Are You Familiar with the New SAFER Guides?

Beginning with the CY 2022 Medicare Promoting Interoperability (PI) Program (finalized in the FY 2022 IPPS/LTCH PPS rulemaking), CMS added a SAFER Guides measure for eligible hospitals and critical access hospitals (CAHs) that is reported as a simple “yes/no” attestation indicating whether the organization completed an annual SAFER self-assessment. That requirement applies to eligible hospitals and CAHs (not ASCs), but it has moved the SAFER Guides into the limelight and caught the ear of many ASC leaders.

Implementing an EHR requires careful consideration of policies and procedures for user access, record completion, training, and support. But the bigger picture that will allow centers to address EHR safety in other areas of concern requires a concise, simple checklist of what to do, who should do it, and when it should be completed.

The SAFER Guides do precisely that. These guides are self-assessment tools that help identify risks and prioritize, resolve, or minimize them. While they are not mandatory for ASCs under CMS ASC payment programs, can we be far behind? Regardless, they are an excellent way to ensure you have thought through the processes you hope you rarely need to use.

The New SAFER Guides in 2025: What Do They Bring New and Why Does It Matter?

Over the past few years, EHR oversight has moved from a background IT concern to a core patient safety and operational issue. While ambulatory surgery centers are not held to the same Medicare PI reporting requirements as acute care hospitals and CAHs, expectations around EHR governance, downtime readiness, and clinical risk management continue to rise. The 2025 SAFER Guides reflect that shift.

The updated SAFER Guides were revised for the 2025 edition (the prior major update was 2016) to focus on the most common and highest-risk EHR failures seen across care settings. The intent was not to add more requirements, but to make the guidance more usable. Redundant content was removed, the number of recommended practices was reduced by roughly 40 percent, and the structure was simplified so leadership teams can quickly identify gaps that matter.

For ASC leadership, this matters because EHR-related breakdowns often show up during high-stress moments: patient identification errors, missed test results, unclear handoffs, or system downtime during procedures. These are not theoretical risks. They directly affect EHR and patient safety in fast-moving outpatient environments.

The Updated 2025 SAFER Guides: Structure and Functions

The updated framework consists of eight guides organized into three groups. Most ASCs should begin with the foundational content and then focus on areas that align with their case mix, staffing model, and technology footprint.

Foundational Guides

• High Priority Practices pulls together the most critical recommendations from across the framework. These practices represent the minimum safety behaviors leadership should understand and support. For ASCs, this guide is a practical starting point because it highlights where governance, training, and system configuration most often fail.
• Organizational Responsibilities focuses on accountability. It addresses leadership oversight, staff roles, training, and monitoring. A key update in 2025 is the inclusion of guidance related to AI-enabled EHR features. Even in ASCs, tools that influence scheduling, documentation, or clinical decision support require clear ownership and validation. This guide supports structured EHR risk management without overcomplicating governance.

Infrastructure Guides

• Contingency Planning addresses planned and unplanned EHR downtime. For ASCs, this aligns directly with the ASC disaster plan. The guide emphasizes preparation for partial system failures, not just full outages, and reinforces the need for staff to practice downtime workflows rather than document them.
• System Management consolidates what used to be spread across multiple areas. It covers system configuration, updates, interfaces, and ongoing validation. This is particularly relevant for centers that rely on vendor-hosted systems or have multiple interfaces with labs, billing platforms, or health information exchanges.

Clinical Process Guides

• Patient Identification focuses on ensuring that the correct patient data is displayed and used at every step of care. In procedural settings, where turnover is fast, this remains a foundational safety concern.
• Computerized Provider Order Entry with Decision Support guide addresses how orders, alerts, and decision support tools are designed and monitored. Poorly configured alerts or outdated order sets can quietly undermine EHR safety and clinician trust.
• Test Results Reporting and Follow-Up focuses on closed-loop communication. Even in ASCs, missed pathology or delayed result follow-up represents a real liability tied directly to EHR patient safety.
• Clinician Communication addresses EHR-based messaging and handoffs, including referrals, discharges, and care transitions. Clear electronic communication is essential in environments where care often continues outside the center’s walls.

New 5-Point Scoring System

One of the most valuable updates for 2025 is the move away from the binary “Yes/No” or “Implemented/Not Implemented” status. The 2025 SAFER Guides introduce a 5-point implementation rating scale to help organizations reflect partial adoption and track progress over time. ASC leaders can now track progress more accurately using the 5-point Likert scale:

1. Not implemented (0%): No action taken yet.
2. Making progress (1-30%): Early pilot phase or adoption.
3. Halfway there (31-60%): Implementing the recommendation in about half of the workflows.
4. Substantial progress (61-90%): Wide adoption with minor gaps.
5. Fully implemented (91-100%): Consistently followed across the entire center.

