CMS Patient Safety Structural Measure / Domain 4, Statement B
An AHRQ-listed Patient Safety Organization, listed since 2009
If your hospital could not affirm Domain 4, Statement B this spring, there is still time: a PSO relationship that starts before the CY2026 performance year closes on December 31, 2026 makes it answerable next April.
Statement B is the one statement in the Patient Safety Structural Measure a hospital cannot answer any other way. It takes a Patient Safety Organization listed by AHRQ, and American Data Network’s PSO is number P0051, listed February 25, 2009, among the first AHRQ ever listed.
The requirement
There is no substitute for a PSO on Statement B
Most PSSM statements can be met several ways. This one cannot. CMS’s attestation guide states the test in a single sentence: “Hospitals positively attesting to this statement are those working with an AHRQ-listed Patient Safety Organization.” Its April 2026 FAQ says the same thing from the other direction: “Only hospitals that work with an Agency for Healthcare Research and Quality (AHRQ) listed PSO may attest affirmatively to Domain 4, Statement B.”
There is no internal program, committee, or alternative vendor arrangement that answers it. Either your hospital works with a listed PSO or Statement B is a no.
What it requires
The PSO has to be listed by AHRQ
AHRQ maintains the public federal directory of listed PSOs. ADN PSO appears there as P0051, with an effective date of initial listing of February 25, 2009, and no disclosures or findings on file. You can verify all of it yourself on AHRQ’s site before you talk to us. This is the whole requirement, and it is the one thing a hospital cannot arrange internally.
What it does not require
Any one of the listed activities is enough
CMS names the qualifying patient safety activities from 42 CFR 3.20 “such as, but not limited to” and joins them with “or.” Collection and analysis of patient safety work product. Dissemination of information such as best practices. Encouraging a culture of safety. Activities related to operating a patient safety evaluation system. Any one of them qualifies. Sending serious safety events to a PSO is one way to satisfy the statement, not the definition of it. For most ADN members, the qualifying activity is a culture of safety survey we administer.
The misreading that costs hospitals a year
You do not have to change your event reporting system to answer Statement B yes.
The most common reason a quality team defers this is a belief that Statement B means routing serious safety events out of the system they already use. It does not. If you have read that the statement requires reporting serious safety events to a PSO that submits to AHRQ’s national database, that was the version CMS proposed and then changed before the final rule, and a fair amount of published material still carries it. The current statement asks for a working relationship with a listed PSO and gives you four ways to have one.
ADN PSO closes Statement B, not the whole domain. Domain 4 holds five attestation statements and scores all or nothing, so no vendor can hand your hospital a domain point. Statements A, C, D and E stay your hospital’s work, and we will tell you plainly where we do and do not help.
How the measure is scored
Five domains, twenty five statements, no partial credit
The Patient Safety Structural Measure (PSSM) is an attestation measure in the CMS Hospital Inpatient Quality Reporting (IQR) Program and the PPS-Exempt Cancer Hospital Quality Reporting (PCHQR) Program. Each of the five domains carries five statements. Your hospital answers yes or no to each one. Our full guide to the Patient Safety Structural Measure (publishing separately) walks all five domains and all 25 statements.
One point per domain, and only for a clean sweep
A hospital earns the domain point only by affirmatively attesting to all five of its statements. CMS is explicit: “There is no ‘partial credit’ for attesting positively to some of the domain statements.” One missing statement zeroes the whole domain. Total score runs from zero to five.
A low score is public, not financial
PSSM is a pay-for-reporting measure. CMS states there is “no penalty associated with a low score or for answering no to any or all domains.” Hospitals do have to report to satisfy IQR requirements. The consequence of a low score is visibility: your total posts publicly.
Patients see the total, not the reason
Each hospital’s overall score posts on the Medicare.gov Care Compare tool and the Provider Data Catalog in the fall following the performance year. Individual domain scores are not published. So a 3 out of 5 is public, but the fact that a missing PSO relationship caused it is not.
Why ADN PSO
AHRQ-listed PSO since 2009, and doing more than the statement asks
The listing is a public record you can check in a minute. What the listing does not tell you is how active a PSO actually is, and that is the part worth asking about.
