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Feb 02
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Benefits Approval

Benefits Approval in ASCs: Pre-Authorization & Pre-Determination Vastly Differ

By Revenue Cycle Management No Comments

Understanding the difference between pre-authorization and pre-determination of patient benefits is valuable knowledge for ASC front office personnel to possess.  These distinct approval processes are easy to confuse, leading to improper documentation prior to patients receiving health care services.  As a result, claims for services performed get delayed or, worse, outright denied.  Understanding the definitions of these approval processes allows ASC personnel to accurately determine the proper course of action prior to commencing patient care. 

Pre-Authorization

Pre-authorization is a required process.  It determines a patient’s benefits coverage and secures authorization and/or approval from a payor for a proposed procedure before the patient receives the desired care.  

Pre-authorization does not guarantee reimbursement of the services that will be performed.  However, it provides important information regarding a patient’s unique benefits including their eligibility status and potential out-of-pocket expenses.  Not obtaining authorization prior to rendering treatment could result in non-reimbursement by the payor.  

Once authorization is complete, an authorization number is issued.  Adding the authorization number to the claim upon submission is a vital step to avoid unnecessary denials.  In circumstances where a claim is denied based upon lack of medical necessity, having an authorization number bolsters the contents of a provider’s appeal letter.

Pre-Determination

Pre-determination is a process that allows a provider to seek approval from the insurer for proposed services or treatment based upon medical necessity.  It is recommended when the planned procedure is considered experimental, investigational, or cosmetic.  Consult your carrier’s medical policies to identify services that fall into these categories.  It is also wise to obtain pre-determination forms (or letter requirements) from specific carriers to ensure you properly submit the information required to conduct their review. 

The insurer’s medical staff evaluate the pre-determination request against the carrier’s medical policies to determine whether the proposed procedure should be approved or denied.  Approvals and denials, in the form of a letter, are sent to the patient and health care provider(s).  This letter should be on hand prior to rendering services to the patient.  The process can take several weeks to complete.  Pre-determination approvals are not a substitute for the eligibility and verification of benefits process. 

Conclusion

Each payor’s prior approval process is different.  It is important to know the managed care provider’s policies as well as the medical procedures which require prior action.  Understanding the subtle differences in these approval processes helps your facility avoid costly errors on front-end documentation. Remember, it is never as simple as calling the insurer and being told, “no authorization is required.”  Conduct due diligence.  It is very likely the approval of a patient’s procedure falls under one of these two categories.    

Carol Ciluffo – Vice President of Revenue Cycle Management 

Feb 01
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2016 ASC Industry Year in Review

New White Paper! 2016 ASC Industry Year in Review: 10 Key Takeaways

By ASC Development, ASC Governance, ASC Management, Leadership No Comments

We are excited to release our latest white paper – 2016 ASC Industry Year in Review: 10 Key Takeaways.

As we start the new year, it is worthwhile to examine trends and developments that helped shape the ASC industry in 2016.  These trends and developments will most likely set the tone for 2017 and beyond.

Key industry takeaways identified by our leadership include renewed focus on the migration of inpatient surgical care to outpatient settings and a surprising abundance of de novo development.

While momentum for alternative payment models stalled, the impact of implant reimbursement and increased patient financial responsibility dominated operational discussions.  Challenges presented by nursing shortages, increased regulatory compliance, and the demand for more data continued to be hot topics.

Garnering insights from these areas of focus is important given the prominent role ASCs perform in the delivery of affordable quality care.

In summarizing 2016, our Principal Partner, Rick DeHart, stated:

“From my perspective, 2016 was a transitional year for ASCs.  A significant amount of time was spent focusing on the election and anticipating its impact on the future. Everyone was waiting for much of that activity to finish . . . We may see even more activity in the industry in 2017.  Surgery centers are certainly well-positioned to be the low-cost, high-quality provider of choice for an increasing number of patients.”

To read the full report, download the white paper here: https://www.pinnacleiii.com/white-papers/

-The Pinnacle III Marketing Team

Jan 31
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Payor Contracting Negotiators

Payor Contracting Negotiators Yield Tangible Results for ASCs

By Payor Contracting No Comments

Clients often ask me, “Why should we hire a third-party negotiator to handle our ASC’s reimbursement from commercial payors?”  My most straightforward answer is simply, “It takes money to make money.”

There are three reasons why spending money on hiring a payor contracting professional is worth your pretty penny. First, perception is everything.  Second, time is money.  Finally, knowledge is important, but objectivity is essential.