As a pro tip, use the “EHR Limitation” checkbox if your current software lacks the technical capability to meet a recommendation. This documentation is useful for internal risk management and can help explain gaps to leadership, vendors, or (if asked) surveyors/accreditors.

How the New SAFER Guides Align with CMS Expectations

Although the updated content differs from earlier versions, previous SAFER materials remain referenced in quality programs. From a regulatory standpoint, the SAFER framework continues to function as evidence of thoughtful risk management in EHR implementation. For hospitals and CAHs, the CMS PI Program SAFER Guides measure is an attestation of “yes/no” and does not add points to the PI score, but it is still a required attestation element.

For ASC leaders, using the CMS SAFER guides as an internal assessment tool demonstrates proactive oversight rather than reactive compliance. The guides are not about perfection. They are about showing that leadership understands where EHR failures occur and has taken reasonable steps to reduce harm.

Practical Tips for Using the 2025 SAFER Guides

The 2025 SAFER Guides are most effective when approached as a shared leadership exercise rather than an IT task. They are designed to help ASCs identify and address EHR safety risks before they surface during high-pressure clinical situations.

Assemble the Right Contributors

No single person can complete the guides on their own. Plan to involve:

• Clinical leadership and frontline staff
• IT and informatics support
• Your EHR vendor and interface partners
• Diagnostic or ancillary service providers (for ASCs, this is often pathology and any interfaces that handle results routing/notifications)
• Compliance or risk management representatives

Your EHR vendor should support sections related to high-priority practices, system management, interfaces, and clinical decision support. Reconfirm this information annually to account for software updates and workflow changes.

Prepare Before Downtime Happens

The guides are most valuable when used proactively. Completing them in advance helps clarify:

• Roles during partial or full EHR downtime
•  Backup workflows for documentation and orders
• Access and security responses during system disruptions
• Practical ASC downtime specifics (e.g., paper consents/time-outs as needed, implant logs/charge capture continuity, and how you’ll document meds given in pre-op/PACU when the system is slow or unavailable)

This preparation prevents decision-making under pressure and supports safer operations when systems are unavailable.

Focus on High-Risk Areas First

The guides do not need to be completed all at once. A practical approach is to:

• Start with the Foundational Guides
• Prioritize areas tied to patient identification, orders, results, and communication
• Assign section ownership rather than centralizing the work
• Allow time to test and refine policies before finalizing responses

Progress matters more than speed.

Revisit Regularly

EHR systems and workflows change. Build SAFER review into existing activities such as annual risk assessments, downtime drills, quality meetings, or vendor upgrade planning. This keeps EHR safety aligned with real-world operations.

The SAFER Guides Might Be the Key to Success

EHRs directly influence clinical decisions, communication, and patient outcomes. The 2025 SAFER Guides provide a practical structure for ASC leaders to assess readiness, reduce risk, and strengthen system resilience without adding unnecessary burden.

Frequently Asked Questions

As the regulatory landscape for outpatient surgery shifts toward more rigorous digital oversight, leadership teams often have common questions about where these guides fit into their daily operations. Here are some answers!

Do ASCs have to submit SAFER Guide results to CMS?

Currently, ASCs generally do not have a CMS requirement to submit SAFER Guide assessments under IPPS/Medicare PI. Eligible hospitals and CAHs attest “yes/no” to completing an annual SAFER self-assessment as part of the Medicare PI Program, but that requirement does not apply to ASCs. ASCs may still choose to use SAFER internally, and some accreditors/surveyors may view it as evidence of structured EHR risk management if EHR safety or downtime arises during a survey.

How often should we complete the SAFER self-assessment?

It is considered best practice to conduct a self-assessment annually. This aligns with the HIPAA expectation for an ongoing risk analysis process (HIPAA does not set a specific annual frequency, but many organizations do an annual review and update it when systems/workflows change) and ensures that software updates or new staff haven’t introduced new risks into your workflow.

Which SAFER Guide should an ASC start with?

Always start with the High Priority Practices Guide. It contains 16 of the most critical recommendations pulled from all other guides and serves as the best high-level snapshot of your center’s EHR safety and health.

How do the 2025 SAFER Guides address the use of AI in my ASC?

The updated guides include specific recommendations for AI-enabled EHR features, such as automated scheduling, clinical decision support, and ambient documentation (AI scribes).

The 2025 framework emphasizes that ASC leadership is responsible for overseeing these tools, requiring centers to validate that AI outputs are accurate and do not introduce new clinical risks or errors (including inaccurate or fabricated text) into the patient record.