On August 29, 2014, the Centers for Medicare and Medicaid Services (CMS) sent a memo to the State Survey Agency Directors regarding the change in terminology from “flash” sterilization to the updated term “Immediate Use Steam Sterilization” (IUSS) in Surgical Settings (hospitals, critical access hospitals and ambulatory surgical Centers). This memo basically states that CMS now endorses the IUSS multi-society position statement on IUSS that was published in 2010 by the Association for the Advancement of Medical Instrumentation (AAMI). The memo directed surveyors to cite facilities for any instances of abusing IUSS e.g. substituting IUSS for maintaining a sufficient inventory of instruments or using IUSS in a manner that places patients at risk.
On February 2, 2015, The American Society of Ophthalmic Administrators (ASOA) released a public statement titled, CMS Clarifies Policy to Permit Use of Cycle Steam Sterilization in Ophthalmic ASCs. In the article they stated “According to CMS, the vast majority of ophthalmic ASCs are practicing short-cycle steam sterilization, which is permissible as long as the DFU’s are followed.” On February 9th, Outpatient Surgery Magazine published a piece titled CMS Clarifies Sterilization Guidelines for Ophthalmic ASCs. This article stated ASCs can breathe a sigh of relief and ASCs won’t need extra trays to comply with CMS.
As you can imagine that article caused a great deal of confusion among sterile processing professionals and organizations that create our national sterilization standards. On February 12, 2015 the Association for the Advancement of Medical Instrumentation (AAMI) sent a letter to CMS signed by Mary K. Logan, JD, CAE President, AAMI; Ramona Conner, MSN, RN, CNOR (co-chair, AAMI ST-79 Standards Committee) Editor-in-Chief, Guidelines for Perioperative Practice – Association of periOperative Registered Nurses (AORN); and Cynthia Spry, MA, MS, RN, CNOR, CSIT (co-chair, AAMI ST-79 Standards Committee) Independent Consultant. This AAMI letter stated “The ASOA statement has caused an immediate shift in practice that we believe puts patients at risk.” It also asked for clarification of the meaning of “short cycle” because it is not a standards-based definition. To my knowledge there has been no response so far from CMS.
The original August 29, 2014, CMS memo to the State Survey Agency Directors stated
“It should be noted that IUSS is not equivalent to “short cycle” sterilization. Regardless of the cycle duration, correct use of a sterilization cycle for a wrapped/contained load that meets the device manufacturer’s instructions for use (IFU) is the equivalent of terminal sterilization and is not IUSS if it includes use of a dry time and is packaged in a wrap or rigid sterilization container intended to be stored for later use.”
Therefore, it is my professional opinion there is no difference between terminal sterilization and short cycle. You are either terminally sterilizing or using IUSS (aka flash).