Under regulations from the U.S. Centers for Medicare & Medicaid Services (CMS), reporting antibiotic use and resistance data will become mandatory (for virtually all acute care and critical access hospitals) on January 1, 2024. To comply with the new requirements, healthcare facilities will need a great deal of preparation, planning, and execution resources to report their data through the National Healthcare Safety Network (NHSN) Antimicrobial Use and Resistance (AUR) Module.
As your hospital or healthcare system decides where NHSH AUR Module reporting falls on its priority list, it’s important to understand all the risks at stake when facilities aren’t collecting and reporting their antimicrobial use and resistance data.
Since compliance with these new CMS reporting mandates can be complex and challenging, it’s important to remember this newest AUR Module initiative was specifically put in place to help fight the global spread of antibiotic-resistant organisms and create more optimized, evidence-based approaches to antimicrobial stewardship programs (ASP). It is also helpful to fully understand the penalties and consequences of missing the January 1, 2024 NHSN AUR Module reporting deadline. This article outlines the potential CMS reimbursement impact, the reputational risks, and patient safety issues that could befall facilities that inadequately build new action plans and end up with suboptimal NHSN AUR Module reporting.
Risks and Penalties of Noncompliance: The Financial Outlook
When hospitals and healthcare systems use the NHSN AUR Module for reporting their antimicrobial use and resistance data, they can fulfill one of the five components contained in the Public Health and Clinical Data Exchange Objective:
- Syndromic Surveillance Reporting
- Immunization Registry Reporting
- Electronic Case Reporting
- Electronic Reportable Laboratory Result Reporting
- AUR Surveillance
Meeting all five components gives facilities a total of 25 points toward their EHR reporting score. Healthcare facilities need at least 60 points on the EHR score to avoid a downward payment adjustment, and successful NHSN AUR Module data reporting contributes 41.6% points needed for a complete EHR reporting score. While other reporting elements also contribute to this EHR score, reporting antimicrobial data via the AUR Module allows facilities to claim five bonus points for sharing their AUR data with a local or state public health registry.
Facilities that fail to report NHSN AUR Module data cannot earn the full credits available under the Public Health Objective of the CMS Medicare Promoting Interoperability Program (PIP). Acute care hospitals and healthcare systems that don’t fulfill their PIP requirements and fail to report their AUR data risk seeing a reduction in the percentage of their annual increase in Medicare reimbursements from CMS for the fiscal year in which their AUR data should have been reported. And, for critical access hospitals, the financial penalties could include a 1% reduction in total their total Medicare reimbursement.
Financial Impact Example
If you’re wondering how or to what extent the financial penalties for not complying with AUR Module reporting could play out, here’s an example to clarify the picture.
Consider a healthcare facility with a base payment figure of $7,000 per case and an average Diagnosis Related Group Code (DRG) weight adjustment factor of 1.0
If the hospital has 1,000 patient discharges per year, and an annual CMS payment increase of 2.8%, which is then reduced to a 0.7% increase following the negative payment adjustment for non-AUR reporting, the total potential reduction in reimbursement would equal $147,000 that fiscal year.
It’s not hard to see how the total Medicare reduction amount could increase with more patient discharges.
Risking Your Healthcare’s Commitment to Quality and Patient Safety Reputation
Aside from the financial penalties that a hospital or healthcare system might incur for not submitting new AUR reports, the reports themselves provide hospitals with a standardized process for understanding antibiotic prescribing practices and usage patterns relative to comparable institutions. By not reporting AUR data, a hospital or healthcare facility will be unable to access and use the global data captured in the NHSN AUR Module thereby limiting the information and guidance they can access to improve their antimicrobial use and stewardship. With these national benchmarks, individual sites can more readily learn about emerging antimicrobial use and resistance patterns that could improve their own patient care protocols and guidelines. Additionally, when hospitals contribute data to global antimicrobial resistance surveillance studies, best practices develop more quickly, and microorganism containment and elimination efforts also improve.
While it may not occur immediately, there are potential reputational risks that could come about for facilities that fail to report their AUR Module data. Consider this hypothetical headline: “Our Local Hospital is Not Reporting Required Antibiotic Use and Resistance Data to CMS.” While this type of publicity may be a stretch, it’s not out of the question. ID prevention and infection control have become increasingly more important since the Covid-19 pandemic. Community groups have a heightened awareness of what public health “short cuts” can mean and are more willing to hold businesses, in this case hospitals, accountable for their actions and non-actions. The reaction can often be, “What are they hiding and what don’t they want us to know about?”
Finally, with elected officials and members of the press placing a greater focus on healthcare transparency, there is increased skepticism when businesses choose not to or fail to report mandatory information to regulatory agencies.
Doing everything possible to stop the spread and development of antimicrobial organisms while simultaneously working to devise concrete, rational, evidence-based use of antimicrobial agents to improve patient care is something that a hospital would likely want to be known for. Hopefully, reporting AUR Module data is seen as proactive, responsible imperative, not a burden, and a concrete way to help ensure we don’t regress to the modern-day equivalent of living in a world without penicillin and do make a commitment to develop new essential antibiotics for treating future pathogens.
Bonus for Facilities Reporting NHSN AUR Module Data
The Joint Commission (TJC) also has new antimicrobial stewardship standards that require facilities to report antimicrobial use data in standardized units, i.e., days of therapy per 1,000 patient days. By including antimicrobial stewardship measures as one of their elements of performance for an accreditation review, facilities that are ready to report NHSN AUR Module data can address TJC accreditation requirements at the same time – without additional resources or costs.
Have Questions About the Impending NHSN AUR Module Requirements or Your Organizational Readiness for Compliance?
If you’re not sure if your hospital or healthcare system is ready to comply, or if you’re just starting to navigate the new AUR Module reporting rules and have questions, we encourage you to get in touch with the antimicrobial stewardship experts at Infectious Disease Connect.
Our dedication to ID and the delivery of tele-ID services offers healthcare organizations a high-quality, cost-effective way to address the problems created by the severe shortage of ID physicians and pharmacists. Our virtual services help hospitals assess comprehensive ID needs, answer questions, and provide consultation resources for to physicians, pharmacists, and patients. Our ID and antimicrobial stewardship experts are the perfect partners to help you deliver the new and mandatory NHSN AUR Module reporting, thereby allowing your own staff the time they need to address your hospital’s other accreditation and compliance requirements.
Contact firstname.lastname@example.org to get started.