Long Term Care
REGULATORY REQUIREMENTS
The Conditions of Participation (CoP) for Center for Medicare and Medicaid Services (CMS) was revised in October 2016 for long-term care facilities (LTCF). The current regulations require LTCF to develop an Infection Prevention and Control Program (IPCP) that includes an Antimicrobial Stewardship Program (ASP). The ASP must, at a minimum, includes antibiotic use protocols and a system to monitor antibiotic use. To view the full updated CoP, visit https://www.gpo.gov/fdsys/pkg/FR-2016-10-04/pdf/2016-23503.pdf.
The interpretive guidance for the new CMS CoP was published on June 30th, 2017. To view the full document, visit https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/GuidanceforLawsAndRegulations/Nursing-Homes.html. The following are excerpts from the 696-page document relevant to ASP in LTCF.
42 CFR 483.80(a)(3)–pertaining to antibiotic stewardship program
Intent of the regulation is to ensure facility
- optimizes treatment of infection through use of protocols
- reduces risk of adverse events from antibiotic use
- monitors facility-wide antibiotic use
ASP should include leadership support and accountability via the participation of
- the medical director
- consulting pharmacist
- nursing
- administrative leadership, and
- individual with designated responsibility for the infection control program if different.
ASP protocols must
- be incorporated in the infection prevention and control program
- be reviewed on an annual basis
- contain a system of reports to monitor antibiotic usage and resistance data
- incorporate monitoring of antibiotic use
- assess residents for suspected infection using standardized tools and criteria
- include mode and frequency of prescribers and nursing education on ASP
Review by surveyor will determine if facility’s ASP includes
- antibiotic use protocol(s) to address antibiotic prescribing practices such as
- documentation of indication, dose, duration of antibiotic
- review of laboratory reports to determine if antibiotic is indicated or needs adjustment
- use of an infection assessment tool or management algorithm
- system to monitor antibiotic use such as
- antibiotic use reports
- antibiotic resistance reports