As the 2024 mandate for Antibiotic Use and Resistance (AUR) reporting by the Centers for Medicare and Medicaid Services (CMS) went into effect on January 1st, healthcare systems across the United States are grappling with significant challenges in implementation. With financial risk on the line for non-compliance, there is an urgency for hospitals to align with the reporting guidelines and ensure they’ve captured and successfully transmitted the required amount of data by the end of the first reporting year.
However, the path to compliance isn’t as easy as simply turning on the technology, with hurdles ranging from logistical implementation to technological barriers that hinder data-sharing. As hospitals must have at least 180 continuous days of data reported at the end of this year, platforms must be in place and transmitting data as of July 1st. Teams can no longer wait to adhere to the new reporting mandates if they want to avoid penalties for non-compliance to account for technology and change management obstacles that may hinder this journey.
Understanding the Enforcement Timeline and Penalties
The enforcement timeline for CMS AUR reporting mandates emphasizes the importance of timely action. Hospitals are expected to self-attest to their compliance, but audits may occur. The ramifications of non-compliance are severe, with financial adjustments slated for 2025. Even for those who do understand the urgency of the reporting mandate, many hospitals have questions about how to document this reporting is in place.
The National Healthcare Safety Network (NHSN) plays a pivotal role in providing evidence for compliance, sending monthly reports and summary emails to hospitals. While the NHSN is not expected to share reporting data with CMS, the risk of disqualification from Medicare looms large for hospitals found to be misrepresenting their compliance. And with Medicare dollars on the line, hospitals can’t afford to be caught without the appropriate systems and reporting in place. While right now the only requirement for hospitals is be actively engaged in data submission, it stands to reason that, in the future successful and continuous submission of data is required to satisfy the measure, adding to the urgency of having appropriate monitoring in place today.
Assessing Hospital Preparedness and Primary Challenges
Hospitals vary in their preparedness for AUR reporting, with some leveraging existing systems for compliance they may have had in place before this mandate, such as the Sentri7 Clinical Surveillance platform. If hospitals don’t already have a system in place where they can record their antimicrobial use and resistance rates and communicate those to the NHSN database, they may now face significant hurdles and slowdowns, threatening their ability to capture the required 180 days of data this year.
Primary challenges include system registration and set up, time for Electronic Health Record (EHR) providers to deliver interfaces, and the need to establish a compliance and monitoring process. Hospitals that are late to adopt AUR reporting face delays in data feed provision and the standardization process necessary for submission to NHSN. And because hospitals must now use an ONC-certified technology, home-grown solutions will no longer cut it when it comes to ensuring compliance. Due to the rigor and expense associated with ONC certification and regular changes on data submission requirement, pursuing your own certification is likely not cost effective. Instead, experienced vendors can help facilitate the timely sharing of data to the NHSN record, helping reduce logistical delays.
Disparities in Reporting and Impacts on National Database
Disparities in AUR reporting exist among hospitals of different sizes and resources. Larger hospitals with existing surveillance systems may be better equipped to comply, while resource-limited or smaller hospitals could face a steep learning and implementation curve, depending on the monitoring systems they already have in place. This variability in reporting could undermine the effectiveness of the national database for antibiotic usage, highlighting the need for targeted support and resources for smaller facilities. Collaborative efforts between larger and smaller hospitals, along with regulatory bodies and experienced technology providers, could help bridge these gaps and ensure comprehensive data reporting across the healthcare landscape.
What You Need to Know
Hospitals face significant challenges in implementing AUR reporting mandates due to logistical and technological barriers. Compliance with reporting guidelines is urgent, as hospitals must have at least 180 continuous days of data reported by the end of the first reporting year to avoid penalties.
Disparities exist among hospitals of different sizes and resources in implementing AUR reporting. Larger hospitals with existing surveillance systems may be better equipped to comply, while resource-limited or smaller hospitals face steep learning curves.
Despite challenges, AUR reporting implementation offers significant benefits beyond compliance. It enables data-driven decision-making, benchmarking against national peers, and targeted interventions to improve patient outcomes and reduce healthcare costs.
Upsides and Benefits of AUR Reporting Implementation
Despite the challenges, AUR reporting implementation offers significant benefits beyond compliance. Hospitals can leverage data insights to benchmark against national peers, improve antimicrobial stewardship, and enhance patient management. The integration of technology enables seamless data collection and reporting without compromising patient care or incurring additional financial burdens.
Resource-limited hospitals face unique challenges in implementing AUR reporting technology, but with the right technology partner, have ample time to be successful if they start today. Strategies that have proven effective include targeted support from experienced vendors, streamlined workflows, and leveraging penalty risks to garner organizational buy-in for necessary investments. Additionally, collaborative efforts within the healthcare ecosystem can facilitate knowledge sharing and resource allocation to support hospitals in need. Training programs, state and local grants, and incentives tailored to the specific needs of smaller facilities can help level the playing field and ensure equitable access to AUR reporting resources.
Building on AUR Reporting for Clinical Impact
While AUR reporting is the immediate requirement on the horizon, this mandate can serve as a catalyst for broader improvements in pharmacy services and clinical care delivery. The potential for data-driven decision-making and targeted interventions holds promise for enhancing patient outcomes and reducing healthcare costs in the long run. With an AUR monitoring program that has automatic surveillance in place, healthcare teams also have the data needed to easily tailor therapies and can more readily monitor patients 24/7, even in the absence of round-the-clock pharmacy teams in smaller hospitals.
There are sure to be some bumps in getting the proper systems in place this first year, but the CMS AUR reporting mandates represent a critical step towards enhancing antibiotic stewardship and combating antimicrobial resistance. The potential benefits of increased data availability at national and regional levels are significant. By addressing resource disparities, leveraging technology, and fostering collaboration, the healthcare industry can navigate these challenges effectively and drive meaningful improvements in patient care and public health outcomes. As we move forward, continued efforts to support hospitals in their AUR reporting endeavors will be essential for realizing the full potential of this initiative in safeguarding both individual health and public health at large.
Mok wrote about AUR last year for Contagion and to read that article go here.