Perception is everything

Payors quickly pick up on whether a negotiator is an experienced ASC industry professional. Experience working with payors throughout the country on behalf of numerous entities builds rapport with payors.  That rapport goes a long way toward easing the tension that can easily occur between parties with competing interests.  Because of this, the negotiator, although working on behalf of the ASC, can serve as an independent third-party mediator, creating common ground between the facility and the payor where meaningful discussion can take place.  Hence, broad specialized experience and rapport can be invaluable to your ASC in securing the desired perception with the payor.

Time is money

We’ve all likely heard the adage “time is money.”  Unfortunately, both lack of experience and knowledge will increase the length of the negotiation.  The cost to your center – incurred by delays in receiving optimal reimbursement – can be high as can the irrevocable expense associated with an opportunity foregone.  If the payor doesn’t need to educate a novice or get them up-to-speed on reimbursement issues, this will translate into time savings and, potentially, actual money in your ASC’s pocket.  Also, a third-party negotiator wears a specialized hat.  On the other hand, an administrator needs to wear many hats when running a facility.  This means third-party negotiators are more readily accessible and available to communicate with payors to ensure negotiations are optimally progressing.  As a result, they decrease the amount of time needed to complete negotiations.

Knowledge is important, but objectivity is essential

Physician stakeholders and your ASC’s administrator have knowledge about your facility like none other.  They know the strengths of the center and how each one benefits payors and their members. However, they typically don’t know enough about reimbursement trends and payor acumen to objectively assemble and present reimbursement proposals to payors.  Your ASC’s team is essential to equipping the negotiator with what s/he needs to form an evidence based negotiation.* However, they’re not in the best position to determine reasonableness of a request for reimbursement – they lack objectivity.

When it comes down to it, ask yourself if you are well equipped to handle any of the situations above.  Obtaining professional managed care contracting expertise may be one of the best decisions you make for your ASC and your time.

*Discussing the value and components of evidence based negotiations is beyond the scope of this blog posting.  However, it will be the single subject of a future posting

Dan Connolly – Vice President of Payor Relations and Contracting

Jan 27
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Recruiting Surgeons

Questions to Consider when Recruiting Surgeons to Your ASC

By ASC Management, Leadership No Comments

There will come a time when your ASC will need to recruit new surgeons.  Whether it’s for a new, thriving, or struggling ASC, recruiting new surgeons is a continual priority.  The selection process for adding physician members to your ASC is critical to becoming and remaining a prosperous center.

Ask yourself the following questions when recruiting surgeons.

  1. What is the surgeon’s character/competence?

If the surgeon has been problematic in the health care community and has established a reputation as being difficult to work with, consider the impact they may have at your center.  If you would not send a family member to them for surgery, would you associate yourself professionally with them?  Choose your partners wisely.

  1. What is the return on investment (ROI)?

Not all cases, or case mixes, are created equal.  Sometimes an ASC is not the best place for certain procedures or specialties.  To obtain an understanding of the ROI, evaluate the surgeon’s CPT codes and case mix.  Compare these to your facility’s existing contracts (or the proposed contract rates if you are evaluating a startup situation).  Avoid assuming all cases and surgeons are alike when it comes to supplies, staffing, and implant usage.  Perform due diligence on what a surgeon utilizes or what a case requires.  Additionally, payor mix will play a significant role in determining how appropriate a surgeon is for your ASC.  If you do not want to contract with a particular payor, and that payor represents a significant portion of a surgeon’s cases, recruiting that surgeon may not be the best move for you.

  1. Is there exclusivity or conflicting interests?

In the late 1990s, there were very few ASCs and they performed very well. In the early 2000s, word got out ASCs were a viable means of augmenting a physician’s income and improving their quality of life.  Thus, in many parts of the country, ASCs proliferated.  This proliferation contributed to physicians diluting their cases across many ASCs.  This was not a problem when the ASCs serviced distinct geographic areas and did not jeopardize the physician’s ability to meet federal Safe Harbor requirements.  However, that is not reflective of the current environment.  When considering surgeons for membership in your center, vet any other ASC investments they may have. Determine how those investments might impact their commitment to your center, as well as their ability to meet federal and ASC specific requirements.

  1. Are you clearly defining expectations?

We all do better when clear expectations are established ahead of time. This is no different for ASC physician members.  You can accomplish this via the center’s operating agreement and bylaws.  I like to consider these documents the ASC’s prenuptial agreement.  Allow boards and steering committees to clearly define responses to issues they may encounter down the road by addressing them proactively in these documents.  These can include, but are not limited to, behavioral expectations, dictation expectations, non-compete provisions, Safe Harbor compliance, buy/sell agreements, and enforcement.  All potential members need to thoroughly read and acknowledge their agreement with these documents before you consider them for membership.  Lastly, if you are evaluating membership for new surgeons in an existing ASC, consider implementing a trial period of three to six months.  This allows all parties to ensure the center is a good fit.

