REGULATORY REVIEW The memo states that IUSS should

be used only in emergency situations and implies that this policy is due to the risk that infections might arise due to the use of IUSS. There were con- cerns from the ophthalmic commu- nity upon the release of this memo that there would be widespread confusion as to whether or not the sterilization practices in ophthalmic ASCs were considered IUSS.

Ophthalmic Community Advocacy Efforts Following the release of Surveyor memo S&C 14-44, the American Acad- emy of Ophthalmology (the Acad- emy), the American Society of Cata- ract and Refractive Surgery (ASCRS) and the Outpatient Ophthalmic Sur- gery Society (OOSS) met twice with CMS to discuss their concerns that this policy change would require ASCs to use terminal sterilization units and additional sets of instruments, which could be extremely costly. After these meetings, CMS clarified that the prac- tices of most ophthalmic ASCs would be in compliance with its rules govern- ing instrument sterilization. Despite CMS’ attempt to clarify the kind of sterilization that is or is not acceptable on a routine basis, con- fusion about the differences between IUSS and short-cycle sterilization remains. Facilities performing sur- gery should understand the differences between the two to ensure that they comply with Medicare’s infection pre- vention and control requirements.

IUSS—Not Acceptable for Regular Use IUSS, formerly “flash steriliza- tion,” has traditionally been used to describe steam


is of relatively recent origin and results from a consensus statement, Immedi- ate Use Steam Sterilization, that was endorsed by multiple organizations and coordinated by AAMI. It replaces the much less precise and outdated term “flash sterilization.”

This process is in contrast to tradi- tional “terminal sterilization” cycles, where instruments are sterilized within containers, wrappers or primary pack-

Even when all steps are performed properly, CMS confirms, IUSS should be limited to situations in which there is an urgent need and insufficient time to process an instrument by using terminal sterilization.”

—Kara Newbury, ASCA

aging designed to maintain the instru- ments’ sterility and allow the devices to be stored for later use. The term “flash” arose out of the abbreviated time of exposure of the unwrapped device. In clarifying that IUSS is unaccept-

able as a routine method of steriliza- tion, CMS cites concerns about the routine use of IUSS as being “based on a lack of time to accomplish adequate pre-cleaning, increased risk of inad-

Create a Culture of Safety Across Your ASC with Clarity PSO

Protection Gain legal privilege & confidentiality protections

Empowerment Increase staff communication & encourage reporting & feedback


where unwrapped medical instruments are subjected to an abbreviated steam exposure time and used promptly, i.e., without being stored, once the clean- ing cycle is complete. The term IUSS

Collaboration Develop meaningful patient safety activities & learn from your peers

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