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Nov 02
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Improving Clinical Staff Efficiency with ASC Business Education

By ASC Management, Leadership No Comments

Gradually moving up the ASC job ladder provided me with opportunities to learn a great many things. One of the most significant lessons arose not long after I moved into a management position.

As a nurse, my focus was on delivering the best care possible to every patient that crossed my path. When we delivered great outcomes, I felt successful. Because there were always patients for me to care for, I assumed the ASCs I worked in were also successful businesses.

My outlook changed when I became a manager. My effectiveness as a manager requires focusing on the bigger picture. A significant part of that picture still includes the delivery of safe, compliant care. However, another sizable part involves the financial side of running an ASC. I felt very comfortable with the former and completely unprepared for the latter.

In a clinical position with no management duties, I didn’t stop to consider the ASC business. I didn’t know the reimbursement we receive for a case covers everything we do for patients, from the moment they walk in the door until they go home. It also covers the ASC’s expenses, including our surgical supplies, utilities, rent, and, of course, salaries. I did not receive any relevant ASC business education until I assumed a management position.

Receiving an ASC business education changed my perspective on the delivery of care. Now, every time I see an unused towel or suture in the trash, I equate it to money – money that could go toward better equipment, new technology, and pay raises. I quickly surmised conveying some ASC business education basics to my clinical staff would likely go a long way toward cutting our costs.

Here are some of the ways I approach providing ASC business education to clinical staff.

Allocate time. During our monthly staff meetings, I commit time to discuss our business. I gauge what staff members do and do not understand. I provide clarification when they have specific questions. Once a quarter, I dedicate most of a meeting to ASC business education. This allows me to dive more deeply into specific topics. Since much of what I cover is new, I spread out education to avoid overwhelming staff. I want to teach, not scare them.

Keep it simple. Clinical staff don’t need to know every little detail about the ASC business. When I explain concepts like reimbursement, inventory management, just-in-time ordering, and case costing, I take a “101” rather than a “301” approach. I define concepts using basic terms and outline how they affect the ASC’s bottom line. I focus on how improvements in our ASC business performance benefit patients, staff, and facility.

Break down costs. Sometimes providing a little data can help drive a point home. Our ASC uses Project C.U.R.E. bins to gather medical supplies and equipment for donation. Staff discard unused items from surgical packs into these bins. After these bins fill up, I take pictures of the items inside and put a cost to them. I show these pictures and share the financial breakdown with staff. I also share data comparing the cost of “red” medical waste versus regular waste and disposable versus reusable supplies. Talk about eye-opening experiences!

Challenge staff. Once staff gain a better appreciation of waste costs, we attack our surgical packs. I ask staff to look at the packs to determine what is actually needed in them. At times, staff indicate rarely used items are included in the pack per physician request. In these instances, I speak with the physician. We typically remove the item from the pack but make sure it is available in the room during surgery. That’s a win-win!

New isn’t always necessary. On one occasion, an influx of non-ambulatory nurses joined our ASC. The facility they previously worked in purchased everything new. I educated them about refurbished equipment. I emphasized our use of this equipment did not jeopardize the delivery of high-quality care they were used to providing but did save us money.

Focus on safety. When speaking about cutting costs with your clinical staff, expect some looks of concern. Staff may translate “cutting costs” to mean “cutting resources” and, therefore, “cutting corners” on safety. Convey to staff the ASC will not authorize cuts that could jeopardize safety.

For example, we were using a lot of sterile towels during non-sterile cases. When I addressed how the use of non-sterile towels during these cases would benefit the ASC business, I also explained why doing so wouldn’t increase risk.

Engage Staff, Grow the ASC Business

As my clinical staff gained a better understanding of our ASC business model, they embraced the challenge of finding and implementing cost-cutting changes. With this mindset, we achieved significant savings in a short amount of time.

I know we can always do better. That’s why I try to ensure our clinical staff always have the business education of our ASC operations in the back of their minds. It’s easy, even for leadership, to become complacent when things seem to be going well. But in a health care environment where every dollar really does matter, there’s no room for complacency, and no reason not to empower all staff to make a difference in the bottom line.

Tara Demuth-Fenton, Director of Operations

Oct 26
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ASC Vendor Contracts – How to Track Service and Save Time!

ASC Vendor Contracts – How to Track Service and Save Time!

By ASC Management No Comments

Surgery center stakeholders expect administrators to proactively evaluate ASC vendor contracts and continually assess vendor performance to ensure their ASC is receiving high-quality services. These tasks not only ensure ASC operations run smoothly and cost effectively but maintain compliance with expected quality metrics.

