure therapy 4. Progressive respiratory difficulties resulting from failure to diagnose hemothorax 5. Progressive respiratory difficulties resulting from failure to diagnose pulmonary infiltrate and pneumonia Stage III pressure ulcer (3) 1. Progression from single stage II pressure ulcer to bilateral stage III pressure ulcers (buttocks) 2. Progression from stage I pressure ulcer to stage III pressure ulcer (heel) 3. Stage III pressure ulcer (sacrum) Harm Level Preventability NQF HAC H F H H F F F H H F F I F F F I F F F F F F F H H F F F LP LNP LNP LP LNP LNP CNP LP LP LNP LP UTD LP LNP LP UTD LP LNP LP LP UTD LP LNP CP UTD LP LP CP E E E LP LP LP ? ? ? ? continued on next page OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 53 ? A P P E N D I X ~ H Table H-1: Adverse Events by Clinical Category, Harm Level, Preventability, and Whether the Events Were NQF Serious Reportable Events or Medicare HACs (n=128) (Continued) Adverse Event Events Related to Patient Care (continued) Other events related to patient care (5) 1. Breakdown of surgical wound 2. Congestive heart failure resulting from failure to manage high blood pressure 3. Hypoxia resulting from failure to stabilize tracheostomy and provide oxygen during transfer 4. Severe back pain and possible vertebral compression fracture from patient fall 5. Significant episode of weakness and dizziness associated with an exacerbation of hyponatremia Events Related to Surgery or Other Procedures (33) Excessive bleeding (5) 1. Bleeding for several days following colonoscopy 2. Bleeding from femoral artery following IV placement 3. Cascade event in which hemorrhage of femoral artery at puncture site led to shock, apnea, and ultimately a myocardial infarction 4. Cascade event in which premature removal of dialysis needle resulted in excessive bleeding, shock, intubation, and aspiration 5. Hematoma following knee arthroplasty Severe hypotension (4) 1. Hypotension during hemodialysis treatment 2. Hypotension following cardiac surgery 3. Hypotension following endoscopic procedure 4. Hypotension with atrial fibrillation and rapid ventricular response following dialysis treatment Respiratory complication (4) 1. Agonal breathing following premature extubation 2. Cascade event in which acute respiratory failure following cardiac procedure led to hematuria and hemoptysis 3. Cascade event in which angioedema secondary to contrast used for fistulogram led to intubation, ventilator-associated pneumonia, and shock 4. Respiratory distress following percutaneous tracheostomy Iatrogenic pneumothorax (3) 1. Cascade event in which postoperative pneumothorax led to acute respiratory failure 2. Cascade event in which removal of chest tube led to pneumothorax, reinsertion of chest tube, and reintubation 3. Pneumothorax following chest tube placement Postoperative ileus (3) 1. Cascade event in which outpatient surgery to repair hernia following cholecystectomy led to hospitalization for postoperative hypoxemia, atelectasis, and ileus 2. Significant ileus following partial colon resection 3. Significant ileus following partial colon resection F F H H F F F H F H F I H H H F LNP LNP LP CP LP LNP LNP CNP LP CP LNP CNP CNP LNP LNP CNP F F H F F UTD LNP CP CNP LP ? Harm Level Preventability NQF HAC F F F LNP CNP LNP continued on next page OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 54 ? A P P E N D I X ~ H Table H-1: Adverse Events by Clinical Category, Harm Level, Preventability, and Whether the Events Were NQF Serious Reportable Events or Medicare HACs (n=128) (Continued) Adverse Event Events Related to Surgery or Other Procedures (continued) Postoperative urinary retention (3) 1. Postoperative urinary retention associated with indwelling urinary catheter 2. Postoperative urinary retention associated with indwelling urinary catheter 3. Postoperative urinary retention associated with urinary catheter Acute coronary syndrome (2) 1. Acute coronary syndrome following laparoscopic cholecystectomy and resulting in permanent