CMS regulations for Antimicrobial Stewardship Programs


The Centers for Medicare and Medicaid Services (CMS) now require unified and integrated implementation of an antimicrobial stewardship program (ASP) as a condition of participation. This integrated approach is necessary to help further reduce inappropriate antibiotic use and antimicrobial resistance for both acute care and critical access hospitals.

What must hospitals do to comply?

    1. Document the facility wide evidence-based use of antibiotics using accepted national guidelines in all departments and services of the hospital.
    2. Demonstrate sustained improvements in proper antibiotic use in all departments and services of the hospital.
    3. Detail all ASP activities and continuously use local data to evaluate the success of the program.
    4. Provide ongoing training of hospital staff regarding proper antimicrobial use.
    5. Coordinate efforts with other relevant hospital groups including medical nursing and pharmacy leadership, Quality Assurance and Performance Improvement (QAPI) program, and Infection Prevention and Control (IPC).

What does this mean?

  • Fortunately, CMS kept “intentionally built flexibility” into the revised regulations and does not mandate adherence to one specific guideline or set of guidelines regarding ASPs. This flexibility allows individual hospitals to customize workflows and approaches to fit their unique needs and allocation of resources, and routinely adapt policies and procedures to coordinate with published updates to these references.

What are some examples of ways hospitals can demonstrate compliance?

  • Successful ASPs rely heavily on data and metrics to drive location actions, monitor progress, and identify areas of need.
    1. Take Action on interventions and initiatives to improve antimicrobial use and provide ongoing Education to hospital staff on proper use and evidence-based guideline updates. Interventions can be broad, pharmacy-driven, and/or syndrome-specific.
    2. Document the use of antibiotics in all departments (i.e., Tracking).
    3. Demonstrate improvements in antimicrobial use by Reporting ASP metrics in a meaningful way. Common ASP metrics include:
      • Antimicrobial usage in days of therapy per 1,000 patient days or days present
      • Process outcomes (e.g., intervention acceptance rates, criteria or guideline compliance, time to optimal therapy)
      • Clinical patient outcomes (e.g., syndrome-specific goals, effects on CDI rates and antibiotic resistance)
  • ASPs, IPC, and QAPI often share some common, overarching goals of reducing antibiotic resistance and side effects such as CDI; the strategies employed to get there, however, are different. Having an ASP leader who can work with these departments and hospital administration to identify 1-2 common goals for each year can help all departments focus on specific problems to find and coordinate initiatives to solve for them. For example, a focus on reducing hospital-acquired CDI cases can include coordinated interventions between IPC, environmental services, and an ASP focus on reducing the use of high-risk antimicrobial agents.

ID Connect Services & Solutions

There are many challenges and complexities to developing, implementing, and maintaining an antimicrobial stewardship program. Hospitals and health systems do not have to do it alone. ID Connect offers a full suite of services and software solutions to help that can range from evaluation of a current program to a daily-integrated approach between local ASPs or pharmacists and our team of experts.

Contact us to assess your current efforts and learn how we can help your facility comply with ASP regulations.


Resources: Best practices and guidelines for ASP

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