Use these questions to assist you with your recruitment initiatives.   Remind ASC leadership when seeking new members, it’s typically easier to obtain a divorce than it is to remove an undesirable surgery center partner.  This fact makes the vetting of new partners that much more important. Remember, it is never as simple as “s/he has a lot of cases.”

Robert Carrera – President and CEO

Jan 25
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ASC Experience

The ASC Experience: A Patient’s Perspective

By ASC Management No Comments

Those of us who work in ASCs can easily forget that many health care consumers are not familiar with the services we provide.  If a patient hasn’t been directed to an ambulatory setting for surgical care, they are often unaware that freestanding ASCs exist.  If they’ve had surgery in a hospital’s outpatient department (HOPD), they may not be aware alternative outpatient settings are available.

While we know the benefits of choosing an ASC over a hospital setting, our patients experience the care we provide from a completely different point of view.  While it is uncommon for patients to have the same procedure performed both in a hospital and at an ASC, one of our billing service employees was able to offer this unique perspective.  

We hope her story resonates with you.  It may even help you identify what makes your ASC a facility of choice for your physicians and patients.  

Here’s her story:

“The day we had been dreading for years finally arrived.  My husband could no longer walk without significant pain. He needed a left knee replacement.  He had his right knee replaced 10 years earlier in a hospital setting.  The process went about as badly as any could go.  But now, he could no longer hold out.   We made an appointment with a surgeon. 

Our surgeon, Dr. Ian Weber, described a newer process for the procedure including a post-operative pain block.  He suggested my husband was a good candidate for having the procedure in an ambulatory surgery center instead of a hospital.  We chose The Surgery Center at Lutheran. 

We arrived at 6:00 on a Monday morning.  Within 10 minutes a nurse took us back to pre-op and explained the procedure my husband would undergo.  During each step of the process, the nurses made sure we both understood what was occurring and why.  Within an hour, my husband was prepped for surgery and off he went.   Approximately two hours later a nurse came to let me know he was in recovery and led me back to stay with him.  My husband recognized and spoke to me immediately. 

From that point forward, the recovery nurse never left our line of sight.  She checked on my husband frequently to see if he needed anything and assessed how the pain block was wearing off.  She explained the goals he needed to achieve to be released and then helped him accomplish them.  By noon he was sitting up, eating lunch, and ready for physical therapy.  Around 1:00 p.m., with the aid of crutches, he walked around the surgery center.  The physical therapist was on one side and the recovery nurse on the other side to ensure his safety. By 2:00 p.m., the surgery center released my husband to go home with me. 

What a difference!  Ten years earlier, my husband spent four days in the hospital with various nurses assigned to his care.  Unfortunately, shift changes represented a step backwards as each new nurse needed to be brought current with my husband’s condition.  This year he spent eight hours at an ASC with one recovery nurse who knew exactly what was going on with my husband every step of the way.  The ability for my husband to sleep in his own bed that night and recover at home was amazing.   The difference between the two experiences could not have been greater. 

We are grateful to The Surgery Center at Lutheran and their amazing staff.  If we ever need surgery again, we will choose an ASC over a hospital stay.”

-The Pinnacle III Team

Jan 19
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ASC Development Project

Congratulations! Your ASC Development Project Prognosis is Strong. Now What?

By ASC Development No Comments

When the results of your feasibility analysis indicate your ASC development project is likely to be a successful endeavor, it’s important to ensure your next steps are strategic and well-planned.  Developing a new center involves many tasks.  If you put the cart before horse, you will end up going nowhere.  Conversely, if you forget to harness the horse to the cart, you won’t arrive at your destination with all the essential components.  You must know the timeline, ensure you take each step in the proper order, and proficiently complete the identified tasks in a timely manner.  Here are some of the key tasks to consider on your development journey.

1. Choose an experienced health care attorney.

Hire a health care attorney you trust and/or have worked with in the past to pull together the necessary legal documents.  Having a solid framework in place to guide the ownership structure will be integral throughout the life of the business.  Treat your operating agreement as the entity’s pre-nuptial.  Address items that could be potential roadblocks – how you will add new partners or assist those that need to leave the partnership, for example.  It is much easier to handle these potential issues at the outset, rather than at a time when clearer heads may not prevail. 

2. Devise a plan for the physical space.

Do you want to build from the ground up?  Do you already have land?   Or, do you want to rent and remodel?  These are questions to immediately consider.  The cost for tenant improvements versus a new construction project can vary immensely.  Location is a key consideration.  Patients prefer ease of access which includes convenience from main roads, ample parking, and navigation into and out of the facility.   Consider proximity to the surgeons’ practices and hospitals.  Establish a pros and cons list to aid in the decision-making process.  The final decision will have an impact on the pro forma and loan requirements.  Make these decisions early on.

