Antibiotic Stewardship Program Update

Senate Bill 579, which passed in 2016, modified existing infection control standards and regulated development of antimicrobial stewardship programs in Missouri hospitals. With this legislation, Missouri hospitals are required to develop and operationalize Antibiotic Stewardship Programs, to report new healthcare-associated infection and surveillance data, and to submit antibiotic use or resistance data through the Centers for Disease Control and Prevention’s National Healthcare Safety Network Antimicrobial Use or Resistance module when regulations concerning Stage 3 of meaningful use are in effect. The Missouri Hospital Association is committed to providing applicable education and support of the requirements outlined in statute and regulation through several resources, including previous Inside Track editions, webinars and an Antibiotic Stewardship Immersion Project.

Missouri hospitals continue to work to improve stewardship programs through data monitoring and quality improvement activities, collaboration among organizations, and investments in technical infrastructure. Twenty-four Missouri hospitals actively participated in an MHA staff-led Antibiotic Stewardship Immersion Project aimed at supporting members to establish and improve ASP programs to meet the requirements of Senate Bill 579. The project, which began in November 2016 and ended in August 2017, included access to national subject matter experts, case studies and tools, intervention support, and coaching from MHA staff. Each hospital developed policies and interventions to meet ASP compliance and optimize antibiotic use, as recommended by CDC guidelines. Following the project, seven hospitals continued robust data reporting to MHA to enable longer-term results tracking. Two of the tracked metrics directly linked to optimizing antibiotic use include compliance rate (number of prescriptions with confirmed right drug, dose, time, duration and medical necessity) and days of therapy. The compliance rate for the seven sustained reporting hospitals improved by 24 percent with a 52 percent reduction in antibiotic days of therapy. The causal factors for this reduction are thought to be varied and include increased education and awareness by prescribers of the need to optimize antibiotic use; specific hospital-based interventions, such as IV to PO conversion, formulary restrictions, antibiotic time outs and improved culturing practices; and increased engagement and oversight of prescriptions by pharmacists. Additionally, public-facing educational campaigns help inform patients about antibiotic use. Hospitals across Missouri continue working to optimize and monitor antibiotic use, as well as engage in the development of data collection and reporting capabilities using NHSN’s AUR module.

It was announced last year that Stage 3 of meaningful use would be delayed until January 2019. This has proven to be a beneficial reprieve for many Missouri hospitals as they struggle to implement the technology necessary for submitting data into NHSN’s AUR module. Recently, the Centers for Medicare & Medicaid Services published the fiscal year 2019 Hospital Inpatient Prospective Payment System proposed rule, which appears to significantly change the meaningful use program, even renaming it Medicare and Medicaid Promoting Interoperability Program. CMS proposes to require the use of 2015 Edition Certified Electronic Health Record Technology beginning in calendar year 2019. The basis for this decision is provided in the rule and heavily focuses on the increased interoperability residing with the CEHRT 2015 edition. This is important related to ASP reporting through the NHSN module as it does not appear that CMS is willing to allow the use of the 2014 CEHRT edition, and the intent appears to be to move forward with the technology improvements consistent with Stage 3 requirements. If your systems are not compliant, the window of time is decreasing. Hospitals are encouraged to comment on the rule and send comments to MHA. Comments are due by Monday, June 25.

As noted, another requirement resulting from Senate Bill 579 was the revision of state regulatory requirements surrounding hospital-acquired infections and surveillance reporting. The Infection Control Advisory Committee met numerous times to discuss who, what and where information should be reported. The final rules surrounding reporting of healthcare-associated infections were recently published in the Missouri Register, effective Monday, April 30, 2018. Hospitals should have received a letter from the department in the last couple of weeks – similar to this one – announcing the changes. If your hospital did not receive a letter or you have questions about reporting, please contact Patricia Tighe, 573/522-9610, with the Bureau of Health Care Analysis and Data Dissemination.

The importance of antimicrobial stewardship is increasingly drawing the attention of media, regulators and legislators. There is no sign that interest in this topic will fade as illnesses related to antibiotic overuse become harder to treat, sepsis cases continue to rise and the development of new antimicrobial agents is at an all-time low. Contact Sarah Willson for any regulatory questions, or Alison Williams for any clinical quality improvement needs.