Verifiable on AHRQ’s site
One of the first PSOs AHRQ listed
AHRQ began listing PSOs in 2008 under the Patient Safety and Quality Improvement Act of 2005. ADN PSO’s effective date of initial listing is February 25, 2009, its PSO number is P0051, and its AHRQ record shows no disclosures or findings. Listed since 2009, which is a public record rather than a marketing claim.
More than the statement asks for
An active voluntary NPSD reporter
Submitting de-identified patient safety data to AHRQ’s Network of Patient Safety Databases is voluntary for PSOs, and many listed PSOs do not do it. ADN PSO does. Statement B does not require it, so treat this as evidence rather than as a box to tick: a PSO that is submitting to the national database is a PSO with a live analytic operation behind it, not a listing on a shelf.
The company behind the PSO
Twenty five years inside hospital quality reporting
American Data Network has worked in hospital quality data for more than 25 years, has been an ORYX vendor since Core Measures reporting began, and serves hospitals nationwide ranging from 10 to 800 beds. The PSO is not a side venture bolted onto a software product, it sits inside a quality reporting business.
Federally listed since February 25, 2009
ADN PSO is listed by the Agency for Healthcare Research and Quality as PSO number P0051. Check our listing in AHRQ’s directory.
What membership actually does
Why PSOs exist
Compliance is the reason most hospitals call. It is not the reason PSOs exist. This is what the relationship changes day to day.
Federal privilege and confidentiality
Under the Patient Safety and Quality Improvement Act of 2005, patient safety work product that your hospital develops inside a Patient Safety Evaluation System (PSES) and reports to a listed PSO is privileged and confidential under federal law, subject to the exceptions written into the statute. In practice that is what lets a team write down what actually happened, in specific language, and analyze it candidly. Whether your membership carries these protections depends on how you participate; see the membership levels below.
A working relationship, not just a membership card
For hospitals that report events to the PSO, ADN PSO receives serious safety events, near misses and precursor events, analyses them, feeds best practices back to participants, and submits de-identified data to AHRQ’s NPSD. Statement B asks you to affirm that your hospital works with a listed PSO to carry out patient safety activities. The point of doing it properly is not the attestation, it is that your documentation shows a live relationship rather than a signature on file.
Patterns a single hospital cannot see alone
One hospital sees its own events. A PSO sees the same event types across participating organizations, which is how a near miss that looks like a one-off locally gets recognized as a recurring failure mode worth a system fix. When our team analyzed four years of submitted patient safety events, more than 40% sat in a single category: “Other.” Working out what was actually in there produced a proprietary list of 33 subcategories, and an invitation to present the findings at the National Association for Healthcare Quality conference.
Shared learning among participating organizations
Members get the benefit of what other participating organizations have already learned, through shared analysis and safety communications rather than starting every investigation from scratch.
About Domain 3, Statement E. The shared learning above is learning among PSO participants. It is not the same thing as the large-scale learning network in Domain 3, Statement E, which CMS defines as a collaborative of hospitals that share data and practices for research and development, citing Children’s Hospitals’ Solutions for Patient Safety and the Partnership for Patients as its examples. ADN PSO membership does not satisfy that statement, and we will not tell you it does.
Not legal advice. PSQIA protections attach to how patient safety information is created and handled inside your PSES, not to membership by itself, which is why the PSES setup deserves attention. American Data Network is not a law firm and does not provide legal advice. Have your own counsel review your PSES documentation.
Membership levels
Three ways to be a member
Which level you are on decides what you get, and whether your events are reported to the PSO decides whether federal privilege attaches.
Included at no additional charge
Membership through Event Reporting App
For hospitals already running ADN’s Quality Assurance Communication (QAC) application. The one level where your events are part of the relationship.
Includedwith your event reporting subscription
- The membership itself, the same AHRQ-listed relationship that answers Domain 4, Statement B.
- Events report to the PSO monthly. Work product your team designates flows without ever leaving the application.
- Federal privilege attaches to that reported work product, as described above, subject to the exceptions written into the statute.
For hospitals between full surveys
Membership + Pulse Survey
For hospitals whose full survey already happened, this year or last, in house or with another vendor. The pulse carries your off year. When your next survey year arrives, run the full survey yourself and keep this level, or step up to Membership + Full Culture Survey and ADN runs it.
