Discussion Paper on Adverse
Event and Error Reporting in Healthcare
January 24, 2000
I. Introduction
The recently released Institute of Medicine (IOM) report,
"To Err is Human: Building a Safer Health System," outlines
broad recommendations to improve patient safety and reduce
medical error. The recommendations are designed for implementation
at the public policy level to encourage organizations and
practitioners to enhance patient safety at the care delivery
level.
Although no single recommendation or activity offers a full
solution to medical error, error prevention experts agree
that successful error reduction strategies depend heavily
on responsible detection and open reporting of errors. To
that end, two of the nine recommendations call for the establishment
and/or expansion of external mandatory and voluntary reporting
programs.
According to the IOM report, reporting programs, whether
voluntary or mandatory, must satisfy two primary purposes:
- To hold providers accountable for performance and patient
safety; and
- To provide information that leads to new knowledge and
improved patient safety.
II. Mandatory and Voluntary Reporting Systems
Both voluntary and mandatory reporting systems are operating
currently throughout the nation with varying levels of success.
A brief look at the success of these programs in meeting the
IOM goals listed above may provide guidance in designing a
reporting system model.
Mandatory Reporting Systems
Experience shows that current mandatory reporting programs
have not been as successful as perhaps originally envisioned.
While mandatory reporting systems have the potential to produce
useful data, compliance with reporting requirements has been
inconsistent, as evidenced by significant variation in the
volume of reports and amount of useful information received
by most mandatory systems. Such underreporting, despite any
mandate, is understandable when you consider that disclosure
has typically exposed organizations and individual practitioners
to financial penalties, punitive actions concerning professional
and organizational licenses, and legal and public scrutiny.
Any reporting program that has at its core the punishment
of healthcare practitioners and organizations is bound to
fail in terms of gaining new knowledge about errors, as well
as holding providers accountable for patient safety. While
punishment may be warranted in rare instances for illegal
or malicious behavior, mandatory reporting in today's health
systems typically results in punitive measures against health
care professionals and organizations involved in medical error,
whether punishment is warranted or not. Therefore, mandatory
reporting, with its attendant threat of punishment, has had
the undeniable effect of suppressing error reporting and inhibiting
open discussion about errors and their system-based causes.
In truth, all reporting systems are fundamentally voluntary,
and even mandated reporting may be avoided (Billings C. Presentation
to Subcommittee on Creating an External Environment for Quality
Healthcare. Jan 29, 1999) to escape the threat of punishment.
In essence, many of the mandatory systems are perceived as
less than credible because they tend to assign blame rather
than identify and correct the system-based causes of errors.
Blame typically underpins accountability systems and may be
a powerful disincentive to reckless behavior. However, blame
also discourages reporting and is a powerful barrier to collaborative
problem solving. The inclination to blame individuals is rooted
in hindsight bias - a tendency to see a problem as much simpler
once you are in possession of the full facts and outcomes.
Hindsight bias renders it difficult for you to understand
that the situation faced by an individual at the time of the
event is very different than perceived after the event. The
events typically reported to mandatory systems have resulted
in serious harm, and outcome-based event analysis is especially
prone to hindsight bias.
Equally important, reports received through mandatory systems
often do not include information that is crucial and necessary
for the identification of system-based causes of error and
the selection of error reduction strategies that can offer
the greatest chance for success. Any reporting program that
is not built fundamentally on the reports of front-line practitioners
is likely to be a waste of valuable resources. Currently,
reports to existing mandatory systems typically originate
from a designated person within a healthcare organization
who is not necessarily one of the front-line practitioners
most familiar with the error. Further, the information usually
contains a description of "what" happened, not "why" it happened.
Additionally, the person designated to report an adverse event
to a mandatory system is often under considerable pressure
to minimize the organization's exposure to liability and public
distrust. Therefore, it is not uncommon for pertinent information,
which is crucial for effective analysis, to be overlooked,
unavailable, or simply excluded.
Such second-hand reporting is not nearly as valuable as front-line
practitioner reporting to the experts who must analyze errors
and suggest solutions. As a result, the IOM report notes that
current mandatory reporting programs have been less successful
in synthesizing and analyzing information contained in the
reports and recommending broad system improvements to enhance
patient safety. Moreover, personnel with current mandatory
systems may not have sufficient expertise to understand the
system-based causes of errors and the most effective means
to error-proof systems. In such situations, the human tragedy
of medical error is compounded because much of the important
information contained in each error that could lead to successful
system-based error reduction strategies may well have been
overlooked.