damage to heart muscle 2. Acute coronary syndrome that developed as a complication of percutaneous coronary intervention Blood clots and other occlusions (blockage within a blood vessel) (2) 1. Acute occlusion of the popliteal artery following colonoscopy and partial colon resection 2. Pericardial blood clot following cardiac surgery Cardiac complication (2) 1. Atrial fibrillation following mitral valve replacement surgery 2. Severe ventricular tachycardia following coronary artery bypass graft Other procedure-related complication (5) 1. Cascade event in which coronary bypass surgery led to complex tachycardia complicated by hypotension 2. Cascade event in which complications following bowel surgery resulted in surgical site hemorrhage 3. Delay in surgery because of equipment malfunction 4. Hematuria due to indwelling urinary catheter-associated trauma 5. Seroma (pocket of fluid) following stomach resection Events Related to Infection (19) Urinary tract infection (5) 1. Cascade event in which cystoscopy eroded artificial urethral sphincter necessitating use of urinary catheter which led to urinary tract infection (E. coli) 2. Urinary tract infection (E. coli) associated with urinary catheter 3. Urinary tract infection (E. coli) associated with urinary catheter 4. Urinary tract infection (Klebsiella) associated with urinary catheter 5. Urinary tract infection (Serratia) associated with urinary catheter Vascular catheter-associated infection (central or peripheral line) (4) 1. Cascade event in which vascular catheter led to sepsis, deep vein thrombosis, and pulmonary embolism 2. Cascade event in which vascular catheter led to septicemia and deep vein thrombosis 3. Forearm cellulitis (inflammation of skin or connective tissue) following vascular catheter insertion 4. Methicillin-resistant Staphylococcus aureus (MRSA) infection following pleural catheter insertion Harm Level Preventability NQF HAC F F F G F LNP LP LNP CNP CNP G F H H CNP LNP CNP CNP H F F F F LNP LNP LP LNP LNP G F E E E F F F H LP LP LP LP LP LP LP CP LP ? ? ? ? ? ? ? continued on next page OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 55 ? A P P E N D I X ~ H Table H-1: Adverse Events by Clinical Category, Harm Level, Preventability, and Whether the Events Were NQF Serious Reportable Events or Medicare HACs (n=128) (Continued) Adverse Event Events Related to Infection (continued) Other bloodstream infections (excluding vascular catheter-associated Infections) (4) 1. Cascade event in which failure to treat systemic inflammatory response syndrome led to acute renal failure and aspiration pneumonia 2. Cascade event in which removal of urinary catheter led to recurrence of obstructive uropathy, renal failure, sepsis, and permanent deterioration of renal function 3. Cascade event in which untreated febrile neutropenia led to septic shock 4. Sepsis (methicillin-resistant Staphylococcus epidermis) Respiratory infection (4) 1. Pneumonia (MRSA) following abdominal surgery 2. Pneumonia (unspecified) following knee surgery 3. Ventilator-associated pneumonia (Klebsiella) 4. Ventilator-associated pneumonia (MRSA) Surgical or procedural site infection (2) 1. Cascade event in which anastomotic leak following colectomy led to abscesses and bacteremia 2. Surgical site infection following foot surgery Harm Level Preventability NQF HAC I CP G I F F F F H F F CP CP LNP LNP LNP LNP LNP LP LNP Source: Office of Inspector General (OIG) analysis of hospital stays for 780 Medicare beneficiaries in October 2008. OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 56 ? A P P E N D I X ~ H Table H-2: Temporary Harm Events, E Level on the NCC MERP Index, Identified Among Medicare Beneficiaries by Clinical Category (n=174 ) Temporary Harm Event Events Related to Medication (73) Delirium or change in mental status (22) 1. Altered mental status secondary to narcotic analgesic (fentanyl) and sedative (midazolam) 2. Cascade event in which delirium secondary to antipsychotic (haloperidol) led to patient pulling