Priced per facility on licensed beds. The number you sign at is the number you keep for your whole agreement, and one short conversation gets you the exact figure.
- The membership itself. Working with an AHRQ-listed PSO is the only way a hospital can affirm Domain 4, Statement B. No internal program substitutes.
- An annual pulse survey on units you designate: the off-year survey Domain 3, Statement A expects on a two-year cycle, and itself a qualifying activity, encouraging a culture of safety.
- The member resource library. Safety alerts and best practices, the dissemination activity CMS names as qualifying PSO work.
- An attestation evidence letter each March, documenting the qualifying activities we carried out with your hospital. The paper you want in hand when attestation opens April 1.
The full survey cycle, administered by ADN
Membership + Full Culture Survey
For hospitals whose survey year is now, or coming up. ADN administers your full AHRQ SOPS survey in survey years, with the pulse in the off years.
One flat annual price for both years of the cycle, priced per facility on your survey size. One short conversation gets you the exact figure.
- One flat annual price that does not change between survey years and pulse years, so the whole two-year cycle is one decision instead of two.
- Your report within 30 days of survey close, with benchmarked comparisons, heat maps and department-level views.
- Both halves of the Domain 3, Statement A cadence handled: the validated survey in survey years, the pulse in between.
Everything in Membership + Pulse Survey, plus
If membership is your first step
Your entire first year of membership credits toward an event reporting subscription.
Join at either level and answer Statement B this year. If you move your event reporting to ADN’s application within 12 months, every dollar of that first year comes off the subscription, so starting with membership carries no penalty.
Standalone membership does not send your event data to the PSO, and it does not extend federal privilege to information inside your hospital’s own systems. You satisfy the structural measure; you do not acquire the legal protections. If those protections matter to your hospital, that is the event reporting path.
Multi-facility systems sharing a CCN should price all facilities together; that is a short call with Susan.
How enrollment works
Four steps, starting with a conversation
Nothing here requires you to change your event reporting system or move your data anywhere first.
Scope the facilities
A short call to map your CCNs and NHSN OrgIDs, confirm which facilities attest separately, and establish where Statement B stands for each one today.
Sign the participation agreement
ADN provides the PSO participation agreement that establishes the relationship and the confidentiality terms required under PSQIA.
Schedule your culture survey
ADN administers your survey and returns the results: the annual pulse on units you designate at the Pulse level, or the full AHRQ SOPS survey in survey years at the Full Culture level. Either way, it is the qualifying activity that makes the relationship real rather than a signature on file, and it counts toward the Domain 3, Statement A cadence at the same time.
Begin the patient safety activities
Once your hospital is working with ADN PSO inside the performance year, on any of the activities the statement names, Statement B is answerable for that year. Attestation itself happens in the April to May window through NHSN.
Enrollment started before December 31 counts for CY2026
A short call is enough to confirm where Statement B stands for each of your facilities and what enrollment would involve.
The calendar
What has happened, and what December 31 decides
Attestation runs April 1 to May 15 each year, moving to the next business day if the 15th falls on a Friday or a weekend. Hospitals submit through the CDC’s National Healthcare Safety Network (NHSN), not the Hospital Quality Reporting portal.
The performance-year rule, and what follows from it
A practice counts for the year if it was in place at any point during that year, not only from January 1.
CMS put it this way: hospitals are attesting that the practice “has been hospital practice or was put into place at some point during the performance year, although not necessarily occurring at the start of the year.” Its own example is a hospital that began publicly displaying patient safety metrics in June 2025 and could still attest yes for CY2025 on Domain 4, Statement C.
Applied to Statement B: a hospital that joins an AHRQ-listed PSO and starts working with it at any point before December 31, 2026 can affirm Statement B for CY2026. After the year closes, that answer is fixed until the following performance year.
For multi-facility systems
A shared CCN publishes the lowest score among its facilities
This is the rule most quality leaders have not read yet, and it changes how a system should think about enrollment.
CMS scores PSSM at the hospital level, not the system level: “The responses to the attestation statements should represent the individual hospital.” Where facilities share a CMS Certification Number (CCN) but report under separate NHSN Organization Identification Numbers (OrgIDs), each one attests separately, and CMS applies the lowest score of those OrgIDs to the shared CCN. That minimum is the number that publishes.