In the end, perhaps it is not the "mandatory reporting" component
that has made many such systems unsuccessful in gaining the
public's confidence, learning about the causes of error, and
enhancing patient safety. Instead, the root of the problem
more likely lies in the design of the reporting systems, the
punitive culture in which they function, and the ineffective
use of data submitted to the program.
Voluntary Reporting Systems
Conversely, the success level with existing voluntary reporting
systems has generally been much better than that experienced
by mandatory systems. Success stems not from a vast number
of reports, but from:
- The wealth of information contained within a representative
sampling of errors reported to voluntary programs;
- The recognition that error reduction efforts should not
wait until a numerical threshold has been exceeded; and
- Its focus on enhancing systems to improve practitioner
performance.
Reports to voluntary systems typically come from front-line
practitioners or others similarly close to the error, whom can
best describe the specific conditions that led to that error.
Better error descriptions make possible more effective analysis
of the system-based causes of errors. This first-hand reporting
and the improved analysis it affords has been used by error
prevention experts to create a "road map" for improvement that
easily and realistically can be extrapolated and implemented
at the broadest variety of healthcare organizations. These practical
recommendations for safe practice have been established, published,
and widely disseminated throughout the healthcare community.
Further, voluntary reporting programs have learned that many
errors are caused by factors outside the healthcare practice
site and beyond the direct control of a healthcare practitioner.
Thus, safe practice recommendations have been communicated
to medical device manufacturers, pharmaceutical companies,
automation technology companies, healthcare reimbursement
systems, and others less directly involved in patient care,
but nonetheless influential in the safe provision of care.
The success of current voluntary reporting systems also stems
from the trust and respect that has typically developed between
reporters and recipients who use the information to improve
patient safety across the nation. Reporting is perceived to
have immense value when those who report an error or potentially
hazardous situation can readily see that the information is
swiftly acted upon and used confidentially and proactively
to develop and publish safe practice recommendations that
can prevent errors. Additionally, many voluntary systems are
considered more credible because of their autonomy and because
they operate independently without reliance upon or relationship
to regulatory and accrediting bodies or other health care
community stakeholders. Thus, the analysis of the information
can provide new knowledge about patient safety, without conflict
of interest or pressure from other political, economic, or
marketplace forces.
Perhaps most important, the success of current voluntary
reporting systems stems from their non-punitive, system-based
approach to error reduction. Typically, voluntary reporting
systems acknowledge the inevitability of human error and understand
that errors occur because people cannot consistently outperform
unsafe systems that bound and constrain them. Therefore, the
tendency to blame individuals is lessened, event analysis
is system or process oriented rather than outcome oriented,
and error reduction efforts are not targeted at the individual
- the least manageable link in the error chain. Instead, error
reduction efforts are designed to strengthen the systems in
which practitioners work to make it difficult or impossible
to err. The IOM report title, "To Err is Human: Building a
Safer Health System," speaks loudly in support of a non-punitive,
system-based approach to error reduction. As the title clearly
implies, humans are fallible. Therefore, holding individuals
accountable to perform perfectly at all times is a wholly
unrealistic expectation.
Despite clear successes with voluntary systems, more can
and must be done to expand voluntary reporting. Although reports
submitted to voluntary systems are typically confidential,
the major barrier in reporting to an external system is the
loss of state statutory legal protection of the insightful
analysis that is often contained within the body of the error
report.
In the end, voluntary reporting systems have been largely
successful in gaining new information about preventable adverse
events, understanding the data through expert analysis, understanding
the causation of errors, and sharing that knowledge with the
healthcare community. However, using this knowledge to enhance
patient safety is the responsibility of the healthcare community.
While there is ample evidence that many organizations routinely
attempt to apply the knowledge gained from voluntary reporting
systems, some have not made patient safety a priority or provided
the necessary resources to accomplish such a goal. Thus, the
missing link is widespread adoption of proven error reduction
strategies that have been identified through internal analysis
of adverse events, external analysis of voluntarily submitted
reports, and scientific research.