catheter out which resulted in hematuria 3. Confusion and delirium secondary to narcotic analgesics (hydromorphone and morphine) 4. Confusion secondary to narcotic analgesic (hydromorphone) 5. Confusion secondary to sedative (benzodiazepine) 6. Delirium secondary to anticonvulsants (valproic acid) 7. Delirium secondary to local anesthetic (lidocaine) 8. Delirium secondary to narcotic analgesic (hydromorphone) 9. Delirium secondary to narcotic analgesic (hydrocodone with acetaminophen) 10. Delirium secondary to narcotic analgesic (morphine) 11. Drowsiness secondary to narcotic analgesic (hydromorphone) 12. Hallucinations and delirium secondary to narcotic analgesic (morphine) 13. Hallucinations secondary to sedative (alprazolam) and multiple narcotic analgesics 14. Lethargy secondary to narcotic analgesic (hydromorphone) 15. Lethargy secondary to narcotic analgesic (oxycodone with acetaminophen) 16. Omission of antidepressant (fluoxetine with olanzapine) that led to episode of acute paranoia 17. Oversedation secondary to antihistamine and sedative (promethazine) 18. Oversedation secondary to multiple psychiatric medications (alprazolam, haloperidol, and quetiapine) 19. Oversedation secondary to narcotic analgesic (fentanyl) and sedative (midazolam) 20. Oversedation secondary to narcotic analgesic (hydromorphone) 21. Paranoid delusions secondary to narcotic analgesics (hydromorphone and morphine) 22. Somnolence secondary to narcotic analgesics (hydromorphone and morphine) Hypoglycemic event (11) 1. Hypoglycemia secondary to diabetes medication (glipizide) 2. Hypoglycemia secondary to glycemic management 3. Hypoglycemia secondary to glycemic management 4. Hypoglycemia secondary to glycemic management 5. Hypoglycemia secondary to glycemic management 6. Hypoglycemia secondary to glycemic management 7. Hypoglycemia secondary to glycemic management 8. Hypoglycemia secondary to glycemic management 9. Hypoglycemia secondary to glycemic management 10. Hypoglycemia secondary to glycemic management 11. Volatile blood glucose secondary to insulin management Thrush and other opportunistic infection (7) 1. Fungal infection (cutaneous rash) secondary to antibiotics (unspecified) 2. Thrush (Candidiasis) secondary to broad spectrum antibiotics (unspecified) 3. Thrush (oropharyngeal Candida) secondary to antibiotics (piperacillin and tazobactam) 4. Thrush (unspecified) secondary to antibiotics (unspecified) 5. Thrush (unspecified) secondary to antibiotics and steroids (unspecified) 6. Thrush (unspecified) secondary to antibiotics and steroids (unspecified) 7. Thrush (unspecified) secondary to steroids (unspecified) Preventability LP LP LP LP LP CNP CNP LP LP CNP LNP LNP UTD LP LP LP LP LNP LNP LP LP CP UTD CP LNP LNP LNP LP LP LP LP LP LNP CNP CNP CNP LNP CNP CNP CNP continued on next page OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 57 ? A P P E N D I X ~ H Table H-2: Temporary Harm Events, E Level on the NCC MERP Index, Identified Among Medicare Beneficiaries by Clinical Category (n=174) (Continued) Temporary Harm Event Events Related to Medication (continued) Allergic reaction or side effect related to skin (6) 1. Generalized pruritic (itching) rash secondary to narcotic analgesic (morphine) 2. Hives and facial swelling due to contrast used during cardiac catheterization 3. Hives and significant itching secondary to narcotic analgesic (hydromorphone) 4. Hives secondary to allergic reaction to antibiotics (moxifloxacin) 5. Itching and erythema (redness) secondary to narcotic analgesic (hydromorphone) 6. Itching secondary to antibiotics (clindamycin and cephalosporin) Gastrointestinal complication (5) 1. Allergic reaction (nausea and vomiting) to narcotic analgesics (hydromorphone) 2. Diarrhea secondary to antibiotic (amoxicillin and clavulanate) 3. Nausea and vomiting secondary to hypertension therapy (nitroprusside) 4. Nausea and vomiting secondary to narcotic analgesic (morphine) 5. Severe diarrhea secondary to laxatives Hypotension (5) 1. Cascade event