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Consultant addresses trends among ASCs
By Richard Bays, RN, MBA, CPHQ, CLNC
R Bays Consulting
Question: As a consultant, you specialize in helping ambulatory surgery centers (ASCs) get in compliance with accreditation and licensing. Are there any parts of the almost two-year-old 2009 Medicare Conditions for Coverage that ASCs are having a difficult time handling?
Answer: Some of the areas I've seen difficulties are in the four outlined below:
§ 416.42 Condition for coverage Surgical services.
Physicians must have been granted clinical privileges by the governing body of the ASC in accordance with approved policies and procedures of the ASC. In reviewing physician files, the problems are one, have they been granted privileges prior to performing surgery and two, was their license verified as current prior to performing cases at the ASC.
§ 416.44 Condition for coverage Environment.
Life Safety Code violations are becoming more frequent as inspectors are focusing more on this area. Physical fire wall penetrations, lack of documentation for fire drills, and fire safety training are the most common items being cited.
§ 416.47 Condition for coverage Medical records.
One of the issues I see during closed record reviews is improperly executed consents. Consents should specify the procedure to be performed, site (right/left), the time and date of execution, the patient's name and name of the witness.
§ 416.48 Condition for coverage Pharmaceutical services.
Medication administration continues to be an ongoing compliance issue, with anesthesia tending to be the weakest area. Medications should be labeled when they are on the sterile field, multi-dose vials should be labeled when opened, and controlled substances should be accounted for and secured. Expired medications are the no. 1 problem area.
Question: What are some of the most significant trends that you have seen in the ASC industry over the past few years?
Answer: Some of the ASCs are choosing to not accept Medicare patients and relying solely on private insurance and cash pay patients. This model can work, depending on your overall case mix and long-term strategic planning. It also eliminates the accreditation process that most facilities participate in to gain access to CMS/Medicare. Another sometimes painful reality is the need for diversification at some facilities. Many single-specialty ASCs have expanded their services to offer new procedures. Physical expansion or additional equipment costs are weighed into a "repackaging" of the ASC. Some ASCs have explored selling partial interest in the facility or joint ventures with others. The trend recently has been examining a longer-range plan to remain profitable and diligent preparation for possible scenarios revolving around the new healthcare reform that is brewing. Every facility has its own personality; there's no magic bullet. [Editor's note: This article is reprinted with the permission of the Texas Ambulatory Surgery Center Society.]