Conclusions
The IOM report suggests that the two stated purposes of external
reporting systems - holding providers accountable for patient
safety and gaining information that leads to improved patient
safety - are not conceptually incompatible. However, it may
be difficult to satisfy both simultaneously. For that reason,
the report suggests that mandatory reporting systems may be
necessary to hold providers accountable and deliver the necessary
incentives for organizations to invest sufficient resources
in enhancing safety. This recommendation likely reflects a
general and growing feeling that the nation needs better healthcare
information as well as a safer healthcare system, and that
individual practitioners and providers must be held accountable
for their actions. The report further recommends public and
legal disclosure of serious errors, citing the public's right
to know about such errors.
On the other hand, the report readily acknowledges that voluntary
reporting systems, for both internal and external programs,
are more useful and effective in learning about adverse events
and improving patient safety. Thus, both mandatory and voluntary
reporting systems are recommended to meet the goals of learning
about errors and holding providers accountable for enhancing
patient safety.
The Institute for Safe Medication Practices (ISMP) firmly
agrees with the difficulty in satisfying both stated goals
simultaneously with either mandatory or voluntary reporting
alone. However, ISMP does not believe that mandatory reporting
systems, as they currently exist or as proposed in the IOM
report, will significantly increase provider accountability
for patient safety or the public's trust in the healthcare
system. Moreover, individual state-administered mandatory
programs are unlikely to be successful in meeting this goal.
If we must address provider accountability through a reporting
system, success is more likely if you encourage healthcare
organizations to report adverse events to a public agency,
such as the Joint Commission on Accreditation of Healthcare
Organizations (JC). While the JC encourages voluntary
reporting of sentinel events, the organization also provides
the level of expertise needed to validate, during on-site
visits, that system-based changes have been made to prevent
reoccurrence. However, organizations that mandate actions
after an adverse event, such as JC, will undoubtedly inhibit
disclosure of errors and lessen the amount of knowledge that
can be gained from the reporting system.
However, other IOM recommendations address the goal of holding
providers accountable for patient safety in a far more meaningful
way than the recommendation for mandatory reporting. Examples
include:
- Regulators and accreditors should require healthcare
organizations to implement meaningful patient safety programs
with defined executive responsibility;
- Public and private purchasers of healthcare services
should provide incentives for healthcare organizations to
demonstrate continuous improvement in patient safety;
- Professional societies should recognize patient safety
considerations in practice guidelines and in standards related
to the introduction and diffusion of new technologies, therapies,
and drugs;
- Educational bodies, professional societies, and group
purchasers should define standards of practice, inform members
about patient safety, and call attention to the issues among
the general public;
- Competency testing of professionals should encompass
error-prone activities;
- Accrediting bodies and group purchasers should recognize
and reward healthcare organizations that participate in
voluntary reporting systems;
- Healthcare organizations should incorporate well-understood
safety principles; and
- Healthcare organizations should implement proven medication
safety practices.
ISMP also does not believe that legal disclosure of serious
errors will regain the public's trust or enhance patient safety.
The IOM report notes that committee members held alternative
views on the protection of information submitted to external
reporting systems. Some members felt that all information should
be protected to prevent interference with disclosure of errors,
proper analysis, and actions to enhance safety. Others felt
that information should be disclosed and that liability is a
part of the accountability system that serves a legitimate role
in holding people responsible for their actions. The report
states that mandatory reporting and legal disclosure of very
serious adverse events caused by errors represent a compromise
for both sides. ISMP believes the ramifications of this compromise
could be significant and, in the end, will have little impact
on patient safety other than to drive errors even further underground,
especially in the absence of comprehensive tort reform legislation.
At a minimum, federal legislation is needed to extend peer review
protection to all information, including very serious and fatal
adverse events, submitted to reporting systems.
The healthcare community does not need the "bigger hammer"
of mandatory reporting or legal disclosure of serious errors
to enhance patient safety and gain the public's trust. Many
healthcare organizations are making significant changes that
enhance patient safety, even without mandatory reporting requirements.
The larger priority is to learn from preventable adverse events
and errors through voluntary reporting systems and research,
and to assure widespread application of that knowledge through
implementation of the remaining IOM recommendations.
