PUBLIC COMMENT: 2023-02 HS Statewide Stroke System
NAME/ORGANIZATION OF COMMENTOR
Dr. Alex Chebl-Director of the Harris
Complex Stroke at Henry Ford Health, and
the Director of the Stroke and Vascular
Neurology Division at Henry Ford Hospital,
and member of the American Heart
Association and American Stroke
Association.
COMMENT MADE (PUBLIC OR WRITTEN)
Public Hearing
RULE NUMBER
R 330.251(n)
COMMENT
DHHS RESPONSE
MDHHS to ensure data can The details related to data exchange will be developed in depth in policy
be exported to the state
database and allow
exportation of state data to agreements, and import/export processes for the Michigan Stroke
get with the guideline stroke. Registry. The department intends to provide a direct entry model at no
cost to hospital partners.
after the administrative rules are adopted. The trauma system has policy
and process in place. This will inform the development of data use
Public Hearing
R 330.251
The Associations recommend DHHS opposes this recommendation. It appears that the commentor may
changes to the definitions of have inadvertently used a previous draft of the rule set. There is no
accreditation and
certification as the
designation is used for the
powers and duties of the
Department. The language
for accreditation and
definition of accreditation. The definition of accreditation was removed
because it is not used in the body of the document. Stroke programs
receive certification from national professional review organizations.
certification and verification
could cause confusion.
Public Hearing
R 330.251(c)
The Associations recommend DHHS opposes this recommendation.The department is charged with
changes to the definitions of integration of the Stroke System of Care into the existing Trauma System.
accreditation and
certification as the
designation is used for the
powers and duties of the
Department. The language
for accreditation and
The definition of certification was agreed upon by the administrative rules
work group made up of stakeholders and professional subject matter
experts across the state of Michigan. Integration requires consistency
across the service lines.
Certification provides verification of resources that the departments uses
to designate facilities based upon the level that the hospital is certified as.
certification and verification
could cause confusion.
Public Hearing
Public Hearing
R 330.251(g)
R 330.253(g)
For the definition of
DHHS opposes this suggestion. EMS regulations are addressed in the EMS
rule set. Disciplinary action for EMS agencies is fully described in Mich
Admin Code R 325.22126.
disciplinary action, we
suggest including EMS
agencies, as they may also
fail to comply with the Code.
The regional stroke advisory The Regional Advisory Council membership is modeled on Mich Admin
council and the statewide
stroke care advisory
subcommittee both pose
ambiguity around their
Code R 325.127. Rule 3(h) which supports the intended system
integration by including broad stakeholder titles: MCA personnel,
emergency medical services (EMS) personnel, life support agency
representatives, health care facility representatives, physician, nurses and
membership. For instance, is consumers to avoid being over prescriptive and inadvertently exclusive of
the American Heart
an important partner/stakeholder. Policy will further refine roles with
Association considered a
stakeholder input as described in A Statewide System of Care for Time
consumer under the regional Sensitive Emergencies: The Integration of Stroke and STEMI Care into the
stroke advisory council? For Regional Trauma System . A Consumer will be a Michigan resident who
both the council and the
subcommittee we
recommend the definition
has experience with the system who can provide perspective and input
on system impacts and how to improve. A national organization would
not be considered a consumer. It is expected that the content experts on
include, inclusive of expertise the advisory council and committee are members of and/or participate
in the specific field such as
professional organization,
with expertise in stroke
systems of care.
with national organizations and can reflect the current position of these
bodies as it relates to the state.
Public Hearing
R 330.253(j)
The Regional Advisory Council membership is modeled on Mich Admin
Code R 325.127. Rule 3(h) which supports the intended system
integration by including broad stakeholder titles: MCA personnel,
emergency medical services (EMS) personnel, life support agency
representatives, health care facility representatives, physician, nurses and
consumers to avoid being over prescriptive and inadvertently exclusive of
an important partner/stakeholder. Policy will further refine roles with
stakeholder input as described in A Statewide System of Care for Time
Sensitive Emergencies: The Integraration of Stroke and STEMI Care into
the Regional Trauma System . A Consumer will be a Michigan resident
who has experience with the system who can provide perspective and
input on system impacts and how to improve. A national organization
would not be considered a consumer. It is expected that the content
experts on the advisory council and committee are members of and/or
participate with national organizations and can reflect the current
position of these bodies as it relates to the state.
The regional stroke advisory
council and the statewide
stroke care advisory
subcommittee both pose
ambiguity around their
membership. For instance, is
the American Heart
Association considered a
consumer under the regional
stroke advisory council? For
both the council and the
subcommittee we
recommend the definition
include, inclusive of expertise
in the specific field such as
professional organization,
with expertise in stroke
systems of care.
Public Hearing
R 330.253(q)
The State trauma committee This is correct and a similar model will be followed for the Stroke advisory
has representation from
Level 1 and 2 trauma
hospitals certified by the
committee, with an application process (link) and considerations for
representation from urban, rural, regional geography and capability. All
of which will be outlined in policy which allows for a slight amount of
American College of Surgery. flexibility to ensure the system is represented accurately and effectively
At a minimum, we suggest a and which allows for some latitude for clinicians who may not be able
Level 1 CSC, or Level 2 TSC
make a commitment to serve, for effective group dynamics, preserving
certified, and Level 3 PSC or institutional memory and to effect system building. Titles that are too
Level 4 ASR. CSC IS
descriptive/prescriptive limit the pool of candidates, positions go unfilled
and the important advising function of the committee is compromised.
comprehensive stroke
center, TSC is thrombectomy
stroke center, PSC is primary
stroke center, and ASR is
acute stroke ready. And, let’s
see, Level 4, administrative
representation should be
allowable.