3. Chose the right architect and construction company.

Firms with strong knowledge of the regulations as they relate to ASCs are a must.  Best practice is for your development company, architect, and construction company to work closely with each other throughout the entire design/build process.  This helps ensures a licensable and certifiable building.  Oversight in the following areas is imperative:

A. Budget.

Consider adding a commissioning agent or construction manager to keep bids within range and avoid cost overruns. Research the associated costs in your local community to secure competitive pricing.

B. Value Engineering.

A good general contractor or construction manager will actively look for ways to save money where it counts.

C. Involve surgeons in the design to ensure efficiency in the delivery of care.

Surgeons are your best resource for understanding center needs related to delivery of care. They are also likely paying for the project; it’s vital to keep them involved in the decision-making process.  Collaboration from all parties on where to spend, and save, project money creates greater satisfaction with the final result.  Maintain a record of decisions made to serve as a future reference when someone inquires why something was done a certain way.

D. Involve key regulators in the building process.

Having permitting individuals from the city, county, state, and surveying bodies on site throughout the construction process allows you to proactively identify issues of concern.  Waiting for the occupancy permit can lead to inconsistencies that must be remedied at a potentially significant cost.

4. Establish relationships with financial lending organizations.

The terms offered on a project can vary greatly as can the required guarantees.  Knowing how to effectively oversee this process allows the owners an opportunity to make the best overall decision. Complete a bidding process and interview the key banking individuals you will be working with.  Secure services from financial lenders who work well with your steering committee and board members.  Ask about hidden fees and closing costs.  Find out how business fees will be applied as you ramp up the account.  Often, the bank will be willing to negotiate early in the process to obtain the loan business.

5. Appropriately time the purchase of equipment.

Starting discussions with vendors early on allows for potential price reductions on key equipment when new models are coming into the market.  The prior year’s model is usually less expensive or there may be loaner equipment available for purchase.  Sometimes putting a down payment on equipment allows you to lock in the current year’s pricing.  This happens even if you don’t complete the purchase until the next calendar year.  Organization keeps construction on schedule, prevents delays, and ensures equipment delivery and installation occur at appropriate intervals.

6. Establish a staffing plan early.

An established staffing plan allows for a smoother transition from development to operational management.  Bring key staff members on board early to ensure proper operational structure prior to the opening of the facility.  All staff need to demonstrate skilled organizational processes when surveyed by the state, CMS, and an accrediting body.  A tiered approach to hiring allows for competency and cost effectiveness in those early months of operation.

You will not find a healthcare project more unique than developing a surgery center.  It is a demanding, rigorous process.  Working with experienced professionals who understand the nuances of each of the above-listed items can alleviate the feared trial and error process if you are undergoing this task for the first time.  Prepare, ask questions, lean on the expertise of others, and collaborate.  These are the keys to success in launching your new surgery center business. 

Lisa Austin – Vice President of Facility Development

Jan 17
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CMS Survey

An ASC Administrator’s Guide to Responding to a CMS Survey & Plan of Correction

By ASC Management No Comments

At some point, most facilities undergo a Centers for Medicare and Medicaid (CMS) Survey. These unannounced surveys can occur on any given day; hopefully your ASC is ready!

Prepare for Your Survey – Know the Conditions of Coverage

CMS establishes minimum health and safety standards, called Conditions for Coverage (CfCs), that ASCs must meet to obtain and maintain certification. The standards cover all aspects of an ASC from operational organization – including patient care and safety – to facility design. CfCs must be met for all patients seen in your facility, not just those covered by Medicare and Medicaid. You can find these standards in Appendix I: Survey Procedures and Interpretive Guidelines for Life Safety Code Surveys[1] and Appendix L: Interpretive Guidelines for ASCs[2] of the CMS State Operations Manual.

It is imperative for all members of your facility to be familiar with and understand these standards prior to a survey. To ensure sufficient preparation for an unannounced survey, put together binders of all the documentation the surveyors will want to review – policies, contracts, and other agreements – that address each CfC. Include an index that references back to each standard. These binders can then serve as survey preparation for your staff. As staff review each standard and locate the documentation supporting the standard, they are also educating themselves. Remember, the more educated and prepared your facility is, the higher the likelihood that you will achieve a satisfactory survey outcome.