The following section provides a conceptual framework for
a model reporting system - a model that can most effectively
prevent tragic adverse events, save lives, use national resources
most widely, and regain the public's trust in health care.
III. Conceptual Framework for Adverse Event and Error
Reporting
The IOM report does not propose establishing a national voluntary
reporting system, as there are already a number of good efforts
in existence. However, expansion of existing programs and
the establishment of new voluntary reporting systems to cover
gaps in the current complement are encouraged. The proposed
Center for Patient Safety has been charged with oversight
of this process. While several options are available for the
general design of voluntary systems, ISMP recommends, and
the IOM report supports, the establishment or enhancement
of focused "mini-systems" that are targeted toward selected
areas in health care, such as surgical events, anesthesia
events, medication events, pediatric events, and so on. The
framework for such "mini-systems" should:
- be national in scope;
- be voluntary in nature;
- be confidential;
- be non-punitive with respect to those who report;
- be independent of regulatory or accrediting bodies;
- be objective with findings and recommendations;
- be embraced and supported by the full health care community;
- be effective and credible in analyzing and using the
information;
- be timely and widespread with communications about errors
and their prevention;
- encourage unrestricted practitioner reporting;
- receive reports of serious and fatal events caused by
error, "near misses," and hazardous situations that could
lead to error;
- provide incentives for reporting;
- encourage universal acknowledgment, adoption, and implementation
of proven safety practices; and
- offer a level of evidentiary protection for the error
information reported to it.
Voluntary Reporting
While reporting is fundamental to the broad goal of error
reduction, barriers to reporting must be addressed before
we can have a substantial positive impact on patient safety.
Reporting will occur only if practitioners feel safe doing
so and it becomes a culturally accepted activity within the
healthcare community. Today, the obvious difficulty with widespread
reporting falls primarily into three categories: fear of individual
or organizational repercussion; the ill-conceived, false belief
that medical error can be used as a measure of practitioner
competence; and potential legal discovery of error reports.
Thus, fundamental in our quest for safer patient care is an
undeniable need for broader protection of error reports and
a non-punitive culture that places higher value on reporting
errors and resolving system-based problems than pursuing the
largely unsuccessful path of punishing practitioners for errors.
Until the healthcare community embraces such a culture, error
reporting will continue to be an untapped resource, even if
mandated. Although health care is slowly moving toward such
a culture, mandatory reporting will not be successful until
such a paradigm shift is in full swing. Primarily for that
reason, the Institute for Safe Medication Practices (ISMP)
strongly recommends voluntary reporting systems.
Also, voluntary reporting is preferred for another important
reason. As noted in the IOM report, the volume of reports
alone does not determine the success of a reporting system.
Although a voluntary reporting system will not capture information
about all error-related deaths and serious injuries, because
of the repetitive nature of health care errors, a sound reporting
system does not need reports of all deaths/injuries to be
effective. In fact, as voluntary reporting systems are alerted
to problems and provide feedback to the healthcare community,
reports about the same problem decreases.
Aiming to capture information on all adverse events and errors
through a large, mandatory reporting programs is unnecessary,
redundant, and potentially wasteful of our nation's resources.
This is because programs that collect larger numbers of error
reports are unlikely to yield much new information beyond
that which can be readily learned from a more streamlined
and effective voluntary program. In fact, the collection of
too much information simply slows analysis and subsequent
actions that should be taken to protect against future errors.
Further, important information is likely to be lost in the
process of filtering such a large body of reports.
Equally important, mandating reports on all serious errors
will not yield sufficient or accurate information about the
current status of patient safety. The usefulness of reported
events lies in the quality and contextual richness of the
reported events, not in counting error reports. Scientific
research has verified that healthcare practitioners fail to
detect a large number of medical errors. As such, even in
an ideal world where all detected errors would be reported,
there would be no value in assessing the current state of
patient safety by counting the number or calculating the percentage
of errors through any reporting system. To date, research
methodologies have been proven to be the only valid means
of measuring patient safety in health care, as it relates
to medical error. Hence, the number of errors reported to
a program is not a true reflection of medical error occurrence
or patient safety. In fact, the volume of reports is far less
significant than the quality of information contained in reports
that reflect a sampling of medical error across the nation.
