The measure specifications for CMS996 do not currently account for patients that “Transfer In” or “Transfer From” as previous renderings of the STEMI measure once did. This negatively impacts our facilities that have Freestanding Emergency Rooms (FSERs) who transfer patients to the main facility for PCI treatment. The FSER and main facility relationship is such that they both roll-up under the same COID and CCN. For the context of this measure logic, it would appear that there could be a large lapse in time between arrival to PCI start time, because the arrival to the FSER and subsequent transfer to the main facility would all be within the same patient encounter.

Consider this patient scenario for example:

• Smith walks into Pleasant Town FSER at 0900 with complaints of chest pain, receives an EKG and is diagnosed with STEMI. Mr. Smith has pre-existing conditions that contraindicate the use of thrombolytics. The FSER is not PCI capable, and Mr. Smith will need to be transferred to Pleasant Town Hospital for PCI.
• Pleasant Town Hospital is across town and is at a minimum a thirty- minute drive away. At 0935 Mr. Smith is loaded into the ambulance for transfer to the main facility -Pleasant Town Hospital. The ambulance arrives at Pleasant Town Hospital at 1007.
• After receiving report from EMS and getting Mr. Smith into an ER bay at the main facility, the ER team contacts the Cath Lab team to arrange for transport. The time is now 1022.
• After obtaining consent and prepping Mr. Smith for the procedure, the Cardiologist is ready to begin. The PCI start time is documented as 1045.

This patient encounter would be considered a fall out under the current specifications because:

• Patient did not receive thrombolytics (though contraindicated).
• Because of the joint COID/CCN between the facilities it would not appear that the patient actually transferred between facilities with a time lapse of over 30 minutes.
• The PCI start time is greater than the 90 minutes from arrival time, again because of the shared COID/CCN it would all appear to be the same encounter rather than an inter-facility transfer in.

Both the FSER ER and main facility in this case provided patient care to the best of their ability and when considered individually would be in compliance with the measure specifications, however because they are considered one facility these patient encounters are fallouts.

Please advise on how to proceed with this measure as this has a significant impact on our organization’s outcomes in that we utilize the services of our over 165 FSERs that each roll up to a main facility COID and CCN.