What to Expect When Your Surveyor Arrives

Surveyors usually arrive early in the morning for unannounced surveys. You can plan on them conducting their on-site review for one and a half days to two full days depending on the size of your facility. They will review all aspects of your clinical and business operations. The surveyors will ask to review a multitude of items and one of them will follow a patient through the entire treatment process. The Life Safety surveyor will focus on the building and Life Safety Codes.

Although aiming for a perfect score, even the most highly functioning ASCs are typically cited for something. That’s the nature of the beast. Surveyors, intent on ensuring safety and quality of care for patients and staff alike, seek strict adherence to their certification standards. Deficiencies cited, no matter how minor, prompt a Plan of Correction. 

Upon completion of your survey, you will receive a report via certified mail. The report, which usually arrives within a few weeks of your survey, will include a request for a Plan of Correction (POC). The POC outlines any deficiencies cited during the survey. The deficiencies are reported on CMS-2567.[3] You must respond to each deficiency with specific details pertaining to the corrective actions you plan to take to fully resolve the citation. Your responses are recorded on the right side of the form.

Components of Your Plan of Correction (POC)

Five main components need to be included in your POC:

  1. The first component is the deficiency standard number and a detailed statement of what needs to be corrected. This should be a concise sentence related to the shortcoming.

If you are cited for expired medications in your inventory, for example, your response could be: Q181. The entire medication supply will be monitored monthly for expiration dates.

  1. Next, specify how the deficiency will be corrected. Note detailed information about the corrective action taken and who was involved. List all the items you completed to correct the inadequacy and maintain documentation regarding how you addressed the issue.

For example: Performed staff training on 12/12/2016. All clinical personnel were in attendance. Reviewed policy on expiration of medications and solutions. Revised policy to clarify preference for single dose vials and ampules. Responded to questions from staff regarding who retains responsibility for monitoring medication expiration dates.

  1. The third component notes how you will ensure ongoing compliance with the corrected deficiency – via random audits, for example. If you do audit, retain documentation of audit results. Be specific about how you will monitor the corrections made. Ensure monitoring is consistent and timely. Clearly state how you will maintain compliance.

For example: Updated emergency cart medication lists. Began actively monitoring the expiration dates of all medications throughout the facility. Implemented random audits of the medication supply to ensure compliance. Initial audit was conducted on 12/16/2016 in various locations around the facility. No expired medications were found. Compliance expectation is 100% removal of expired medications from floor stock as evidenced by monthly inspections.

  1. Name the responsible party for completion of each task and ensure ongoing compliance. You are permitted to use a person’s name but noting someone’s title (e.g., Clinical Director or Business Office Manager) ensures responsibility is linked to a defined role rather than a specific individual.
  1. The final component is provision of a completion date for the deficiency. Ensure the deficiency is corrected by the date you set.

Next Steps

Upon completion of the plan, sign and date the form. Return the document to the person and address noted on the Plan of Correction. You typically have 10 days after receipt of the POC letter to return your response.

Make sure you retain a copy of the POC on file at the center with all your corrective action documentation. As you work through the POC and collect supporting documentation, keep everything together in one binder. This is very helpful in the event of a re-survey.

The CMS regional office will review your POC. You can then expect a response letter from them regarding acceptance or denial of your plan of correction. If your POC was accepted, the letter will also inform you whether a re-survey will occur. A rejected POC will contain information regarding any changes that need to be made and a new deadline for completion. Update the POC and return per the letter’s instructions by the specified due date.

Conclusion

Although preparing, undergoing, and responding to a survey is a daunting task, surveys provide us with opportunities to view our ASC operations from the outside in. They allow us to implement best practices that ultimately lead to a center of excellence, a goal we are all trying to achieve. Don’t let the prospect of an unannounced survey worry you. Preparation and organization is key to successfully completing your survey, even if you are required to submit a plan of correction.

Kelli McMahan – Vice President of Operations

[1] https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/som107ap_i_lsc.pdf

[2] https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/downloads/som107ap_l_ambulatory.pdf

[3] https://www.cms.gov/Medicare/CMS-Forms/CMS-Forms/Downloads/CMS2567.pdf

Jan 17
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CMS Survey

An ASC Administrator’s Guide to Responding to a CMS Survey & Plan of Correction

By ASC Management No Comments

At some point, most facilities undergo a Centers for Medicare and Medicaid (CMS) Survey. These unannounced surveys can occur on any given day; hopefully your ASC is ready!

Prepare for Your Survey – Know the Conditions of Coverage

CMS establishes minimum health and safety standards, called Conditions for Coverage (CfCs), that ASCs must meet to obtain and maintain certification.  The standards cover all aspects of an ASC from operational organization – including patient care and safety – to facility design.  CfCs must be met for all patients seen in your facility,  not just those covered by Medicare and Medicaid.   You can find these standards in Appendix I:  Survey Procedures and Interpretive Guidelines for Life Safety Code Surveys[1] and Appendix L:  Interpretive Guidelines for ASCs[2] of the CMS State Operations Manual.