Legal Protection of Error Information
Reporting has potential adverse consequences for those who
report errors. Therefore, reporting systems that incorporate
incentives and safeguards are likely to receive more and better
data if the system is perceived as trustworthy and safe. One
of the most significant incentives for reporting is to offer
confidentiality and some level of evidentiary protection for
the information submitted to reporting systems.
Information contained in specific error reports should not
be legally discoverable solely because the organization has
reported it externally to a reporting system. Instead, the
information contained in externally submitted reports should
be given the same legal protections currently afforded by
state peer review statutes. In other word, reporting to an
external reporting system should not waive the protections
currently in place through state peer review statutes. Such
protection is similar in spirit to the original intentions
of state peer review statutes -to encourage open analysis
of adverse events for the purpose of improvement, without
fear of legally disclosing information gathered during the
peer review process.
Because many state peer review statues would require careful
revision to extend protection to information submitted to
external reporting systems and other collaborative efforts,
federal legislation would be a more efficient and effective
alternative. Such federal legislation also should protect
those who receive and analyze error reports from being forced
to release sensitive patient, provider, or error information,
even if requested during the legal discovery processes.
While the IOM committee points out that protection from liability
may seem inappropriate for specific errors that cause serious
patient harm, information obtained during analysis of the
error already carries varying degrees of legal protection
through state statutes. Thus, information about harmful events
that result from errors should not be excluded from
protection when organizations share the information with external
sources for the purpose of enhancing patient safety.
Public Disclosure of Errors and Provider Accountability
With or without reporting systems, healthcare providers have
a moral and ethical obligation to disclose medical errors
honestly and promptly to patients and/or patients' families
who are the victims of such errors. Moreover, such disclosure
may reduce the financial risk to organizations. However, compelling
widespread public disclosure of specific adverse events due
to errors does not serve the public well. If specific errors
are honestly revealed to patients and/or families, the decision
to publicly disclose such information lies in the hands of
the proper parties, the victims themselves, without risking
inadvertent disclosure of sensitive or legally-protected healthcare
information by providers.
Still, there is an appropriate place for public disclosure
of patient safety issues. The IOM report notes that the public
has a right to expect health care organizations to respond
to evidence of safety hazards by taking whatever steps are
necessary to make it difficult or impossible to make a similar
error in the future. The report also notes that the public
has a right to be informed about unsafe conditions. ISMP strongly
agrees with this.
Providers and other participants in the healthcare process
should be held accountable for the successful implementation
of selected safety strategies that grow out of expert analysis
of reported adverse events and scientific research. Reporting
systems should not have the power to mandate implementation
of recommendations that arise from analysis of adverse events.
However, regulatory agencies (such as state health departments),
accrediting bodies (such as JC), federal agencies (such
as the Food and Drug Administration and the Health Care Finance
Administration), and healthcare purchasing groups should evaluate
such recommendations for feasibility and the cost/benefit
of adoption as standards and the power to enforce these standards.
Any healthcare organization's compliance with such standards
should then be assessed during on-site visits.
Additionally, accountability should be expanded to include
other participants in health care. Just as the public has
a right to expect healthcare providers to implement solutions
and practice the safest therapy possible, the public also
has a right to expect companies that produce medical devices,
pharmaceutical products, healthcare computers/software, and
other health-related products and services to do their part
in error-proofing health care. From committing financial resources
to improving the safety of medical devices or redesigning
a drug label, these often-overlooked participants outside
the individual healthcare setting also should be held accountable
for implementing safety strategies that have been adopted
as standards by oversight agencies.
If healthcare organizations and/or companies do not comply
satisfactorily with safety standards adopted by accrediting
and regulatory bodies, or other oversight agencies, those
safety breaches could be disclosed publicly. Additional information
may be used to compare that organization's or company's compliance
with the aggregate of other healthcare organizations or companies.
This public exposure of safety breaches equips health care
consumers to make safer and more informed healthcare decisions.
Further, it is far more meaningful than simply disclosing
sentinel events.
If desired, healthcare organizations or companies may choose
to disclose publicly their adherence to adopted safety standards,
after such compliance has been verified through on-site assessment
by regulatory or accrediting bodies, or other oversight agencies.
