This is an important metric and accurately reflects serious hypoglycemia resulting from anti-diabetic therapy. At Fairview Health Services, we utilize a similar metric with the only difference being that our threshold is a blood sugar less than or equal to 40 as opposed to less than 40. In use for over a decade, we have found it to be a very useful marker of anti-diabetic related adverse drug events. However, in order to ensure that perverse incentives are not unintentionally created, it should also be combined with a measure of glycemic control. In truth, more harm occurs from untreated HYPERglycemia than it does from HYPOglycemia. The focus on HYPOglycemia is because of its more acute impact. It would, therefore, be possible or even likely, for a hospital to reduce its HYPOglycemia rate by under-treating diabetes in a way that patients' blood sugars run too high. Therefore, we would advocate for a balancing measure that includes what has been proposed with a measure of glycemic control. We would be happy to discuss this with you at length at your convenience.