If my hospital is part of a HIIN, do I have to submit data to a PSO?

A previous Ask CHPSO article, Does our hospital have to submit event report data to the PSO by January 1, 2017, highlighted how a hospital can fulfill the requirement of the Affordable Care Act to either report to a PSO or have an evidence based initiative based on the evaluation of safety reports. CMS states that HIINs (Hospital Improvement Innovation Network) satisfy the non-PSO reporting option. If hospitals choose to not report to a PSO based on HIIN participation, there are a few caveats to keep in mind:

  • The hospital will not have Patient Safety Work Product privilege, as that requires an intent to report to a PSO.
  • PSO members that do not submit events to the PSO will not obtain all the benefits of PSO participation. For instance, at CHPSO, hospitals that do not submit data will not receive research requests (due to restrictions the law places on PSOs sending information to non-reporting hospitals), RCA critiques, and access to the hospital benchmarking tool.
  • The HIIN program, as currently structured, is temporary, and participants will need to seek other methods of satisfying the Affordable Care Act requirement once the program ends. PSOs were established by the Agency for Healthcare Research and Quality in 2008, and CHPSO is one of the first and largest PSOs in the nation.

There are many benefits to participating in a HIIN. There are also many benefits to participating in a PSO, and the two complement each other. CHPSO coordinates with CalHIIN specifically and the HIIN program in general to ensure that the benefits to participants in both PSO and HIIN are maximized. For more information, contact

“Ask CHPSO” is a regular column in the bimonthly Patient Safety News and is intended to provide answers to common inquiries. If you have a question, please contact us at (916) 552-2600 or All inquirers will remain anonymous.