So a system can do excellent work at its flagship and still publish a weak number because one smaller facility was left out of the patient safety infrastructure. If enrollment is worth doing for one hospital under a shared CCN, it is worth doing for all of them.
CMS’s own example
Both hospitals attest separately. CMS applies the lower score to the CCN, and the CCN score is what appears on Care Compare.
The rest of the picture
Where the rest of ADN’s Patient Safety Suite lands
PSSM treats patient safety as one connected infrastructure, which is why most hospitals working toward it are managing four or five vendors on four or five renewal dates. Here is which statement each ADN offering actually supports, stated at the statement level rather than the domain level.
| ADN offering | What it supports, and how |
|---|---|
| ADN PSO | The AHRQ-listed PSO relationship the statement requires, and the only statement in the measure that cannot be answered another way.Domain 4, Statement B |
| Survey on Patient Safety Culture (SOPS) administration | The validated hospital-wide culture of safety survey, administered end to end by ADN, with your report delivered within 30 days of survey close. Statement A accepts the survey annually, or every two years with pulse surveys on target units during non-survey years.Domain 3, Statement A |
| Off-year pulse survey | The non-survey-year half of that same cadence, on target units. Two details hospitals often get wrong: CMS says the pulse does not have to be a validated instrument and is “a short set of questions, typically 5 to 15,” and CMS says safety rounds do not suffice as a pulse survey.Domain 3, Statement A |
| Quality Assurance Communication (QAC), patient safety event reporting | A confidential reporting system with real-time notifications, dashboards and analytics, including the feedback loop back to the person who reported. Hospitals that want their events to sit inside the PSO relationship can route them through QAC, but that is a choice, not a requirement of Statement B. Separately, QAC supports the event analysis work in Domain 3, Statement B without satisfying it, since that statement asks for a dedicated team using an evidence-based approach such as RCA2, and the team is yours.Domain 3, Statement B |
| Complaints and Grievances | Tracking and resolution for patient complaints and grievances, which is where the safety signal in patient complaints becomes usable. Statement D specifically names safety signals from patient complaints as patient input on safety events.Domain 5, Statement D |
Nothing on this list, bought alone or bought together, delivers a domain point by itself. Each domain holds five statements and scores all or nothing. What ADN can do is close specific statements and be straight with you about which ones are still yours.
Questions we get
PSO and PSSM Domain 4, answered
Are we required to work with a PSO?
No. CMS does not require PSO membership, and PSO participation has always been voluntary under the Patient Safety and Quality Improvement Act of 2005.
What CMS does say is that Domain 4, Statement B cannot be answered any other way: “Only hospitals that work with an Agency for Healthcare Research and Quality (AHRQ) listed PSO may attest affirmatively to Domain 4, Statement B.” Because domains score all or nothing, a hospital with no PSO relationship cannot earn the Domain 4 point no matter how strong its other four statements are.
Does Statement B require us to report events to a PSO?
No, and this is the most common misreading of the measure. CMS names the qualifying patient safety activities “such as, but not limited to” and joins them with “or”: collection and analysis of patient safety work product, dissemination of information such as best practices, encouraging a culture of safety, or activities related to operating a patient safety evaluation system. Any one of them qualifies.
If you have read a version of this statement that requires reporting serious safety events to a PSO that submits to AHRQ’s national database, that was the wording CMS proposed and then changed before the final rule. Some published material still carries it. The current text is on page 7 of the CMS Attestation Guide for the Patient Safety Structural Measure, last modified June 10, 2025.
What is the NPSD, and does it matter for Statement B?
The Network of Patient Safety Databases (NPSD) is AHRQ’s national repository of de-identified patient safety data, assembled from information that PSOs choose to submit.
It does not affect your Statement B answer. Statement B asks only that the PSO be listed by AHRQ. ADN PSO submits to the NPSD voluntarily and many listed PSOs do not, so we mention it as a sign of an active PSO rather than as something you need. If your current PSO does not submit, that has no bearing on your attestation.
We already work with a PSO. Is there any reason to look at this?
