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



The National Action Plan to Combat Antibiotic- Resistant Bacteria intends for healthcare institutions and providers to reduce inappropriate antimicrobial use among inpatient and outpatient populations by 20% and 50%, respectively.1 The CMS and Joint Commission mandates are in place as both enforcement and to guide institutions toward success. Reducing inappropriate antimicrobial use will help mitigate the threat of antibiotic-resistant bacteria and CDI. By 2020, the National Action Plan’s goals are to reduce CDI by 50% and to reduce hospital acquisition of carbapenem- resistant Enterobacteriaceae by 60%.1 Although ambitious, achieving these metrics is important for patient care and for maintaining healthy communities, locally and globally.    
Table. Joint Commission and CMS Requirements for Antimicrobial Stewardship
Program implementation ASP should be implemented based upon national guidelines and should promote evidence-based usage of antimicrobials. The ASP should include core elements as defined by the CDC and utilizes multidisciplinary protocols.
Committee members Unspecified. The program should promote a coordinated multidisciplinary approach that includes all staff and prescribers involved in antibiotic selection, administration, and monitoring. The organization should have a multidisciplinary antimicrobial stewardship team with an ID physician, pharmacist, infection preventionist, and practitioner.
Organizational buy-in Hospital leadership should establish an ASP as an organizational priority. The organization should establish an ASP as a priority and provides necessary resources.
Leadership A program leader with appropriate expertise in infectious diseases and/or antimicrobial stewardship should be appointed. One leader should be responsible for program outcomes.
Documentation All stewardship activities should be documented, including evidence-based use of antibiotics ASP data should be collected and analyzed.
Program monitoring Unspecified The ASP should track antibiotic resistance and antibiotic prescribing patterns.
Reporting Unspecified ASPs should report metrics monitored to relevant healthcare providers
Improvement The program should demonstrate improvement in appropriate antibiotic use. The program should act upon opportunities for improvement as identified through program monitoring.
Patient education Unspecified Patients and their families should be educated, as needed, regarding appropriate use of antimicrobials.
Provider education Training and education should be provided to relevant staff and prescribers regarding practical applications of an ASP. Staff and providers involved in antibiotic orders from initiation to administration and monitoring should receive education about antibiotic resistance and stewardship.
ASP, antimicrobial stewardship program; CDC, Centers for Disease Control and Prevention; CMS, Centers for Medicare & Medicaid Services; Infectious disease     
Zahra Kassamali currently co-directs the Antimicrobial Stewardship program at UW Medicine, Valley Medical Center, in the greater Seattle metropolitan area and holds an affiliate faculty position with the School of Pharmacy at the University of Washington. Prior to her work in Seattle, Dr. Kassamali held clinical and faculty positions in infectious diseases at UCLA and at the University of Illinois, Chicago.

1. National Action Plan for Combating Antibiotic-Resistant Bacteria. The White House website. docs/national_action_plan_for_combating_antibotic-resistant_ bacteria.pdf. Published March 2015. Accessed October 11, 2016.
2. Executive Order – combating antibiotic-resistant bacteria [press release]. Washington, DC: The White House Office of the Press Secretary; September 18, 2014. 2014/09/18/executive-order-combating-antibiotic-resistantbacteria. Accessed October 11, 2016.
3. Department of Health and Human Services; Centers for Medicare & Medicaid Services. Medicare and Medicaid Programs; Hospital and Critical Access Hospital (CAH) Changes to Promote Innovation, Flexibility, and Improvement in Patient Care. Federal Register website. Published June 16, 2016. Accessed October 6, 2016.
4. Prepublication standards: new antimicrobial stewardship standard. The Joint Commission website. prepublication_standards_antimicrobial_stewardship_standard/. Published June 22, 2016. Accessed October 6, 2016.
5. About the Joint Commission. The Joint Commission website. www. aspx. Accessed October 13, 2016.
6. Core elements of hospital antibiotic stewardship programs.CDC website. html. Updated May 25, 2016. Accessed October 13, 2016.

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