Error Reporting Process
As noted in the IOM report, thorough analysis of errors depends
on the quality of the information received. As such, the real
value of the error report lies in the insightful narrative
that describes the event and the details that identify the
system-based circumstances under which it occurred.
Because inadequate and second-hand information provides little
or no benefit, it is imperative that error or adverse event
reports be initiated by front-line practitioners who are most
directly involved in the day-to-day operations and can best
describe the event and shortcomings of the system. The person
reporting should submit the completed report directly to the
applicable voluntary reporting system. Some organizations
may prefer that a designated person submit all external reports.
However, individual practitioners should not be banned from
directly submitting verbal, written, or electronic reports
to any voluntary reporting system to speed timely notice of
the error, provide additional detail about the error, or report
an error that they may not be comfortable fully disclosing
within their own organization. Duplicate reports of the same
error from multiple sources are likely to be detected. Still,
duplicate reports would not seriously jeopardize the integrity
of the reporting system, as the volume of reports would play
a very minor role in comparison to the quality of the reports
received.
Patient names should be removed from the reports. However,
organizations and individual reporters should be encouraged,
but not required, to identify their names to allow reporting
system staff to talk directly with those who report the event
or situation to gain important follow-up details. Once analysis
is complete, the report could be purged of provider and/or
reporter names to provide a stronger assurance of confidentiality.
A standardized format should be used for all reporting systems.
This standardization will help ensure consistency of information
and enhance the effectiveness of an aggregate database upon
which trends can be identified and the primary causes of errors
tallied. Both manual and electronic forms of reporting should
contain standard, minimum data fields that guide identification
of the system-based causes of error. Experts in respective
fields should establish these minimum data fields, or a reporting
taxonomy for each category of medical error, that can best
gather useful information about the events or hazardous situations.
However, a narrative description of the event or situation
should be encouraged and its importance should not be overlooked.
At the same time, the reporting format must be clear and easy
for practitioners to complete.
Analysis of Reports
Submitted reports, properly interpreted, can provide important
new knowledge about the function of systems and the latent
causes of error. The IOM report notes, and ISMP strongly believes,
that those who analyze and review error reports must be content
experts who can understand and interpret the information being
provided through the reporting system and other means of data
collection. To that end, independent, multidisciplinary experts
who are closely related to the type of information received
by the voluntary reporting system should analyze the data.
Such experts, who are independent of regulatory or accrediting
bodies, can objectively determine the causes of errors and
suggest effective solutions, absent any conflict of interest.
Open communication and methods for sharing information among
reporting systems should be established to address overlapping
problems (e.g., surgical misadventure that involves medication)
and streamline error-reduction strategies (e.g., bar-coded
name bracelets to prevent multiple types of medical error,
such as administering medications to, or performing surgery
on, the wrong patient). Equally important, voluntary reporting
systems should establish open communication channels with
regulatory and accrediting agencies so the knowledge gained
from analysis of the reports can be evaluated for possible
adoption as safety standards.
Rapid Dissemination of Information
Errors cannot be prevented in the field unless practitioners
and others in health care hear about and learn from the safe
practice recommendations that result from analysis of errors
and near misses. For that reason, communication is a powerful
and necessary component of an effective reporting program.
Therefore, with appropriate protections for patients/provider
confidentiality, named-blinded error descriptions, analysis
of the causes of errors, and suggested prevention strategies
should be made easily available to healthcare participants
who need the information on a daily basis to enhance patient
safety. Reporting systems should include as part of their
mission a formally-sanctioned communication function (publication,
web-site, and other print and electronic forms of communication,
as necessary) to provide this crucial information directly,
promptly, and effectively to those healthcare professionals,
organizations, and others in the healthcare community who
need it. In addition, every effort should be made to place
information in other health-care-related forms of communication,
such as well-read professional journals and magazines, and
health-related consumer publications. Rapid dissemination
of accurate, valid, and peer reviewed information also provides
credible evidence that the information is being used appropriately
and effectively, which in turn stimulates further reporting.
Reportable Events and Priorities
The IOM report recommends that harmful adverse events be
reported to mandatory systems and those that cause little
or no harm be reported to voluntary systems. However, throughout
the IOM report, the immense value of learning from voluntary
reporting systems is made clear. Yet, there is no provision
in the IOM recommendations for front-line practitioners to
report serious and fatal adverse events caused by error to
voluntary reporting systems. This serious oversight will significantly
reduce the opportunity for voluntary reporting systems to
learn about the causes of error. Further, mandatory reporting
systems, as proposed in the IOM report, will not achieve this
goal, either, as their focus will be on holding providers
accountable for patient safety.