It is imperative for all members of your facility to be familiar with and understand these standards prior to a survey.  To ensure sufficient preparation for an unannounced survey, put together binders of all the documentation the surveyors will want to review – policies, contracts, and other agreements – that address each CfC.  Include an index that references back to each standard.  These binders can then serve as survey preparation for your staff.   As staff review each standard and locate the documentation supporting the standard, they are also educating themselves.  Remember, the more educated and prepared your facility is, the higher the likelihood that you will achieve a satisfactory survey outcome. 

What to Expect When Your Surveyor Arrives

Surveyors usually arrive early in the morning for unannounced surveys. You can plan on them conducting their on-site review for one and a half days to two full days depending on the size of your facility. They will review all aspects of your clinical and business operations. The surveyors will ask to review a multitude of items and one of them will follow a patient through the entire treatment process. The Life Safety surveyor will focus on the building and Life Safety Codes. 

Although aiming for a perfect score, even the most highly functioning ASCs are typically cited for something.  That’s the nature of the beast.   Surveyors, intent on ensuring safety and quality of care for patients and staff alike, seek strict adherence to their certification standards.  Deficiencies cited, no matter how “minor,” prompt a Plan of Correction.  

Upon completion of your survey, you will receive a report via certified mail.  The report, which usually arrives within a few weeks of your survey, will include a request for a Plan of Correction (POC).  The POC outlines any deficiencies cited during the survey.  The deficiencies are reported on CMS-2567.[3]  You must respond to each deficiency with specific details pertaining to the corrective actions you plan to take to fully resolve the citation.  Your responses are recorded on the right side of the form. 

Components of Your Plan of Correction (POC)

Five main components need to be included in your POC:

  1. The first component is the deficiency standard number and a detailed statement of what needs to be corrected. This should be a concise sentence related to the shortcoming. 

If you are cited for expired medications in your inventory, for example, your response could be:  Q181. The entire medication supply will be monitored monthly for expiration dates.

  1. Next, specify how the deficiency will be corrected. Note detailed information about the corrective action taken and who was involved.  List all the items you completed to correct the inadequacy and maintain documentation regarding how you addressed the issue. 

For example:  Performed staff training on 12/12/2016.  All clinical personnel were in attendance.  Reviewed policy on expiration of medications and solutions.  Revised policy to clarify preference for single dose vials and ampules.  Responded to questions from staff regarding who retains responsibility for monitoring medication expiration dates.

  1. The third component notes how you will ensure ongoing compliance with the corrected deficiency – via random audits, for example. If you do audit, retain documentation of audit results.  Be specific about how you will monitor the corrections made.  Ensure monitoring is consistent and timely.  Clearly state how you will maintain compliance.

For example:  Updated emergency cart medication lists.  Began actively monitoring the expiration dates of all medications throughout the facility. Implemented random audits of the medication supply to ensure compliance. Initial audit was conducted on 12/16/2016 in various locations around the facility.  No expired medications were found. Compliance expectation is 100% removal of expired medications from floor stock as evidenced by monthly inspections.

  1. Name the responsible party for completion of each task and ensure ongoing compliance. You are permitted to use a person’s name but noting someone’s title (e.g., Clinical Director or Business Office Manager) ensures responsibility is linked to a defined role rather than a specific individual. 
  1. The final component is provision of a completion date for the deficiency. Ensure the deficiency is corrected by the date you set.

Next Steps

Upon completion of the plan, sign and date the form.  Return the document to the person and address noted on the Plan of Correction.  You typically have 10 days after receipt of the POC letter to return your response.

Make sure you retain a copy of the POC on file at the center with all your corrective action documentation.  As you work through the POC and collect supporting documentation, keep everything together in one binder.  This is very helpful in the event of a re-survey.

The CMS regional office will review your POC.  You can then expect a response letter from them regarding acceptance or denial of your plan of correction.  If your POC was accepted, the letter will also inform you whether a re-survey will occur.  A rejected POC will contain information regarding any changes that need to be made and a new deadline for completion.  Update the POC and return per the letter’s instructions by the specified due date.

Conclusion

Although preparing, undergoing, and responding to a survey is a daunting task, surveys provide us with opportunities to view our ASC operations from the outside in.  They allow us to implement best practices that ultimately lead to a center of excellence, a goal we are all trying to achieve.  Don’t let the prospect of an unannounced survey worry you.  Preparation and organization is key to successfully completing your survey, even if you are required to submit a plan of correction.

