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Regulatory Requirements for ASP in Different Healthcare SettingsPublished August 1, 2018

By now, you are probably aware of the regulations and accreditation requirements for antimicrobial stewardship programs (ASP) in the acute, long-term, and ambulatory care settings.  If you don’t know or remember all the details, you can review the videos from Drs. Bergman’s and Dr. Crnich’s talks on these topics presented during the Nebraska Antimicrobial Stewardship Summit in June this year.

Dr. Bergman highlighted the current regulatory requirements for acute and outpatient antimicrobial stewardship.  He provided details on each of the 7 CDC Core Elements of ASP for hospitals, and small and critical access hospitals.  Dr. Bergman emphasized that ASP should try to avoid implementing too many policies and interventions simultaneously in order to avert confusion and frustration for providers and staff.  During the presentation, Dr. Bergman also reviewed the Joint Commission standards for hospital ASP and provided information on the new requirement for critical access hospitals to implement ASP in order to receive FLEX grant funding.

For the ambulatory care setting, Dr. Bergman reviewed the 4 CDC Core Elements for outpatient ASP.  Although not required by the Center for Medicare and Medicaid Services (CMS), implementation of these Core Elements allows clinics to earn payment incentives via MIPS/MACRA.  This payment incentive system rewards prescribing quality over quantity in certain conditions, such as avoidance of antibiotics in adults with acute bronchitis.

In one of the afternoon breakout session of the Summit, Dr. Crnich spoke about regulatory requirements for post-acute and long-term care ASP.  He began by outlining the history of infection control regulations that led to the CMS ‘Mega Rule’ of 2016.  While the directors of nursing and infection preventionists are the key persons in long-term care ASP, Dr. Crnich provided concrete examples of how medical directors and pharmacists can assist with the program.  He pointed out that medical directors are especially important to serve as role models for other prescribers and should be involved in managing ‘negative deviants’ in antimicrobial prescribing.  Pharmacists are especially important in providing antimicrobial use data and can play an active role in identifying inappropriate use.

To watch these videos, please go to https://asap.nebraskamed.com/resources/2018-summit-slides/.  Alternative, you can go directly to the ASAP YouTube channel for Dr. Bergman’s and Dr. Crnich’s videos.

Written by Phil Chung, PharmD, MS, BCPS

Page last reviewed: November 8, 2018