The ASC leaders reaffirmed their commitment to patient safety and found much to agree on in the report. “We agree that surveillance of HAIs across surgical settings is important,” the letter stated. “Information on HAIs should be transparent and available to providers for quality improvement and to the public. We agree that measures from the Surgical Care Improvement Project and the NQF serious reportable events sets should be considered and encourage the Workgroup to identify which of the measures are applicable to ASCs.”
However, the letter made some specific comments on several of the workgroup’s proposals, called “candidate measures” because they are still in their early stages. The following is a summary of each HHS proposal and some highlights of the industry representatives’ response.
By Dec. 31, 2013, ASCs must have a surveillance system for procedure-related adverse events, including surveillance for all patients for at least 30 days after discharge.
Industry response: Surveillance efforts should include a range of high-volume procedures across ASC surgical specialties and develop a reliable measurement of the incidence of HAIs related to care provided in ASCs. Surveillance of ambulatory patients presents challenges. More research is needed on what method works best. For example, surveying the performing surgeon to determine patient outcomes after discharge can be effective but this approach is resource-intensive and may not capture all SSIs. The costs of surveillance should not exceed the potential impact of this measure on public health.
By Dec. 31, 2013, ASCs must demonstrate 100 percent adherence to measures in the infection control worksheet.
Industry response: Use of the worksheet should be promoted in other settings besides ASCs “to encourage a focus on best practices across surgical settings and also to allow for meaningful comparisons across settings.” Based on the experience of other healthcare providers, it is advisable to set “attainable milestones and goals for adherence.” Milestones should acknowledge substantial improvements towards the goal and attainment of the highest standards.
By Dec. 31, 2015, all ASCs must report surveillance data in standardized formats to patient safety organizations and the National Healthcare Safety Network.
Industry response: PSOs may not have the capacity to deal with this information. Fewer than 90 PSOs are currently in operation in less than one-third of the states and they already have a great deal of work to do assisting hospitals, physicians and other providers on a wide range of safety issues. Furthermore, enrolling and participating in this program can be “very challenging” because most ASCs do not have access to an IT support department. Also, reporting the same information to multiple entities is “counter-productive.”
By Dec. 31, 2015, ASCs must demonstrate 100 percent adherence to Surgical Care Improvement Project and the National Quality Forum infection process measures, such as perioperative antibiotics, hair removal, postoperative glucose control, normothermia.
Industry response: ASC-specific measures that have been harmonized with SCIP measures are “the most appropriate for measuring performance in the ASC setting.” With the endorsement of the National Quality Forum, the ASC industry has voluntarily begun measuring two quality indicators: timely administration of prophylactic intravenous antibiotics and appropriate surgical site hair removal. The ASC industry has reviewed two other indicators from the SCIP set mentioned by the workgroup: post-operative glucose control and normothermia.
By Dec. 31, 2015, ASCs must achieve zero incidence of “never events” as defined by the National Quality Forum.
Industry response: Most serious reportable events, such as patient abductions and patient suicides, are not relevant to HAIs. And other measures, such as Stage 3 or 4 pressure ulcers acquired after admission to a healthcare facility, are not relevant to ASCs due to the short duration of the patient’s visit.
By Dec. 31, 2015, and within two years of NQF endorsement, all ASCs must have implemented any new applicable HAI-related measures.
Industry response: There should be a system of notice and rulemaking to give all the stakeholders an opportunity to review, comment-upon and improve quality measures.
By Dec. 31, 2015, all ASCs must have a certified infection preventionist on staff or contract with one for services.
Industry response: The industry generally supports such training but requiring specific certification is too limiting. Even in the more complex setting in the hospital, there are no specific requirements for certification of this work.
Overall concerns
As the HHS workgroup develops its recommendations, the ASC groups urged it to:
- Build on current activities of the ASC industry and others.
- Build a foundation of research to support an evidence-based plan.
- Work to create transparency across surgical settings.
- Incentivize providers to make investments that will reduce HAIs.
- Consider how the measures align with industry needs and capabilities to ensure their effectiveness.
Read the ASC groups’ letter to HHS about infection control measures (pdf).
View an outline of the HHS workgroup’s proposals for ASC measures for HAI prevention (pdf).