in which diuretic (furosemide) led to sinus tachycardia, renal insufficiency, and hypotension 2. Hypotension and dizziness secondary to antihypertensive medication (unspecified) 3. Hypotension following administration of blood pressure medication (metoprolol) 4. Hypotension secondary to multiple antihypertensives (unspecified) 5. Low blood pressure secondary to aggressive diuresis (enalapril and furosemide) Dysrhythmia (3) 1. Dysrhythmia secondary to beta-blocker (labetalol) 2. Dysrhythmia secondary to cardiac medication (digoxin) 3. Palpitations and nausea secondary to bronchodilators (albuterol) Excessive bleeding (3) 1. Epistaxis (nasal bleed) secondary to anticoagulant (enoxaparin) 2. Gross hematuria secondary to anticoagulant (heparin) 3. Hematuria secondary to anticoagulant (enoxaparin) Severe headache or dizziness (3) 1. Extended period of dizziness secondary to opioid withdrawal medication (buprenorphine) 2. Headache secondary to cardiac medication (nitroglycerine) 3. Nausea and headache secondary to cardiac medication (nitroglycerine) Acute renal failure or insufficiency (2) 1. Acute renal failure secondary to radiopaque contrast 2. Acute renal insufficiency secondary to multiple nephrotoxic agents, including kanamycin and ketorolac Allergic reaction to blood or related products (2) 1. Allergic reaction to blood transfusion 2. Hives during infusion of fresh frozen plasma Respiratory complication (2) 1. Hypoxia secondary to narcotic analgesic (meperidine) 2. Respiratory acidosis secondary to narcotic analgesic (hydrocodone with acetaminophen) and sedative (alprazolam) Other events related to medication (2) 1. Fever secondary to antiulcer medication used to treat uterine atony (misoprostol) 2. Urinary retention secondary to narcotic analgesic (opioid) CNP LNP CNP CNP CNP CNP CP UTD LNP LNP LP LP LP CP LP LNP LNP LP CNP CNP CNP LNP LP LP CNP LNP CP CNP CNP LP CP CNP LNP continued on next page Preventability OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 58 ? A P P E N D I X ~ H Table H-2: Temporary Harm Events, E Level on the NCC MERP Index, Identified Among Medicare Beneficiaries by Clinical Category (n=174 ) (Continued) ( Temporary Harm Event Events Related to Patient Care (63) Stage I, Stage II, or unstaged pressure ulcer (20) 1. Bilateral stage I pressure ulcer (buttocks) 2. Deep tissue injury (buttock) 3. Progression from stage I pressure ulcer to stage II pressure ulcer (coccyx) 4. Progression from stage I pressure ulcer to stage II pressure ulcer (coccyx) 5. Progression from stage I pressure ulcer to stage II pressure ulcer (coccyx) 6. Stage I pressure ulcer (coccyx) 7. Stage I pressure ulcer (coccyx) 8. Stage I pressure ulcer (heel) 9. Stage I pressure ulcer (sacrum) 10. Stage I pressure ulcer (sacrum and buttocks) 11. Stage I pressure ulcer (unspecified location) 12. Stage I pressure ulcer secondary to restraints (sacrum and buttock) 13. Stage II pressure ulcer (buttock) 14. Stage II pressure ulcer (buttock) 15. Stage II pressure ulcer (buttock) 16. Stage II pressure ulcer (heel and ankle) 17. Stage II pressure ulcer (sacrum) 18. Stage II pressure ulcer (sacrum) and stage I pressure ulcer (heel) 19. Stage II pressure ulcer (unspecified location) 20. Unstaged pressure ulcer (sacrum) IV volume overload (15) 1. Anasarca secondary to IV fluid resuscitation 2. Bilateral pulmonary effusion and pulmonary edema secondary to IV volume overload 3. Cascade event in which excessive IV fluids administered after a procedure led to volume overload and hyponatremia 4. Cascade event in which IV volume overload during a procedure led to acute respiratory distress 5. Cascade event in which the delay of a procedure led to the transfusion of additional blood products and resulted in dyspnea 6. Dyspnea and pulmonary congestion secondary to IV volume overload 7. Dyspnea and pulmonary edema secondary to IV volume overload of contrast agent 8. Dyspnea and pulmonary edema secondary to IV volume overload 9. Dyspnea secondary to fluid overload of contrast