Preparing for AUR Reporting Mandates to Capitalize on Quality Reimbursement

photo credit: Pexels/Tom Fisk

Antibiotics have been a crucial tool in modern medicine, but their overuse has led to widespread antibiotic resistance, threatening the ability to treat bacterial infections. Hospitals are one of the largest consumers of antibiotics, and their misuse can have severe consequences for public health. As hospitals continue to grapple with the COVID-19 pandemic, overprescription of antibiotics empirically or for secondary infections has been a concern.

While hospitals weren’t required to share metrics on their antibiotic use in the past, in January 2024, the Centers for Medicare & Medicaid Services (CMS) will compel participating hospitals to report their Antimicrobial Use and Resistance (AUR) data to the National Healthcare Safety Network (NHSN) through the Promoting Interoperability program.

This AUR data will be specifically required to satisfy the Public Health and Clinical Data Exchange objective, and if hospitals don’t comply, they risk a 75% reduction in the annual scheduled increase in reimbursement, with critical access hospitals facing a 1% reduction in their Medicare payment reimbursements for non-compliance.

This will have far-reaching impacts on antimicrobial prescribing in hospitals, but there are things hospitals can do today to get ahead of this reporting requirement and ensure they are prepared for the upcoming mandate.

Current State of Antimicrobial Prescribing in Hospitals
The COVID-19 pandemic has caused significant disruptions to healthcare systems worldwide, and the impact on antimicrobial prescribing in hospitals has been significant. It is hard to determine the current state of antimicrobial prescribing as data reporting lags and while the community impact of COVID has diminished, there is still a significant burden on hospitals when patients are admitted. It is still early to tell if the pandemic has changed prescribing patterns but with a current seven-day average for new COVID-19 hospital admissions around 1800 patients, it’s expected that antimicrobial use is still on the rise.

During the pandemic, healthcare providers may have prescribed empiric antibiotics to patients with COVID-19 symptoms, despite knowing that antibiotics do not treat the virus while diagnostic testing is in progress. Furthermore, critically ill COVID-19 patients may have developed secondary bacterial infections, leading to higher antibiotic use in hospitals. Therefore, monitoring and reporting antibiotic use and resistance data in hospitals has become crucial to manage the current pandemic and future public health crises.

Current State of Hospitals' AUR Data Reporting
While the CMS mandate doesn’t go into effect for another six months, it’s important for pharmacy leaders to know where their hospital currently stands on its compliance. The majority of states still have less than 50% of their hospitals’ reporting data, and smaller community hospitals are lagging behind.

Fortunately, the new requirement is just to demonstrate that hospitals are capturing the data and reporting it, without pushing them to reach a specific threshold of prescribing patterns or resistance. Instead, the goal is to make the national database for antibiotic usage more complete.

Reporting antibiotic use and antibiotic resistance data to the National Healthcare Safety Network (NHSN) enables the CDC to better understand and benchmark antimicrobial use in the nation’s hospitals, track and identify potential antimicrobial resistance emergence, and drive national progress on minimizing antimicrobial resistance. Hospitals that are currently reporting are likely more IT-resourced, academic medical centers, and it is hard to say if resource-limited hospitals are using more or fewer antibiotics than larger hospitals without visibility into this data.

Further complicating the upcoming reporting mandates, Wolters Kluwer ran a poll during a recent webinar and found that approximately 70% of attendees were unaware of the upcoming mandate for AUR data reporting. Finance departments might be aware to see what the requirements look like for reimbursement purposes, but they need to connect with directors of pharmacy to ensure the data collection processes are taking place on the clinical side. And this data integration can’t wait – hospitals must start preparing now to avoid financial penalties that may result from not reporting this data.

Preparing for the Upcoming Mandate
Many pharmacy teams will attempt to gather and submit this data themselves, but the complex reporting and submission process makes this difficult. To avoid financial penalties, hospitals should make sure that their electronic health record (EHR) is set up to collect this antibiotic use and resistance data. Hospitals should aim to have barcoded medication administration in as many patient care areas as possible, as paper charting can cause problems and inaccurate reporting.

Collaboration with hospital IT teams is essential to capture this information across the hospital—particularly in procedural areas such as when antibiotics are given before surgery or biopsy. While hospitals as a whole have embraced more automated medication tracking, non-bedded areas such as OR suites and procedure rooms have been delayed in their use of barcoded medication systems. However, the benefits can extend far beyond antibiotics, as they can also track opioids use, misuse, and diversion.

The latest mandate also requires hospitals to use ONC-certified technology. Pharmacy leaders should be having conversations with their IT teams to ensure they have the right tool in place to capture the data, and report that information to the National Healthcare Safety Network (NHSN). Only some EHR products for AUR reporting are certified, and hospitals may have to pay for additional models to achieve this. External vendors that are already ONC-certified and have a proven workflow to report to NHSN and capture updates from the organization may lower the IT burden on internal teams as they navigate this transition.

How Automation can Support the Transition
On the role of automation in managing antibiotic use reporting in the hospital, there are two things that hospitals must report: antibiotic use and where the patients are located in the hospital. For antibiotic use, hospitals may leverage machine learning (ML) to extract the medication administration data, mapping to the relevant generic drug entity, and calculating the total duration of use. For antimicrobial resistance reporting, automation can help identify microbiology data that would qualify for reporting to NHSN and transform the culture and susceptibilities data from the EHR to the proper species and resistance phenotypes for submission purposes. Analytics tools can use this information to provide a comprehensive view of the hospital's antimicrobial usage, including early identification of outbreaks, development of resistance patterns, and evaluation of appropriateness of drug usage.

Automation also saves the pharmacy staff valuable time as they don’t need to reprioritize their workload to accommodate this new reporting, but instead can have technology capturing data in the background and translating it to the proper format for NHSN automatically. This helps hospitals to be compliant without placing undue burden on pharmacy teams to capture these insights.

Reporting this information also lets hospitals evaluate their standardized antimicrobial administration ratio (SAAR), allowing them to compare their antimicrobial use to peer hospitals and understand how they measure up. As the database currently does not include every hospital in the US, more comprehensive reporting requirements ultimately will motivate more hospitals to participate, and lead to more accurate benchmarking—and where more stewardship may be needed to support appropriate prescribing.

In conclusion, the mandatory reporting of AUR by hospitals participating in the CMS Medicare Promoting Interoperability Program beginning in January 2024 is a significant step in curbing the overuse of antibiotics and the rise of superbugs. However, hospitals need to start preparing now to track and report their antibiotic use and resistance data to avoid financial penalties. To achieve this, they need to collaborate with their IT teams and leverage technology-based approaches, such as automated medication tracking and the use of external ONC-certified vendors, to manage antibiotic use.