Voluntary reporting systems undoubtedly will become less
effective without reports of serious and fatal events. This
is because, unfortunately, predictions of patient harm may
not sufficiently and effectively motivate the entire healthcare
industry to use the knowledge gained through analysis of "near
misses" alone. Additionally, learning is impeded with reports
of only "near misses," as failures in the system and the causes
of errors closest to direct patient interaction may be overlooked.
Clear definitions and examples of reportable events or hazardous
situations should be provided to the healthcare community.
To have a positive impact on patient safety, priority should
be given to reporting and analysis of preventable adverse
events or hazardous situations that have the most significant
potential to cause harm, or that have actually caused patient
harm. Still, this stated priority should not imply any limitations
on reporting. Indeed, practitioners and organizations should
be encouraged and feel free to report any and all adverse
events, errors, or hazardous situations. Only in this way
can we hope to prevent medical errors instead of attempting
simply to count them.
IV. IOM Focus on Medication Errors
While various patient safety issues abound in health care,
medication errors comprise a large proportion of medical error.
Therefore, the IOM report clearly focuses significant attention
on this specialty area. In fact, one of the nine recommendations
requires healthcare organizations to implement proven medication
safety practices.
Strategic focus on reducing medication errors has several
advantages. First, based on the prevalence of medication errors
in health care today, this focused effort is likely to make
a large and positive impact on patient safety. Next, an effective
national model for voluntary medication error reporting currently
exists in the U.S. and is well known as a credible system
among medication error prevention experts and many healthcare
professionals. The Medication Errors Reporting Program (MERP)
is operated by the United States Pharmacopoeia (USP) in cooperation
with ISMP and is an active partner in FDA's MEDWATCH program.
As a tested and proven reporting system that includes expert
analysis of errors and widespread communication of practical
error prevention strategies, the IOM report acknowledged the
immense value of this coordinated, voluntary reporting system.
Finally, as noted in the IOM report, distinct expertise for
each broad category of medical error is needed to analyze
and use the information obtained through reporting programs
properly and effectively. Expertise for safe medication practices
is readily available today through ISMP, USP, and FDA, and
each organization could easily mobilize their forces quickly
to meet the challenges of enhancing and expanding this coordinated,
voluntary reporting system.
To that end, ISMP fully supports the IOM recommendation for
the creation of a Center for Patient Safety to carry out the
proposed functions, which include, but are not limited to
the following:
- To describe and disseminate information on external voluntary
reporting systems to encourage greater participation;
- To convene sponsors and users of external reporting systems
to evaluate ways to make them more effective;
- To periodically assess whether additional efforts are
needed for gaps in information or participation to improve
patient safety and encourage healthcare organizations to
participate in voluntary reporting systems; and
- To fund and evaluate pilot projects for reporting systems.
With the support of the proposed Center for Patient Safety,
ISMP hopes to expand and strengthen the MERP, which is an effective
model reporting system upon which to build, and thereby enhance
our continuing efforts to dramatically improve medication safety
throughout the U.S.
V. About the Institute for Safe Medication Practices (ISMP)
As a nonprofit organization, ISMP is well known as an education
resource for the prevention of medication errors. The Institute
provides independent, multidisciplinary, expert review of
errors reported through the USP/ISMP Medication Errors Reporting
Program (MERP). Through MERP, healthcare professionals across
the nation voluntarily and confidentially report medication
errors and hazardous conditions that could lead to error.
The reporting process is simple. Practitioners complete pre-addressed
mailers, dial toll-free numbers at USP (800-23-ERROR) or ISMP
(800 FAIL-SAFE), or electronically send reports via e-mail.
As an official MEDWATCH partner, ISMP shares all information
and prevention strategies with the U.S. Food and Drug Administration
(FDA). Working with practitioners, healthcare institutions,
regulatory and accrediting agencies, professional organizations,
the pharmaceutical industry, and many others, ISMP provides
timely and accurate medication safety information to the healthcare
community.
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