agent used during arteriogram 10. Dyspnea secondary to IV volume overload of fluids to correct bowel obstruction 11. Postoperative congestive heart failure secondary to IV volume overload 12. Pulmonary edema secondary to IV volume overload 13. Pulmonary edema secondary to postoperative IV volume overload 14. Vascular congestion secondary to fluid resuscitation 15. Vascular congestion secondary to IV volume overload of fresh frozen plasma Skin tear, laceration, abrasion, or other breakdown (9) 1. Blisters from telemetry leads (chest) 2. Laceration during transfer to CT table (ankle) 3. Skin abrasion from tape removal (IV site) 4. Skin breakdown with inflammation and drainage (upper arm) 5. Skin breakdown with tear (sacrum) 6. Skin tear (elbow) 7. Skin tear (wrist) 8. Skin tear from prosthesis (heel) 9. Skin tears from patient turning (elbow and hand) LP LNP CNP LNP LNP LNP LNP LP LP LP LP LP LP LP UTD LP CNP LNP LP LNP LNP LP LP LP UTD LNP LP LP LNP LP LNP LP LNP LNP LP CP CP CNP LNP LP LNP LNP LNP LNP continued on next page Preventability OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 59 ? A P P E N D I X ~ H Table H-2: Temporary Harm Events, E Level on the NCC MERP Index, Identified Among Medicare Beneficiaries by Clinical Category (n=174) (Continued) Temporary Harm Event Events Related to Patient Care (continued) IV infiltrate with symptoms (6) 1. Cellulitis secondary to IV infiltrate 2. IV infiltrate with pain and inflammation 3. IV infiltrate with pain and inflammation 4. IV infiltrate with pain, inflammation, and edema 5. Superficial phlebitis secondary to IV infiltrate 6. Thrombophlebitis secondary to IV infiltrate Patient fall with injury (5) 1. Arm and shoulder injury resulting from patient fall 2. Chest injury resulting from patient fall 3. Shoulder contusion and delay in surgery resulting from patient fall 4. Skin tear/abrasion on knees resulting from patient fall 5. Status epilepticus resulting from patient fall with head trauma Aspiration (3) 1. Aspiration associated with endotracheal tube leak 2. Aspiration associated with procedure-related infiltrate 3. Aspiration pneumonitis associated with patient's secretions Failure to treat constipation or obstipation (3) 1. Exacerbation of constipation (impaction) secondary to narcotic analgesic (hydromorphone) due to failure to provide sufficient treatment 2. Exacerbation of constipation secondary to increase in narcotic analgesics (unspecified) due to failure to provide sufficient treatment 3. Extended period of constipation due to failure to provide sufficient treatment Tachycardia or dysrhythmia (2) 1. Nonsustained ventricular tachycardic dysrhythmia 2. Paroxysmal supraventricular tachycardia Events Related to Surgery or Other Procedures (32) Urinary retention (8) 1. Postoperative urinary retention associated with indwelling catheter 2. Postoperative urinary retention associated with indwelling catheter 3. Postoperative urinary retention associated with indwelling catheter 4. Postoperative urinary retention associated with straight catheter 5. Postoperative urinary retention associated with straight catheter 6. Postoperative urinary retention following back surgery 7. Postoperative urinary retention following hip surgery 8. Postoperative urinary retention following hip surgery Excessive bleeding (6) 1. Anemia following hip surgery 2. Bleeding from femoral catheter site 3. Bleeding from femoral catheter site following dialysis 4. Hematoma and bleeding from IV site 5. Hematoma and drop in hemoglobin following hip surgery 6. Hematoma secondary to IV extravasation Cardiac complication (4) 1. Atrial fibrillation and palpitations following thoracotomy 2. Atrial fibrillation following cystoscopy 3. Minor myocardial infarction following neck surgery 4. Paroxysmal supraventricular tachycardia following surgery CNP LP LP LNP CNP LNP LNP LNP LNP LNP LNP LP LNP LNP CNP LNP CNP LNP continued on next page Preventability LNP LNP LNP LNP LP UTD LP LNP LNP CP LP LNP LP CNP LP LP LP LP UTD OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 60 ? A P P E N D I X ~ H Table H-2: Temporary Harm Events, E Level on the NCC MERP Index, Identified Among Medicare Beneficiaries by Clinical Category (n=174) (Continued) Temporary Harm Event Events Related to Surgery or Other Procedures (continued) Surgical tear or laceration (3) 1. Dural tear during discectomy and spinal decompression 2. Dural tear during laminectomy 3. Unintentional enterotomy during surgery to relieve bowel obstruction Urinary catheter-related trauma (3) 1. Hematuria associated with indwelling urinary catheter 2. Postoperative hematuria associated with indwelling urinary catheter 3. Postoperative hematuria associated with indwelling urinary catheter Prolonged nausea and vomiting (2) 1. Prolonged nausea and vomiting following spinal surgery 2. Prolonged nausea and vomiting secondary to anesthetic given for dilation and curettage Postoperative or postprocedural hypotension (2) 1. Hypotension following cardiac procedure 2. Hypotension following nephrectomy Respiratory complication (2) 1. Dyspnea following nephrectomy 2. Hypoxemia following shoulder arthroplasty Other events related to surgery or other procedures (2) 1. Gout following pacemaker placement procedure 2. Ileus following hip arthroplasty Events Related to Infection (6) Surgical site infection (2) 1. Surgical site infection following colostomy procedure 2. Surgical site infection following hip surgery Bacterial infection (1) 1. Bacterial parotiditis (glandular) infection Respiratory infection (1) 1. Postoperative pneumonia Urinary tract infection (1) 1. Urinary tract infection related to urostomy Vascular catheter-associated infection (1) 1. Infectious phlebitis at catheter insertion site Source: OIG analysis of hospital stays for 780 Medicare beneficiaries in October 2008. Preventability LNP LNP LNP LNP CNP LNP LNP CNP LP LNP UTD UTD CNP LNP LNP LP LNP LNP LNP LP OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 61 A P PEN 0 x Agency Comments: Agency for Healthcare Research and Quality DEPARTMENT OF HEALTH AND HUMAN SERVICES Agency for Healthcar. Research and Quality 540 Gaither Road Rockville, MD 20850 www.ahrq.gov SEP 2 2 2010 TO: Daniel R, Levinson Inspector General Carolyn M. Clancy, MD Director FROM: /S/ SUBJECT: AHRQ Response to OIG draft report, Adverse Events in Hospitals: National Incidence Among Medicare Beneficiaries, OEI-06-09-00090. Thank you for the opportunity to review your draft report, Adverse Events in Hospitals: National Incidence Among Medicare Beneficiaries, OEI-06-09-00090 . .The findings in the report are consistent with previous studies but are nonetheless disturbing. They confirm that adverse events continue to affect hospital inpatients at an alarming rate, and that the types of events that occur vary widely, The report reaffirms AHRQ's need to continue work on improving patient safety by broadening investigation to include areas that are not always seen on lists of adverse events that should never occur or should always be reported. Responses are provided below to the report's two general recommendations that pertain to AHRQ and were provided in the July 20, 2010, draft version of the report that the Agency reviewed. AHRQ concurs with both OIG recommendations. . Recommendation: AHRQ and CMS should broaden patient safety efforts to include all types of adverse events. AHRQ Response: CONCUR AHRQ agrees that efforts to improve patient safety should be broad. While we have sponsored efforts to address specific types of adverse events, such as central-line-associated bloodstream infections and venous thromboembolisms, we have also supported efforts to address underlying causes that contribute to a wide variety of adverse events. For example, we have focused on improving the safety culture in healthcare by providing a widely-adopted patient safety culture survey that is used by hospitals and healthcare systems, and by providing team training to healthcare systems via the TeamSTEPPS program that we