The Centers for Medicare & Medicaid Services does not currently have regulations in place to require antibiotic stewardship programs in hospitals, but the fact that it expanded that section in the final version of its infection control survey suggests that is only a temporary situation.

“They have added additional questions on antimicrobial stewardship,” says Neal Fishman, MD, chairman of the Centers for Disease Control and Prevention’s Hospital Infection Control Practices Advisory Committee. “They are moving toward having antibiotic stewardship as a condition for participation, which was the recommendation of the PCAST committee.”

In a recently released report, the President’s Council of Advisors on Science and Technology (PCAST), recommended that a regulatory requirement for antibiotic stewardship be in place by the end of 2017.¹ The report coincided with an executive order from President Obama calling for regulations requiring antibiotic stewardship programs and other actions to preserve drug efficacy in the face of rising multidrug-resistant pathogens.

The CMS survey “information” requirements on antibiotic stewardship reflect collaboration with the CDC, which has issued similar recommendations and is openly discussing CMS enforcement of the critical issue. The antibiotic stewardship requirements in the final version of the CMS infection control survey include the following:

• The hospital has written policies and procedures whose purpose is to improve antibiotic use (antibiotic stewardship).
• The hospital has designated a leader (e.g., physician, pharmacist, etc.) responsible for program outcomes of antibiotic stewardship activities at the hospital.
• The hospital’s antibiotic stewardship policy and procedures requires practitioners to document in the medical record or during order entry an indication for all antibiotics, in addition to other required elements such as dose and duration.
• The hospital has a formal procedure for all practitioners to review the appropriateness of any antibiotics prescribed after 48 hours from the initial orders (e.g., antibiotic time out).
• The hospital monitors antibiotic use (consumption) at the unit and/or hospital level.²

References

1. President’s Council of Advisors on Science and Technology. Report to the President on Combating Antibiotic Resistance. September 2014. Available at: http://1.usa.gov/1qhDgF6
2. Centers for Medicare & Medicaid Services. Hospital Infection Control Worksheet. Nov. 26, 2014:http://go.cms.gov/1B6NCSV