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Antimicrobial Stewardship Standards: A Comparison of Centers for Medicare & Medicaid Services and Joint Commission Requirements

Although the general text of the CMS CoP is broad, there are certain requirements mentioned specifically by CMS:
  1. Develop antimicrobial stewardship policies and procedures
  2. Demonstrate an active ASP implemented hospital-wide
  3. Improve coordination among all stakeholders involved in antimicrobial use and preventing bacterial resistance
  4. Promote evidence-based antimicrobial use
  5. Reduce adverse effects associated with antimicrobial use, specifically C. difficile infection (CDI) and antibiotic resistance. 
Surveyor tools are under development, but CMS states the following three goals will be assessed:
  1. Demonstrates interdisciplinary coordination among all players involved in antibiotic use and activities contributing to antimicrobial resistance
  2. Documents evidence-based use of antimicrobials
  3. Demonstrates improvement in appropriate antimicrobial use, including reduction of CDI and bacterial resistance. 
CMS recommends appointing a dedicated ASP leader with expertise in infectious diseases or antimicrobial stewardship who will be accountable for programmatic success. In addition to meeting the goals and requirements outlined above, this leader is also responsible for documenting all activities of the ASP and communicating with and educating all relevant hospital staff regarding appropriate antimicrobial use and resistance issues. 


Aside from brevity, the biggest difference between the Joint Commission standards for antimicrobial stewardship and the CMS CoP is the the former is much more specific, as can be seen on the Table on the next page. Therefore, compliance with the Joint Commission would ensure an institution has also met the CoP proposed by CMS. Unlike CMS, in which antimicrobial stewardship was combined with infection prevention, the Joint Commission categorizes ASP under medication management.3,4 Like CMS, the currently published requirements apply to hospitals and critical access hospitals. In addition, Joint Commission standards will be evaluated in nursing care centers.4
There are eight requirements put forth by the Joint Commission that incorporate the general CMS requirements. A principal Joint Commission distinction is the requirement for patient education regarding the appropriate use of antimicrobial therapy. Additionally, there are more substantial requirements for data collection, analysis, and reporting. In terms of programmatic requirements, the Joint Commission cites the CDC Core Elements of Hospital Antibiotic Stewardship Programs,6 stating, “The Joint Commission recommends that organizations use this document when designing their antimicrobial stewardship program.”4 Part of the CDC’s Core Elements includes documenting indications for all antimicrobials and reassessing antibiotic use after 48 hours for appropriateness.6 Joint Commission ASP standards require use of multidisciplinary protocols, such as formulary restrictions; guidelines for therapy in specific infections, both in adult and pediatric populations; and plans for converting intravenous antibiotics to oral therapy. Given the concise presentation of the Joint Commission standard, requirements are not listed here. Readers are encouraged to examine the document directly ( antimicrobial_stewardship_standard).

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