developed in concert with the Department of Defense. We have also provided broad in-person training on the topic of patient safety improvement to public sector and private sector representatives from every state via the Patient Safety Improvement Corps, which we implemented in concert with the Department of Veterans Affairs' National Center for Patient Safety. As we continue to lead and support Federal efforts in patient safety improvement, we intend to broaden efforts to improve patient safety overall (as with TeamSTEPPS), and to address specific problems, such as a targeted program to foster the widespread implementation of the CDC's guideline to prevent catheter-associated urinary tract infections. 1 OEI?06?09?00090 ADVERSE EVENTS IN HOSPITALS: NATIONAL INCIDENCE AMONG MEDICARE BENEFICIARIES 62 ? A P P E N D I X ~ I OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 63 APPEND X Agency Comments: Centers for Medicare & Medicaid Services (-I.. /$.U.Vlcq.~ ,,~~~ ....... (; DEPARTMENT OF HEALTH & HUMAN SERVICES Center. for Medicare & Medicaid Servicas Administrator Washington, DC 20201 DATE: SEP 0 92010 Daniel R. Levinson Inspector General ,..." TO: '= ~";) FROM: /S/ Cl' ""'11' .. -u W ", C/) ') '1 ) '~1 ",. :1':" n:. Thank. you for the opportunity to review and comment on the subject OIG Draft Report, "Adverse Events in Hospitals: National Incidence Among Medicare Beneficiaries, OEI-06-09- 00090." We appreciate the OIG's work on this important and timely topic. When one in eight hospitalized Medicare beneficiaries experience an adverse event, most of which result in a prolonged hospital stay, permanent harm, life-saving interventions, or death, solutions need to be addressed as quickly and efficiently as possible. The Centers for Medicare & Medicaid Services (CMS) has taken significant steps to address these issues, but more work needs to be done. The report's findings provide new information to the Department of Health and Human Services (HHS) broadly, and the Centers for Medicare & Medicaid Services (CMS) specifically, upon which to act to expand efforts to work with hospitals and clinicians to prevent adverse events. CMS seeks to promote a culture of safety across the country in all health care settings. While the report characterizes CMS as an oversight entity and the nation's largest health payer, CMS is also actively transitioning from serving solely as a regulator and passive payer of health care services to an agency that fully supports public health goals as an active payer of high quality and efficient care. CMS is also an engine for innovation across health care. Several new legislative and regulatory enarts, including the new Center for Medicare & Medicaid Il1novation, provide us with new and innovative tools to address the concerns raised in this report. In addition, we plan to continue several efforts already in progress to reduce adverse events. While this response focuses on adverse events in hospitalized patients, our efforts are also directed at addressing issues in dialysis centers and ambulatory and long term care settings, recognizing that in our dynamic and complex healthcare system a patient should expect and receive safe care, wherever that care may be provided. While we have a number of efforts already underway (as discussed throughout this response), we are launching a number of new efforts to infuse a cross-cutting theme of safety throughout the agency to promote a coordinated effort among existing and emerging programs. These are all designed to create incentives for and support to hospitals to identify adverse events, practices to OEI-06?09-00090 ADVERSE EVENTS IN HOSPITALS: NATIONAL INCIDENCE AMONG MEDICARE BENEFICIARIES 64 ? A P P E N D I X ~ I OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 65 ? A P P E N D I X ~ I OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 66 ? A P P E N D I X ~ I OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 67 ? A P P E N D I X ~ I OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 