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

Antimicrobial stewardship programs will soon become nationally mandated.1 Following President Barack Obama’s 2014 executive order to combat antibiotic-resistant bacteria, the White House released a National Action Plan in 2015 that included targets to implement antimicrobial stewardship in all healthcare facilities (Figure).1,2 The Centers for Medicare & Medicaid Services (CMS) recently published updated Conditions of Participation (CoP) for implementation of formal antimicrobial stewardship programs in all hospitals and critical access hospitals participating in Medicare and Medicaid programs.3 Although a specific date for implementing the new CoP has not been published, the general timeline, according to the National Action Plan, estimates this to be done by 2018.1,3

In the meantime, a separate accrediting body, the Joint Commission, will begin assessing institutional antimicrobial stewardship programs (ASPs) on January 1, 2017, as part of their accreditation survey.4 The Joint Commission is an independent organization whose certification generally signifies compliance with CMS.5 Both CMS and the Joint Commission have created their own ASP guidelines.3,4 This article provides an overview of CMS CoP and Joint Commission standards, and will highlight their similarities and differences. 


In 21 of the 128 pages that detail changes to the CoP for participating hospitals and critical access hospitals, CMS discusses the rationale and requirements for antimicrobial stewardship activities.3 Antimicrobial stewardship is embedded within the infection-control and prevention requirements; however, CMS emphasizes that although the two should be fostered independently, they should work together toward common goals. Rather than outline specific criteria, CMS states that institutions should develop and implement an ASP based on national guidelines. These guidelines can include recommendations put forth by the Centers for Disease Control and Prevention (CDC), the Infectious Diseases Society of America, the Society for Healthcare Epidemiology of America, and the American Society of Health System Pharmacists.

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