Kelli McMahan – Vice President of Operations

[1] https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/som107ap_i_lsc.pdf

[2] https://www.cms.gov/Regulationsand-Guidance/Guidance/Manuals/downloads/som107ap_l_ambulatory.pdf

[3] https://www.cms.gov/Medicare/CMS-Forms/CMS-Forms/Downloads/CMS2567.pdf

Jan 10
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Front Office Personnel

Best Practices for Hiring Some of the Most Important Roles in Your ASC – Your Front Office Personnel

By ASC Management No Comments

Some of the most difficult positions to fill in a surgery center are in the front office.  If you focus on hiring someone with a positive attitude who enjoys greeting patients and talking with family members, they may spend their entire day happily conversing but fail to attend to the mounting pile of paperwork.  Conversely, if you focus on hiring someone who accurately processes all that paperwork and is detail oriented, they may have a difficult time acknowledging the presence of others.  What’s an administrator to do?

Perhaps one of the best places to begin is with task delineation.  If you can afford to hire several employees, segregate front office duties by aligning them with specific personality traits.  Prepare job descriptions that support those traits.  Employees who enjoy interacting with others are best suited for greeting patients, securing pre-authorization of services, obtaining physicians’ signatures on medical records, working with physicians’ schedulers, and ensuring vital information is communicated to colleagues and family members.  Those who have an eye for details and are inclined to double-check their work can be tasked with verifying benefits, registering patients, entering data into the patient accounting system, securing patient payments, overseeing petty cash transactions, and obtaining implant invoices from vendor reps before they leave the facility. 

Developing comprehensive job descriptions with personality traits in mind should then lead to interview questions designed to elicit the attitudes, values, and skill sets that are important to you, your team, and your business.  If you are seeking someone who possesses a high level of integrity, asking an applicant to tell you about a time it was necessary for them to admit to others they made a mistake may reveal their capacity for being honest and humble.  Or posing a question about how they react when they are asked to do something beyond their capabilities could provide you with insight into their initiative, determination, and capacity for growth. 

If you intuitively sense the prospective employee is a good cultural fit, move on to technical skill assessment.  Attention to detail, for example, can be assessed in a variety of ways.  Start with the applicant’s resume and/or employment application.  Are there typographical, spelling, or grammatical errors?  If so, they may not be someone who takes the time to double-check their work (or the work of others if their resume was prepared by a professional).  Next, replicate the working conditions by administering a time-based screening tool to assess the applicant’s ability to quickly and accurately identify transposed numbers and letters under pressure. Finally, pay attention to the prospective employee’s responses to instructions you provide and/or interview questions you ask.  While it is easy to misunderstand someone else’s intent during these types of exchanges, applicants who possess attention to detail will typically request clarification to ensure they are responding appropriately.

When you sense you’ve identified a solid candidate, ensure you check references.  Checking references can be tricky – many former employers have policies in place preventing them from extemporaneously responding to questions, choosing instead to only confirm employment dates, position held and, if you’re luck, eligibility for rehire.  However, for those who are willing to discuss the skill sets, personality traits, and work performance of your potential hire, ensure you use their time wisely.  Carefully craft your questions to address items essential for effective performance in your work environment.  And be sure to tap into resources that will provide an honest assessment – former (or current) direct supervisors who are listed on the candidate’s job application, for example.  Recognize the list of references provided by an applicant with his or her resume may contain names of friends or co-workers who may not be familiar with how well the candidate performed on the job but are more than happy to provide a glowing recommendation.

Finally, when you make your job offer, if there are contingencies – successful completion of a background check or drug screen, for example – note how the applicant responds.  If they drag their feet on completing authorization paperwork or physical tests, they are waving a red flag regarding their willingness or ability to follow-through. 

Your assessment of the applicant should continue throughout the onboarding process.  The first couple of weeks your new employee is on the job will provide you with a better idea of what you’ve gotten yourself into.  If you believe the individual oversold themselves and is under-delivering, dig below the surface to determine the root cause.  Has the onboarding process (or lack thereof) contributed to confusion regarding expectations?  Are there tools that need to be provided and/or reviewed to assist the employee attain success in task accomplishment?  While it’s important to work on finding what’s leading to your new hire’s underperformance, sometimes it’s just not the fit you initially envisioned.  It’s okay to recognize that and part ways with the individual rather than allocating additional resources to a situation that isn’t working for either of you. 

Performing due diligence throughout each step of the process provides you with the best chance of finding someone who is the perfect fit.   That’s as satisfying as finding the puzzle piece that has baffled your entire extended family for the better part of a week during your annual holiday ski vacation! 

