Antimicrobial resistance is one of the biggest threats to public health. In fact, there are an estimated 2.8 million infections and more than 35,000 deaths1 annually in the United States which are attributed to antimicrobial-resistant organisms1. To ultimately combat this threat, it is essential for healthcare organizations to record their antimicrobial use and resistance patterns within their facilities and across the communities they serve.
To encourage this tracking, the Centers for Medicare and Medicaid Services (CMS) have introduced significant changes to their antibiotic use and resistance reporting requirements in 2024 that will affect virtually every hospital and healthcare system in the United States. If your hospital or healthcare system is unfamiliar or only partially aware of the new mandatory reporting requirements established by the National Healthcare Safety Network (NHSN), this is a critical time to learn more about reporting data to the Antimicrobial Use and Resistance (AUR) Module in the NHSN, as required data collection starts on January 1, 2024.
“CMS has enshrined the NHSN AUR Module reporting in its promoting interoperability program requirements. This is an incredibly important moment for antimicrobial stewardship nationwide because it elevates the standard of practice for data reporting, resistance surveillance, and antibiotic consumption tracking,” says Matthew Davis, PharmD, Director of Infectious Diseases Pharmacy Services at ID Connect, who consults with ID Connect’s hospital clients on the processes, procedures, and data requirements needed to comply with AUR Module reporting.
“It is both a simple and complex task,” says Davis. “It’s simple in that what CMS requires is straightforward from a data perspective, but each hospital or healthcare system is unique in its structure and how it will need to implement the necessary processes to meet the compliance mandate. It’s a multidisciplinary process that must be coordinated across departments – pharmacy, microbiology, infection prevention, information technology, administration – and will also likely require the involvement of a hospital’s vendor partners. And it takes time, so if you haven’t started yet, now is the time to dig in.”
What is the National Healthcare Safety Network (NHSN) Antimicrobial Use and Resistance (AUR) Module?
The NHSN is a surveillance system managed by the Centers for Disease Control and Prevention (CDC). It was created in 2011 and its primary goal is to provide data that helps healthcare facilities identify areas for improvement, track the progress of infection prevention efforts, and ultimately reduce healthcare-associated infections. NHSN achieves these objectives by collecting standardized data that is directly associated with device-associated infections, procedure-associated infections, and antibiotic use and resistance.
The AUR Module will specifically collect data on the use of antimicrobial agents, including antibiotics, antifungals, and antivirals, and tracks resistance patterns among different pathogens. Facilities can review and analyze their own AUR data and compare their AUR metrics against sets of Standardized Antimicrobial Administrative Ratio benchmarks to help them make informed decisions about antimicrobial prescribing, identify areas for improvement, and implement effective interventions to reduce any overuse of antimicrobials intended to prevent the spread of antimicrobial-resistant infections. Additionally, the Standardized Resistant Infection Ratio can be used by facilities to compare their rates of hospital-onset resistant infections to national benchmarks. Contribution to and use of the AUR information also aims to improve hospitals’ antimicrobial stewardship programs by identifying antibiotic use “hot spots” and generating more information that can be used to construct public health policies that more effectively address the rapidly expanding population of multi-drug resistant pathogens.
How Has CMS Changed the Rules Around AUR Data Reporting?
Beginning in January 2024, AUR Module reporting will be mandatory for all eligible acute care hospitals and critical access hospitals. Only those hospitals with approved hardship exceptions will get more time to comply. Eligible acute care hospitals may submit hardship applications through July 31, 2023, and critical access hospitals have until September 30, 2023.
When hospitals and healthcare systems use the AUR Module in the NHSN for reporting their antimicrobial use and resistance data, they also contribute to one of the five different Public Health and Clinical Data Exchange objectives:
- Syndromic Surveillance Rep
- Immunization Registry Reporting
- Electronic Case Reporting
- Electronic Reportable Laboratory Result Reporting
- Antimicrobial Use and Resistance (AUR) Surveillance
What Data is Specifically Required and How Must it Be Reported in the AUR Module?
Think of the module as having two separate but related data class requirements – antibiotic use and antibiotic resistance information. In its simplest form:
Antibiotic use involves reporting antimicrobial administrations for required antimicrobial agents that are dispensed at a healthcare facility. The data collected includes the drug name, administration route, dose, patient location, and the day it was administered. Data is typically submitted as a summary report, which includes all antibiotics administered during a calendar month.
Example: Documentation of giving levofloxacin 750 mg intravenously over four days to a patient cared for in a general medical ward from 6/14/23- 6/17/23.
Resistance data includes reporting positive culture data for bacterial isolates found in clinical cultures tested for susceptibility at a healthcare facility.
Example: Evidence of methicillin-resistant Staphylococcus aureus found in a blood culture that was isolated from an admitted patient in a surgical ward on 4/12/23.
As hospital and vendor teams start building their reporting capabilities, they can refer to the CDC’s comprehensive protocol document that parses out the data and reporting requirements for each module. Under the CDC NHSN requirements, healthcare facilities reporting AUR Module data cannot manually upload their information. Every facility must use NHSN-validated software for reporting. Whether they choose to use third-party or home-grown software, AUR Module reporting software must be compliant with the Clinical Data Architecture (CDA) Release 2 (RD) standard. Facilities can also visit the NHSN CDA Submission Support Portal (CSSP) to learn more about the requirements, data validation, testing, and tools needed for software validation.
What Resources Should a Healthcare Facility Expect to Need for Implementation and Ongoing Management?
ID Connect’s Director of Infectious Diseases Pharmacy Services, Matthew Davis, PharmD, explains, “Facilities should plan on significant investments of time in both the building and implementation of the reporting processes, and then for the ongoing maintenance and support required to report the data longitudinally.”
Davis also believes that the time frames for implementing NSHN AUR Module submissions will vary widely from facility to facility, especially since the data feeding the new AUR reports needs to be identified and gathered from multiple systems and/or facilities. It also needs to be validated and synthesized into meaningful and accurate reports that fit into the CDC’s reporting architecture. At some hospitals, this may only take a few weeks and at others it could take more than six months. Therefore, Davis stresses the importance of identifying required NSHN AUR Module resources, team members, cross-departmental, and vendor coordination processes sooner rather than later.
While ongoing support for NHSN AUR Module reporting will typically be less resource intensive than the initial build, continuing support needs are still substantial. For example, periodic testing, data quality reviews, and making system updates to account for future NHSN, CMS, or your hospital’s own electronic medical record changes will still require time, focus, and specialized knowledge.
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