The Centers of Medicare and Medicaid Services (CMS) updated regulations and standards that apply specifically to Ambulatory Surgical Centers (ASCs) in 2009. Specifically these regulations mandated new standards relating to infection prevention/control. All ASCs are now required to have a comprehensive and appropriately monitored infection prevention/control program in place. We discussed and explained the specific components of these new infection prevention/ control requirements for ASCs in one of our monthly newsletters last year.
CMS now requires all ASCs to develop programs that:
- Provide a sanitary environment for surgical services
- Are based on nationally recognized infection control guidelines
- Are directed by a designated health care professional with training in infection control
- Are integrated into each ASC’s Quality Assessment and Performance Improvement Program
- Include actions to prevent, identify and manage infections
- Include a mechanism to “immediately implement corrective actions and preventive measures that improve the control of infection within the ASC”
While some of these requirements were unlikely to necessitate changes in practice for ASC’s (e.g. “providing a sanitary environment”), other requirements have forced most ASCs to increase the scope of their existing infection prevention/control programs. For example, the new CMS requirement to “identify infections” obviously means that all ASCs must implement a working surveillance system for surgical site infections (SSI) if one is not already in place. Such surveillance in ASC facilities, by definition, means post-discharge surveillance —a process that has proven difficult and sometimes impossible for many acute care hospitals in the United States. Post-discharge surveillance can be achieved in ASCs associated with acute care hospitals by monitoring the readmissions of patients recently discharged from the ASC. However, “free-standing” ASC’s (i.e. those not associated with acute-care hospitals) face a much larger hurdle as post-discharge surveillance systems need to be designed to detect the small percentage of patients who develop SSIs among the large number of patients who undergo surgical procedures in their facility.
The new CMS regulations require ASCs to expand and update their existing infection prevention/control programs.
- Infection prevention/control programs at ASCs must now include surveillance systems to detect cases of SSI,
- Systems to monitor staff compliance with infection control policies, and
- Systems to insure appropriate ongoing training in infection prevention/control for all staff.
Free-standing ASCs that do not come under the umbrella of the infection prevention/control program of an acute care hospital will face significant challenges in meeting the mandates of these new regulations. The administration of many, if not all ASCs, will have to invest additional resources into their infection prevention/control programs. Such an investment however is likely to improve the quality of care provided for surgical patients and ultimately they will enhance the reputation of each ASC that rises to these challenges.