ASN Urges CMS to Delay Pre-Filled Syringe Policy

ASN has urged the Centers for Medicare and Medicaid Services (CMS) Survey and Certification Group to delay implementation and foster dialogue regarding a policy concerning saline syringe filling practices. The policy is set to take effect by Sunday, July 2, 2017.  Addressed to state survey agency directors, the memorandum states that “ESRD facilities may not fill syringes with saline from the single dose saline bag or IV tubing connected to the patient at the dialysis station” whenever possible. 
Emphasizing ASN’s commitment to the goal of ensuring patient safety, the society expressed reservations about the memorandum’s recommendations, including concerns about the evidence base for and potential unintended consequences of the new policy, as well as its cost-effectiveness.  In a letter from President Eleanor D. Lederer, MD, FASN, ASN encouraged CMS to delay implementation to allow time for public discussion of best practices, including patient and health professional organizations, dialysis providers, and the Centers for Disease Control and Prevention (CDC) – observing that such communication has resulted in implementation of beneficial policies with broad support in the past. 
“In the absence of any evidence suggesting that pre-filled syringes are an effective strategy to reduce infections, I am concerned that this approach will not necessarily lead to better outcomes despite increasing costs.  Before proceeding with nationwide implementation, I believe at the very least CMS should provide an opportunity for all stakeholders, including the CDC, to discuss this new approach.  Ideally, a well-powered trial to establish some science on this approach would be funded so that we are implementing evidence-based policy instead of policy that ‘sounds good,’” said ASN Quality Committee Chair Daniel E. Weiner, MD, FASN.
As of press time, CMS had not yet responded to ASN’s concerns. Read the society’s complete letter to CMS is online at: https://www.asn-online.org/policy/


ASN has urged the Centers for Medicare and Medicaid Services (CMS) Survey and Certification Group to delay implementation and foster dialogue regarding a policy concerning saline syringe filling practices. The policy is set to take effect by Sunday, July 2, 2017.  Addressed to state survey agency directors, the memorandum states that “ESRD facilities may not fill syringes with saline from the single dose saline bag or IV tubing connected to the patient at the dialysis station” whenever possible. 
Emphasizing ASN’s commitment to the goal of ensuring patient safety, the society expressed reservations about the memorandum’s recommendations, including concerns about the evidence base for and potential unintended consequences of the new policy, as well as its cost-effectiveness.  In a letter from President Eleanor D. Lederer, MD, FASN, ASN encouraged CMS to delay implementation to allow time for public discussion of best practices, including patient and health professional organizations, dialysis providers, and the Centers for Disease Control and Prevention (CDC) – observing that such communication has resulted in implementation of beneficial policies with broad support in the past. 
“In the absence of any evidence suggesting that pre-filled syringes are an effective strategy to reduce infections, I am concerned that this approach will not necessarily lead to better outcomes despite increasing costs.  Before proceeding with nationwide implementation, I believe at the very least CMS should provide an opportunity for all stakeholders, including the CDC, to discuss this new approach.  Ideally, a well-powered trial to establish some science on this approach would be funded so that we are implementing evidence-based policy instead of policy that ‘sounds good,’” said ASN Quality Committee Chair Daniel E. Weiner, MD, FASN.
As of press time, CMS had not yet responded to ASN’s concerns. Read the society’s complete letter to CMS is online at: https://www.asn-online.org/policy/

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