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CMS Accepts AARC Position Statement

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August 18, 2009

The AARC Government Affairs staff has finally obtained closure on an issue that has plagued us since development of AARC’s position statement on Inhaled Medication Administration Schedules last year.

We continue to hear from our members, particularly in North Carolina, that state surveyors including the Joint Commission, will not accept AARC’s position statement unless CMS puts something in writing.

It has been CMS’ longstanding policy that the agency does not put in writing its acceptance of a position statement or clinical practice guideline every time a nationally recognized organization develops one because to do so would create an administrative burden and staff resources are insufficient to handle such a policy.  So the AARC’s Government Affairs team asked if CMS would confirm our understanding of what we believed their position to be.

We are pleased to report that we finally have something in writing that our members can take to their hospital departments to show CMS support for the AARC’s position when state surveyors or the Joint Commission conduct their surveys.

“CMS has reviewed and discussed the AARC promulgated standard of practice for a timeframe for the administration of inhaled medications for the purpose of establishing whether an inhaled medication administered by RT is administered `as ordered by the physician’. One component of administering medication `in accordance with the physician’s order,’ is to administer the medication at the ordered time. CMS has advised the AARC that we agree that the timeframes established in their National Standard of Practice for the Administration of Inhaled Medications by RT would be acceptable for determining that a medication had been administered in accordance with the physician’s order, as related to the timeframe component. Of course, a hospital’s Medical Staff would have to first determine that they wished to implement this Standard of Practice, rather than adhere to the 30 minute before and after timeframe established in the hospital guidelines  for 42 CFR 482.23(c). Such a standard of practice would then need to be implemented in hospital policy and practice.”

If a hospital implements a written policy approved by its medical staff based on the AARC position statement, CMS staff advises the hospital to have a copy of the statement on file as verification that its policies are consistent with the RT standard of practice for the delivery of inhaled medications. This will assist surveyors when they review a hospital’s written policy on this issue.

We hope this will put to rest once and for all the problems that have resulted from the confusion over CMS’ acceptance of the AARC’s position statement.