Kim Woodruff – Vice President of Corporate Finance & Compliance 

Jan 04
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Port Jefferson Surgery Center

De Novo ASC Development Alive & Well: New ASC Construction Underway in New York

By ASC Development No Comments

One of the most rewarding aspects of Pinnacle III’s business is partnering with physicians and hospitals who have identified a need in their immediate community to increase their patients’ access to ambulatory care.  We enjoy lending our expertise to de novo ASC development – building on our partners’ initial concept and ensuring their vision becomes a prosperous reality.

Many of our business opportunities arise from word of mouth.   In 2015, prompted by a recommendation from a satisfied physician client, Pinnacle III met with representatives of John T. Mather Memorial Hospital and 19 community physicians to explore the opportunity of developing an ASC in Port Jefferson, New York.  Upon determining Pinnacle III’s business model and values coincided with their needs, we were invited by the group to collaborate with them on this endeavor.  Ground breaking for the new surgery occurred on November 22, 2016.   

Here is a transcript of the project’s press release:

Surgery center construction underway in Port Jeff Station
by Kevin Redding
November 30th, 2016

With construction officially underway in a secluded lot on Route 112, North Shore residents are one step closer to an efficient and cost-effective surgery center that will provide in-and-out care to its patients while eliminating many of the hassles associated with visits to the hospital.

On Nov. 22, staff from John T. Mather Memorial Hospital and 19 community surgeons stood on the site in hard hats and broke ground on what will be the freestanding Port Jefferson Ambulatory Surgery Center in Port Jefferson Station. The outpatient facility will feature six operating rooms equipped to handle procedures in orthopedics, ophthalmology, pain management, general surgery, neurosurgery and otolaryngology. The project, which cost approximately $12 million and has been in the planning stages for about five years, will be far less expensive to run than a hospital, which means cost savings for patients and the health care system overall. It will also open up more space at Mather for patients that require a more complex procedure and a lengthier hospital stay.

Those involved in the project said they hoped for the facility’s doors to officially open in the summer of 2017. For now, though, they’re just pleased things are finally moving forward.

“As we’ve been saying — at long last,” Kenneth Roberts, chief executive officer of Mather Hospital, said during the groundbreaking. “We’ve been working on this project for a long time now, so we’re very happy to see it finally getting pushed forward.”

During an indoor celebration after the groundbreaking ceremony, Mather’s Director of Orthopedic Surgery Michael Fracchia said he was excited about what the center will mean for the community.

“People love these types of facilities because they can get in-and-out service and it’s truly less intrusive on their lives,” Fracchia said. “If you have something done in a hospital, it’s always an all-day event, no matter what it is. But at the surgery center, you seem to be able to get in and out more efficiently and that saves you personal time, saves money, and saves cancellations. It just makes the overall patient experience so much better.”

Fracchia said the facility will be able to run more efficiently because it won’t need the sort of complex technologies often found in hospitals. A patient might need an intensive care unit or an MRI or CT scan, he said, and while these are wonderful technologies, they’re also expensive and require maintenance. By eliminating these systems, the surgical centers can treat more patients at a quicker pace.

“We want to provide more care,” said Brian McGinley, orthopedic surgeon and president of the project. “We can potentially do more while maintaining our inpatient surgery at Mather. The community will have access here, rather than having to go to Nassau County or into the city.”

McGinley said that while planning the project, the team interviewed many companies that specialize in developing ambulatory service centers around the country. They found a fitting partner in Pinnacle III, a company based in Colorado that has successfully facilitated the opening of comparable facilities nationwide. This will be the first Pinnacle III facility in New York State.

In a press release, Robert Carrera, the CEO/president of Pinnacle III, said the company is excited to partner with and assist the local physicians as well as Mather Hospital in bringing high quality and cost-effective services to the Port Jefferson area.

The doctors all agreed on the project’s mission: to provide cost-effective quality health care to as many people on the North Shore as possible.

“You come in here, you drive in, you get taken care of and you don’t have to go through all the hoops that you would at a hospital,” Port Jefferson-based general surgeon Nicholas Craig said. “The doctors have all been in the community for a long time. We not only work here, we live here, so you get taken care of by people who care about their community … and when you care about your community, you care about the people in your community, and that’s what this is all about.”

The high traffic, fast-paced New York market has yielded a desire for more localized, high quality health care in New York’s diverse communities.  Pinnacle III is exploring other opportunities on the eastern seaboard.  For more information on the de novo development services we provide, visit https://www.pinnacleiii.com/asc-management/de-novo-development/ or contact Trista Sandoval at tsandoval@pinnacleiii.com or 970.492.6059.