Probably not for Statement B itself. If your PSO is listed by AHRQ and you are genuinely working with it, you can affirm Statement B, and nothing on this page changes that. Check the listing in AHRQ’s public directory and keep a note of it with your attestation documentation.
Where hospitals do find a gap is in what the relationship is actually producing. A PSO that receives your reports and returns nothing analytic satisfies the attestation and does very little else. That is a value question rather than a compliance one, and it is a fair reason to compare.
Do we have to switch event reporting systems to join?
No. ADNPSO Membership leaves your event reporting exactly where it is. The qualifying activities the membership runs on, the culture survey, the shared best practices, the attestation evidence letter, happen alongside whatever system you use today, and none of them involve your event data.
Statement B does not ask for event reporting in the first place: CMS names the qualifying activities “such as, but not limited to” and joins them with “or,” so a working relationship built on any one of them answers it. Hospitals that want their events inside the PSO relationship, with the federal protections that attach to reported work product, route them through ADN’s event reporting application. That is an option and not a condition of membership.
What if we join late in the year?
CMS addressed this directly. Hospitals attest that a practice “has been hospital practice or was put into place at some point during the performance year, although not necessarily occurring at the start of the year.” CMS’s own example is a hospital that began publicly displaying patient safety metrics in June 2025 and could still attest yes for CY2025.
Applied to Statement B: a hospital that joins an AHRQ-listed PSO and starts working with it at any point before December 31, 2026 can affirm Statement B for CY2026. That is a consequence of CMS’s performance-year rule, not a deadline CMS announced. A relationship that begins in January 2027 belongs to the CY2027 attestation.
Does each of our hospitals need to enroll separately?
Plan on yes, and check your CCN structure early. CMS scores the measure at the hospital level rather than the system level: “The responses to the attestation statements should represent the individual hospital.”
Where facilities share a CMS Certification Number but report under separate NHSN OrgIDs, each attests separately and CMS applies the lowest score among them to the shared CCN. That minimum is what publishes on Care Compare. One facility left out of the patient safety infrastructure can cap what the entire CCN shows.
Is our data discoverable in litigation?
The Patient Safety and Quality Improvement Act of 2005 makes patient safety work product privileged and confidential when it is developed within a Patient Safety Evaluation System and reported to a listed PSO, subject to the exceptions written into the statute.
Those protections attach to how the information is created and handled, not simply to the existence of a membership. Which membership level you hold matters here: standalone ADNPSO Membership does not extend these protections to information inside your own systems, while event data reported to the PSO through our application does carry them. American Data Network is not a law firm and does not provide legal advice. Have your counsel review your PSES documentation.
Will a low PSSM score cost us money?
Not directly. PSSM is a pay-for-reporting measure, and CMS states there is “no penalty associated with a low score or for answering no to any or all domains.” Hospitals do need to report the measure to meet Hospital IQR Program requirements.
The exposure from a low score is public rather than financial. Your overall score posts on the Medicare.gov Care Compare tool and the Provider Data Catalog in the fall after the performance year. Individual domain scores are not published, so viewers see the total without seeing which domain fell short.
How is the measure actually submitted?
Through the CDC’s National Healthcare Safety Network (NHSN), not the Hospital Quality Reporting portal. The attestation form is posted in the NHSN Forms section. The window runs April 1 to May 15 each year, moving to the next business day if the 15th falls on a Friday or a weekend. The first window, for CY2025 performance, ran April 1 to May 18, 2026.
Start here
Let’s find out where Statement B stands for your hospital
Tell us a little about your facilities and we will come back with a straight answer on what enrollment involves and what it would take to have Statement B answerable for CY2026.
If it is easier to start with something you can read on your own time, the PSSM Infrastructure Readiness Checklist walks all 25 attestation statements across the five domains with a running gap count. Download the checklist.
Or skip the form. You can book a time directly with Susan Allen, who is handling PSO enrollment conversations this year.
- American Data Network
10809 Executive Center Drive, Searcy Building, Suite 300
Little Rock, AR 72211 - Phone (501) 225-5533
- Verify our listing ADN PSO, number P0051, in AHRQ’s directory of listed PSOs
Talk to us about PSO enrollment
This is the live “GIT – PSO Product Page” HubSpot form. A submission here is real: it creates a contact and notifies the team, so do not test it with fake data.