Wednesday, July 20, 2022

CMS Updates Guidance for Hospitals for Antibiotic Stewardship: Add ASP Guidance for Labs, from CDC

This blog discusses several new or recent resources.

  1. CMS releases implementation guidance (22pp) on the topic of required Antibiotic Stewardship Programs for hospitals.
    1. Hospitals are required to have ASP since the implementation of March 2020 regulations in the 600 page quality operations manual.
  2. Keep in mind;  CDC recently released its 2020 guidance, Key Activities and Roles for Microbiology Laboratory Staff in Antibiotic Stewardship Programs. (5 pp).
    1. CMS repeatedly refers ASP programs to authoritative ASP guidelines from outside bodies, so in effect they're incorporating this 5 page CDC guide by reference.
  3. More from CDC:
    1. See their 2022 publication, Curren et al.,  on Diagnostic Stewardship for antibiotic resistance and sepsis.  It's based on a December 2019 workshop.  Note it includes the role of diagnostics in ASP, as well as, sometimes the role of diagnostics is to not to use them (don't overuse urine culture).
    2. See also the interesting CDC publication, ASP in outpatient settings, "Guide for Payers."



A few months before the COVID pandemic, CMS updated national requirements for antibiotic stewardship programs in hospitals, finalizing the relevant regulations in the Federal Register (84FR51732 here).  After that publication in September 2019, a few months later, CMS included the regulations themselves in the State Operations Manual, which serves both as a guide to hospital duties and as a handbook for inspectors.  Here.  However, CMS hadn't yet done what it normally does, to provide an amplified practical implementation guide of the regulations themselves.

Now in July 2022 has CMS published a 22-page handbook for how hospitals can implement the ASP in the 2019 regulations.  Find the instructions to hospitals and inspectors online here:

Paper Clip This, to That:

The CMS guidance hardly mentions the word "laboratory" which I found puzzling.  However, the guidance frequently refers to implementing external, authoritative guidelines, and fortunately we have just that from CDC.  See the August 2020 edition of "Key Activities and Roles for Microbiology Laboratory Staff in Antibiotic Stewardship Programs."  It's a critical 5 page addition to the 22 page CMS implementation guidance just publishedHERE.  

But Wait, There's More

Pair this with some important documents from CDC on diagnostics and ASP and sepsis.

And, finally published in 2022, see Curren et al.  This is the result of a December 2019 (pre pandemic!) workshop held at CDC on diagnostics and antibiotic resistance and sepsis, meet report by Curren et al.  Find it in Clin Infect Disease, here.

Although no longer new, there's a 30 page booklet from CDC on how "payers" (!) can improve outpatient antibiotic prescribing.  Here.   Recall studies that overprescribing of Abx in the outpatient setting has been found highest in urgent care centers, middle level in physician offices, and lower in "retail healthcare" e.g. CVS clinics.


I assume that soon the 22 page CMS update on ASP in hospitals, will be integrated into the master 600 page hospital handbook here.