CMS SOM App. H, Tag V551

address, but not be limited to, the following: (5) Vascular access…. The patient’s vascular

access must be monitored to prevent access failure, including monitoring of arteriovenous

grafts and fistulae for symptoms of stenosis.

Interpretive Guidance § 494.90(a)(5)

Page 217 of 420

Note: this guidance is a continuation of the regulatory requirement at § 494.90(a)(5).

The facility must have an ongoing program for vascular access monitoring and surveillance to

detect failure early and facilitate timely referral of patients for intervention when indications of

significant stenosis are present. Patient education should address self-monitoring of the vascular

access.

Monitoring strategies may include physical examination of the vascular access, observation of

changes in adequacy or pressures measured during dialysis, difficulties with cannulation, or

challenges in achieving hemostasis. Precipitating events should also be noted, such as

hypotension or hypovolemia. Surveillance strategies include device-based methods, such as

access flow measurements, direct or derived static venous pressure ratios, and duplex

ultrasound.

For patients with grafts and fistulas, the medical record should show evidence of periodic

monitoring and surveillance of the vascular access for stenosis and signs of impending failure.

The documentation of this may be on the dialysis treatment record, progress notes, or on a

separate log. A member of the facility staff must review the vascular access

monitoring/surveillance documentation to identify adverse trends and act if indicated.

Refer to the Conditions for Infection Control at V147 and V148, as well as the Condition for

QAPI at V633, which also cover the monitoring and surveillance of vascular accesses.