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We appreciate a commenter's position that there are existing CMS programs that drive patient safety improvement and that additional efforts may be conflicting, but we respectfully disagree and believe that further emphasis of patient safety in the Overall Hospital Quality Star Rating aligns with other efforts to improve patient safety including through HACRP

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Therefore, for all participating HOPDs, we estimate removal of this measure will decrease burden by approximately 533 hours (0.167 hours 3,200 HOPDs) at a savings of $29,347 (533 hours $55.06/hour)

Relying solely on a single pathway limits a providers ability to treat complex metabolic resistance

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