Comment on Proposed Sentinel Event Reporting Rules October 2009 2

Maine Hospital Association October 20, 2009 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 preliminary 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. Overall As the National Quality Forum’s endorsement is the applicable national standard of care, we appreciate that the Division has proposed adopting many of the standards and definitions from the National Quality Forum’s Serious Reportable Events in Healthcare 2006 Update. Consistency of language and application is critical to quality improvement efforts and learning from the national data provided by other organizations, such as the newly emerging Patient Safety Organizations. To assure complete consistency, we recommend incorporating the entire National Quality Forum’s publication by reference, as may be updated from time to time. This approach would replace the relevant portions of the proposed rule, and allow all relevant definitions, additional specifications and implementation guidance to apply to Maine’s reporting system ...