Comment on Proposed Sentinel Event Reporting Rules January 2010 2

Maine Hospital Association January 28, 2010 Anne Flanagan, Assistant Director Maine Department of Health and Human Services Division of Licensing and Regulatory Services 11 State House Station 41 Anthony Avenue Augusta, Maine 04333-0011 Dear Anne: On behalf of our entire membership, the Maine Hospital Association (MHA) appreciates the opportunity to provide these comments on the proposed sentinel event reporting rules. The MHA is an Augusta-based non-profit membership organization representing all 39 community hospitals in our state. Our comments are presented by section for easy reference. Section 1.4 We recommend that the definition of “discovery” in Section 1.4 be amended as follows: Discovered. For the purposes of these rules, “discovered” means the point at which one becomes aware of an occurrence sentinel event that triggers an action under these rules. These clarifications are necessary because: • “Sentinel event” is a defined term, but an “occurrence” is not; and • The mandatory actions under these rules are triggered by the detection of a sentinel event. Section 1.13 We appreciate the Division’s use of federal and/or nationally accepted definitions of terms whenever appropriate for consistency and availability of additional guidance. Accordingly, just as Section 1.3’s definition of “disability” references the Americans with Disabilities Act (ADA), we recommend amending the definition of “major life activities” ...