CMS Pushes Cuts in HAIs, Promotes Antibiotic Stewardship

As part of a comprehensive push to improve patient safety through a reduction in hospital-acquired infections (HAIs), the Centers for Medicare and Medicaid Services (CMS) issued a proposed rule this summer that emphasizes adoption of current practice standards for hospitals' infection control efforts. Hospitals and critical access hospitals (CAH) wishing to participate in Medicare and Medicaid will be required to modernize their practices to reduce incidence of HAIs, cut inappropriate antibiotic use, and strengthen patient protections and quality of care, overall. CMS explained in a statement: "The proposed changes to the requirements, formally called the Conditions of Participation, would modernize and revise the requirements to reflect current standards of practice and support improvements in quality of care" by reducing HAIs, readmissions, and barriers to care while improving antibiotic usage and patient protections and responding to workforce shortages.

The proposed rule impacts an estimated 4,900 hospitals and 1,300 CAHs that are certified by Medicare and/or Medicaid and addresses mounting concerns over high rates of preventable HAIs and fears over mounting numbers of multi-drug resistant organisms. Specifically, hospitals and CAHs would be required to:

• Implement hospital-wide infection prevention and control for the surveillance, prevention, and control of HAIs and other infectious diseases

• Employ hospital-wide antibiotic stewardship programs to improve the appropriate use of antibiotics

• "Designate leaders of the infection prevention and control program and the antibiotic stewardship program respectively, who are qualified through education, training, experience, or certification."

"We would promote better alignment of a hospital's infection control and antibiotic stewardship efforts with nationally recognized guidelines and heighten the role and accountability of a hospital's governing body in program implementation and oversight," CMS writes in the June 16 Federal Register. "We believe that these changes, together, would promote a more patient-centered culture of safety focused on infection prevention and control as well as appropriate antibiotic use, while allowing hospitals the flexibility to align their programs with the guidelines best suited to them."

CMS also proposes introduction of the term surveillance, which they define as including infection detection, data collection, and analysis, monitoring. Surveillance includes both testing as well as methods of "automated surveillance" based on the use of medical informatics and computer science technologies. Hospitals would be required to document these surveillance activities.

Active surveillance—the systematic collection of samples from either all or highrisk asymptomatic patients—is thought to be an effective tool in hospitals' arsenal to combat HAIs. A landmark study published in the Journal of the American Medical Association in June 2015 showed that a "bundle" of pre-surgical interventions can significantly reduce the incidence of surgical site infections due to Staphylococcus aureus. Central to this strategy was early nasal screening of patients undergoing total hip or knee replacements and cardiac operations. Yet, active surveillance is not as widely adopted as some in infection control would hope, in part because of mixed results of studies assessing the strategy's clinical and cost effectiveness. For more information of the design of infection control programs, including the role of active surveillance testing, please see the September issue of Diagnostic Testing & Emerging Technologies.

Takeaway: CMS proposes requirements for hospitals promoting reduction of costly hospital acquired infections and better antibiotic stewardship.

Source: "Medicare and Medicaid Programs; Hospital and Critical Access Hospital (CAH) Changes To Promote Innovation, Flexibility, and Improvement in Patient Care; Proposed Rule," Centers for Medicare & Medicaid Services, Federal Register, June 16, 2016 pp. 39448-39480.