68 ? A P P E N D I X ~ I OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 69 ? A P P E N D I X ~ I OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 70 ? A P P E N D I X ~ I OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 71 ? A P P E N D I X ~ I OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 72 ? A P P E N D I X ~ I OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 73 ? ? A C K N O W L E D G M E N T S This report was prepared under the direction of Kevin K. Golladay, Regional Inspector General for Evaluation and Inspections in the Dallas regional office, and A. Blaine Collins, Deputy Regional Inspector General. Amy Ashcraft and Ruth Ann Dorrill served as the team leaders for this study. Other principal Office of Evaluation and Inspections staff from the Dallas regional office who contributed to the report include Deborah Cosimo, Nathan Dong, Ben Gaddis, Jennifer Gist, Anthony Guerrero-Soto, Deborah McGurk, and Jeremy Moore; central office staff who contributed include Rob Gibbons, Sandy Khoury, Sue Nonemaker, Arianne Spaccarelli, and Rita Wurm. OEI-06-09-00090 ADVERSE EVENTS IN H O S P I TA L S : N AT I O N A L I N C I D E N C E A M O N G M E D I C A R E B E N E F I C I A R I E S 74 Office of Inspector General http://oig.hhs.gov The mission of the Office of Inspector General (OIG), as mandated by Public Law 95-452, as amended, is to protect the integrity of the Department of Health and Human Services (HHS) programs, as well as the health and welfare of beneficiaries served by those programs. This statutory mission is carried out through a nationwide network of audits, investigations, and inspections conducted by the following operating components: Office of Audit Services The Office of Audit Services (OAS) provides auditing services for HHS, either by conducting audits with its own audit resources or by overseeing audit work done by others. Audits examine the performance of HHS programs and/or its grantees and contractors in carrying out their respective responsibilities and are intended to provide independent assessments of HHS programs and operations. These assessments help reduce waste, abuse, and mismanagement and promote economy and efficiency throughout HHS. Office of Evaluation and Inspections The Office of Evaluation and Inspections (OEI) conducts national evaluations to provide HHS, Congress, and the public with timely, useful, and reliable information on significant issues. These evaluations focus on preventing fraud, waste, or abuse and promoting economy, efficiency, and effectiveness of departmental programs. To promote impact, OEI reports also present practical recommendations for improving program operations. Office of Investigations The Office of Investigations (OI) conducts criminal, civil, and administrative investigations of fraud and misconduct related to HHS programs, operations, and beneficiaries. With investigators working in all 50 States and the District of Columbia, OI utilizes its resources by actively coordinating with the Department of Justice and other Federal, State, and local law enforcement authorities. The investigative efforts of OI often lead to criminal convictions, administrative sanctions, and/or civil monetary penalties. Office of Counsel to the Inspector General The Office of Counsel to the Inspector General (OCIG) provides general legal services to OIG, rendering advice and opinions on HHS programs and operations and providing all legal support for OIG's internal operations. OCIG represents OIG in all civil and administrative fraud and abuse cases involving HHS programs, including False Claims Act, program exclusion, and civil monetary penalty cases. In connection with these cases, OCIG also negotiates and monitors corporate integrity agreements. OCIG renders advisory opinions, issues compliance program guidance, publishes fraud alerts, and provides other guidance to the health care industry concerning the anti-kickback statute and other OIG enforcement authorities.