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AUR reporting split into AU and AR measures for 2025, presenters say
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Summary
NHSN training presenters explained that CMS split the AUR surveillance measure into two separate measures for 2025—Antimicrobial Use (AU) and Antimicrobial Resistance (AR)—and reviewed registration, required CDA file types, exclusions, vendor validation and key deadlines including a 01/31/2026 submission cutoff.
Michelle Fedrick and Stephanie Sutton led a National Healthcare Safety Network (NHSN) webinar detailing how hospitals must report Antimicrobial Use and Resistance (AUR) data for the CMS Promoting Interoperability Program in calendar year 2025. The session said CMS split the single AUR surveillance measure into two separate measures—AU (antimicrobial use) and AR (antimicrobial resistance)—and that eligible hospitals and critical access hospitals must either demonstrate active engagement with NHSN for each measure or claim an eligible exclusion.
Why it matters: The split lets hospitals be at different engagement levels for AU and AR, but it also requires separate attestations and separate determinations about exclusions. "Because they are separated, hospitals can be at different levels of active engagement for each measure," Stephanie Sutton said, underscoring that facilities must meet the requirements for both measures independently.
What hospitals must do: The presenters outlined three main steps facilities should complete to meet the 2025 requirements: (1) register intent in NHSN (a one-time action completed by the NHSN facility administrator); (2) provide test files for validation if attesting to Option 1 (preproduction/validation); and (3) send production AU and/or AR data to NHSN monthly during the facility's chosen 180-day EHR reporting period if attesting to Option 2 (validated production). "To attest to active engagement for the AU surveillance measure only, send 1 test file," Michelle Fedrick said, and "to attest for AR only, send 2 test files," enumerating the AU summary CDA and the AR event and AR summary CDA files.
Data types and technical requirements: Presenters emphasized that AU data are aggregated (no patient-level data) while AR submissions include patient-level isolate susceptibility results. "With AU, no patient level data is shared, and with AR, yes, patient level data is shared," Stephanie said. All AUR data must be submitted as CDA (clinical document architecture) files (XML/HL7); manual data entry is not allowed. Vendors used to produce CDA files must meet NHSN validation standards and ONC certification where required.
Exclusions and examples: The webinar reviewed exclusions for each measure. Common exclusions remain (for example, facilities with no patients in NHSN-collected care locations or lacking required electronic systems such as EMAR/BCMA, ADT or LIS), and a new 2025 exclusion covers facilities that do not have a data source containing the minimal discrete data elements required for reporting—an exclusion especially pertinent to AR. Presenters gave examples of when external lab results returned by fax/PDF may lead a facility to claim an exclusion, and noted that policy changes for 2025 permit reporting some Canada-genus isolates without susceptibility results, meaning some hospitals will no longer need that exclusion.
Deadlines, attestations and penalties: Facilities designate a continuous 180-day EHR reporting period and must use the same period for AU and AR reporting. The presenters listed timing rules: registration must be completed within 60 days of the start of the chosen reporting period; facilities should respond to NHSN requests for test files within 30 days; facilities that want an official NHSN letter showing validation should submit test files no later than 11/01/2025. Michelle Fedrick emphasized the submission deadline for calendar-year 2025 data: "All relevant calendar year 2025 AU and AR data must be submitted to NHSN by 01/31/2026, to be included in the annual report sent to facilities on 02/01/2026." Facilities attest to CMS in the Hospital Quality Reporting (HQR) system (the presenters cited an example attestation date of 03/14/2026, subject to change). Failure to report or to claim an applicable exclusion can result in a score of 0 for the public health and clinical data exchange objective and a Medicare downward payment adjustment, the presenters said.
Practical notes and resources: NHSN will send automated monthly status emails to facility administrators showing submission status, and facilities should save those emails for records. Presenters recommended using a validated vendor because CDA files are complex, reminded attendees that the NHSN application will reject AR CDA files missing required drug lists for organisms, and directed participants to the AUR module web page, protocol documents and NHSN training webinars for further guidance. For PI-specific questions, presenters pointed participants to the CMS QualityNet Q&A tool and the NHSN help desk email provided in the webinar.
What’s next: Facilities should confirm their 180-day reporting period, complete NHSN registration if not already done, work with a vendor to generate and validate CDA files as needed, and ensure all calendar-year 2025 AU and AR data are submitted to NHSN by 01/31/2026.
