How do you apply the new antimicrobial stewardship standards to the ambulatory practices in a medical center?
Antibiotic Stewardship Standards
For many hospitals, the ambulatory components of the hospital are accredited and surveyed under the hospital standards. These are called provider based practices and will all be listed on your hospital application to Joint Commission as a site of care of the hospital. There may also be some freestanding ambulatory programs, not owned by the hospital, but rather owned by the Health System that will be accredited and surveyed using the Joint Commission’s ambulatory care accreditation manual.
EP 15
As for the 2023 ASP requirements themselves, that is more difficult because the elements of performance do somewhat shift focus between targeted analysis and widespread analysis. The new EP 15 establishes an organization wide responsibility.
EP 16
But, EP 16 regards the NHSN Antibiotic Use and Resistance Module, focusing on the inpatient sector, plus just a few more easily recorded outpatient areas like ED. It exempts all the widespread ambulatory care sites.
EP 17
EP 17 identifies two strategies:
- Preauthorization
- Prospective Review
You are expected to implement at least one. This is not intended to be all antibiotics, but rather the ASP team will identify potentially problematic medications due to cost or toxicity that they want to focus on. These toxic or very expensive antibiotics are inpatient focused, thus you could say the guidance and monitoring is house wide. But in reality, the very expensive new antibiotic you are focusing on is really only seen in inpatient settings.
EP 18
EP 18 speaks to implementing at least two evidence based guidelines. But, the term implementing, could apply to selecting, implementing and educating on the CPG. You could include outpatient programs in the applicability of the policy and providing some education on the CPG.
EP 19
EP 19 then requires some analysis of adherence to one of the CPG’s you selected for EP 18. As you choose, there are some infections listed in EP 18 that clearly have more inpatient applicability than outpatient and the CPG itself may focus more on inpatient also. For example parenteral to oral conversions.
Applying Antibiotic Stewardship Standards
In conclusion, you want to be able to credibly state that the ASP program applies to the entire organization, but because the organization is focused on the most important clinical and financial impact issues, it has an inpatient emphasis. However, educational guidance and training is house wide.
Patton Healthcare Consulting
Patton Healthcare Consulting provides a complete range of Joint Commission and CMS Compliance Assistance and a full range of pre-survey and post survey services.
We serve more than 350 hospitals, behavioral health care organizations, ambulatory clinics and home care companies nationwide—hospitals ranging from critical access hospitals to the largest health systems. Contact us at (888) PHC-INC1 for more information.
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