In my previous blog post, I covered the regulatory requirements for Antibiotic Stewardship Programs set forth by the Centers for Medicare and Medicaid Services and briefly discussed in the Centers for Disease Control and Prevention’s Core Elements for Antibiotic Stewardship in the Nursing Home. In this blog post, I will cover some of the August 29, 2017, updates by CMS to the Long Term Care Survey Pathway that address the new F-Tag 881 – Antibiotic Stewardship Programs.  

  • Utilizing the survey pathway, surveyors will be assessing programs for:
  • Written antibiotic use protocols
  • Protocols to review clinical signs, symptoms, and laboratory reports
  • A process for periodic review of antibiotic use by prescribers
  • Protocols to optimize the treatment of infections
  • A system for provision of feedback on antibiotic use, outcomes, and prescribing practices


These elements, while broad, offer the opportunity to design a program to meet the regulatory needs of the Final Rule while taking into account the resources available at your facility. Remember, there is no one way to implement an Antibiotic Stewardship Program; the program will be specific to each facility.  

Most Antibiotic Stewardship Programs will start small and grow in a step-wise fashion as further policies, procedures, and interventions are implemented.

One of the easiest and most effective first steps to take when developing your program is to implement an antibiotic prescribing policy. Ideally, this policy would outline the decision-making process that your facility’s prescribers would follow prior to writing an order for an antibiotic and delineate the documentation required, such as rationale, indication, dosage, duration, etc.  Standardized documentation and communication templates, if available, can also be utilized to promote adherence to your antibiotic prescribing policy amongst both nursing staff and prescribers.

This policy could also incorporate the use of facility-specific resident assessment, diagnostic testing, and infection-specific treatment algorithms while serving the dual purpose of also optimizing the treatment of infections, another component surveyors will be assessing. The algorithms can be developed from national guidelines published by well-known infectious disease organizations such as the IDSA and SHEA but further refined by applying an antibiotic resistance tool known as an antibiogram.

An antibiogram is a summary of culture and sensitivity reports for a specific region, facility, or other locality. Its primary purpose is to aid clinicians in selecting appropriate initial empiric antibiotic therapy based upon local bacterial resistance patterns while culture and sensitivity results are pending. They can often be obtained from your laboratory provider or a local hospital and are commonly updated on a biannual basis.

Ready, Set, Go!

My next blog will focus on the additional components of the survey pathway related to surveillance and feedback that can augment your efforts in establishing an effective Antibiotic Stewardship Program by November 28, 2017.

Sonja Quale, Pharm.D. is the vice president and chief clinical officer at PharMerica Corporation.