Ambulatory Surgery Center industry responds to infection control concerns raised in JAMA

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ASCs Champion Industry-wide Commitment to Delivering Quality Outpatient Care

As leading organizations representing the Ambulatory Surgery Center (ASC) industry, we wish to address concerns raised in this month's issue of the Journal of the American Medical Association (JAMA) highlighting data from a 2008 Centers for Medicare and Medicaid Services (CMS) pilot study. The industry underscores its strong commitment to patient safety and its nationwide efforts to provide high-quality, patient-centered care at a low cost to the health care system.

"As an integral member of the health care system, ASCs are committed to providing the highest quality care in the safest environment possible for our patients," said Kathy Bryant, President of the Ambulatory Surgery Center Association. "Improving infection control practices is a significant matter facing all health care settings. All health care providers strive toward 100 percent compliance with infection control standards, and this report highlights that we must continue to work diligently toward improved performance."

First released in early 2009, findings from a pilot study evaluating infection control practices in a limited sample of ASC facilities found that some ASCs were not in compliance with infection control practices prescribed by CMS. As the authors noted, the agency revised the Medicare Conditions for Coverage to increase the focus on infection control practices for ASCs in early 2009. Since the process lapses were identified, the ASC industry has engaged in a proactive educational effort with ASCs across the country to promote adherence to the new standards.   These efforts, along with the compliance required by the 2009 revision of the ASC Conditions for Coverage have addressed many of the issues raised in the pilot study. This study highlights the need for all levels of industry and government to be engaged in educating ASCs about these standards.

"The industry takes this report seriously, and since the release of the findings from the pilot study in 2009, we have worked with CMS, accrediting bodies, state ASC associations, medical and nursing professional organizations, and leaders in quality measurement to address concerns quickly and effectively," said Andrew Hayek, Chair of the Ambulatory Surgery Center Advocacy Committee and President and Chief Executive Officer of Surgical Care Affiliates. "We will continue to work actively with CMS and our industry counterparts to ensure broad understanding and implementation of CMS's infection control standards in order to improve compliance."

"The ASC Association and ASC Advocacy Committee embrace the use of the infection control audit tool developed by the Centers for Disease Control and Prevention (CDC), which CMS has made available," Hayek continued. "The industry has implemented voluntary reporting standards and has called on CMS to implement a system for nationwide quality reporting for ASCs and for the entire health care delivery system using comparable data so patients are able to make informed decisions about where to receive their health care."

"Data show that we have low rates of complications and infections related to procedures performed in our thousands of facilities across the country, and ASC quality and safety are regulated by several rigorous, independent processes -- including Medicare certification, state licensure and voluntary accreditation," said David Shapiro M.D., Chair of the Ambulatory Surgery Center Association and a Partner at the Ambulatory Surgery Company. "We successfully treat tens of thousands of Americans every day, and as the data demonstrate, we have a proven track record of outstanding surgical care and patient satisfaction."

As an independent initiative to promote quality and safety measures for the ASC industry, the ASC Quality Collaboration has been working since 2006 to develop quality measures appropriate for the industry, which have been recognized and endorsed by the National Quality Forum. Recently, the Quality Collaboration released the first in a series of educational toolkits aimed at helping facilities address and exceed infection control standards. The first toolkit is focused on increasing appropriate hand hygiene practices and has been made available to ASCs throughout the country.

The Quality Collaboration collects quarterly data evaluating the quality of care being delivered in ASCs. Data aggregated from the most recent ASC Quality Collaboration 2009 Fourth Quarter Report shows that ASCs have low rates of medical error and few complications related to common procedures performed in the outpatient setting. The ASC Quality Collaboration will continue to analyze data from ASC facilities quarterly. Similarly, the ASC Association collected national survey results through its Outcomes Monitoring Project from more than 650 ASCs, which routinely shows that 80 percent of ASCs report fewer than 1.5 post-surgical wound infections per 1,000 patients encountered.

While the study authors acknowledge limitations with the research, they do not provide comparative data across multiple health care settings including hospitals, long-term care facilities and primary care settings. For example, while the tracer methodology used by CMS in the ASC surveys is often used in other settings, CMS has not created a comparable infection control surveyor worksheet for any other health care provider-type it surveys. The research cites ASCs' noncompliance rate for appropriate hand hygiene at 19 percent; however, when compared across other health care settings, including hospitals, the national average noncompliance rate as reported in the American Journal of Infection Control is estimated to be close to 50 percent, indicating a broader issue not limited to the ASC setting.

For several years, ASC industry leaders have encouraged CMS to implement a nationwide quality reporting system for ASCs as permitted by the Tax Relief and Health Care Act of 2006 (PL 109-432).  In addition, the industry has urged the government to create and implement measures that allow for comparison of performance across different types of facilities providing comparable services. Presenting information in facility-specific silos fails to provide meaningful information for patients and providers in making decisions about where to receive surgical care.  

"As the study authors note, significant surgical volume has shifted to the ASC setting over recent decades," added Dr. Shapiro. "We know that medical innovation and clinical advancements are driving this evolution in health care delivery allowing ASCs to provide high-quality, cost-effective surgical care to patients across the country."

The ASC Advocacy Committee and the ASC Association remain committed to improving infection control practices across the entire health sector and promoting quality and safety measures at ASCs nationwide.

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