ASC vendor contracts are defined as services obtained from an agency or vendor external to the facility. Examples of vendor contracts your surgery center may hold include laundry, environmental services, transcription, medical waste disposal, lab/pathology, etc. Your medical supply distributors also fall under the vendor classification.

While this task may seem time-consuming and onerous, here are some ideas on how to streamline the process of regularly assessing if your vendors are meeting your needs.

First, get organized. A best practice is keeping all your ASC vendor contracts in one location where they can easily be accessed. A hard copy contract binder or an electronic folder with multi-user access may meet this need. Establish a master list or spreadsheet of all the service contracts held by your facility. Include information for each vendor – contact information, expiration dates, billing cycles, and service(s) provided. File the master list at the front of your contract binder or on your computer desktop for frequent reference. This list will come in handy for monthly OIG verifications and periodic quality reviews.

Your facility’s quality plan should include an annual review of your ASC vendor contracts. Tracking the quality of the services provided by external vendors is essential. This is because the facility holds ultimate responsibility for the provision of quality services regardless of who is supplying them.

To assess ASC vendor quality, set up one or two measurable, mutually-agreed upon benchmarks or goals. For example, you might establish a benchmark with your laundry service to send no more than ten pieces of torn or unusable linen items to your facility per quarter. Or, you may want to track the return rate of your pathology reports to determine if they are received within the contracted terms. You could track your medical supply distributor’s fill rates to determine if they are meeting your expectations. Tracking controlled variables may prompt you to establish other benchmarks and formalize them in your service contracts. Schedule periodic meetings with your vendors to share measurable results and any new expectations.

Once quality measures are established, add them to your master list. Leave extra space to record the status of each quality measure and a section for comments regarding quality or service. Make sure any poor or unsatisfactory ratings are backed up with specific comments. Explain any non-compliance issues by comparing them to your set standards. Remember to document positive comments for excellent service.

Review poor ratings to determine if there are any trends in declining service. The service review process and subsequent actions taken may lend itself to a quality improvement study. You can use these trends to decide if you need to meet with vendors for corrective action or if it’s time to vet out other vendors for a possible change in service. Be careful not to jump to conclusions. Give vendors a reasonable amount of time to address identified issues.

Combining quality indicators and service assessment into an ASC vendor spreadsheet makes annual presentations to your governing body organized, concise, and relative. This tool also serves as a tremendous time saver because you can proactively address ASC vendor contract expirations, quality assessments, and service expectations. Last, but certainly not least, this system allows you to identify problems early and establish improvement plans with your vendors. If efforts to improve fall short, recommendations to the governing board to change vendors are more likely to be met with support and buy-in due to your continuous documentation, due diligence, and assessment.

Implementing this process will earn you a pat on the back for saving time, while simultaneously addressing quality, due to your strong planning and organizational skills. That’s a win-win for everybody!

Kelli McMahan, VP of Operations

Oct 04
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Safe Medication Practices: Understanding CMS' Standard for ASCs

Safe Medication Practices: Understanding CMS’ Standard for ASCs

By ASC Management No Comments

Highly publicized instances of patient complications associated with compounded sterile preparations (CSPs) have increased scrutiny of safe medication practices in ambulatory surgery centers. Citations are being issued related to safe medication preparation and administration. There is confusion, even among surveyors, on the use of some multi-dose medications, such as eye drops.

In CfC 416.48, Centers for Medicare and Medicaid Services (CMS) clarifies that ASCs must provide drugs and biologicals in a safe and effective manner, in accordance with accepted professional practice, and under the direction of an individual the ASC has designated responsible for provision of the ASC’s pharmaceutical services. In the same CfC, CMS indicates drugs must be prepared and administered according to established policies and acceptable standards of practice. To meet the standard set forth in CfC 416.48, ASC Clinical Directors will want to consider this list of safe medication practice guidelines.

Safe Medication Standards of Practice

  1. Designate a licensed staff member to oversee your pharmacy program. Make sure this individual is routinely present in your facility. Follow your state regulations as they relate to the need for a registered pharmacist. Regulations vary from state to state. Some states do not require a registered pharmacist and some, like Texas, require a weekly consult.
  2. Maintain appropriate records for the ordering, receipt, and disposition of scheduled II, III, IV, and V drugs.
  3. Understand that single-dose medications/vials (SDV) are to be used immediately upon opening, on one patient only, and then discarded. Once opened, they cannot be stored for any period of time.
  4. Date multiple-dose medications/vials (MDV) upon opening with the beyond use date. Do not take a MDV into an immediate patient care area. If this occurs, that MDV becomes a SDV for that particular patient.
  5. Ensure staff are aware of the definition of a MDV – “A vial of liquid medication intended for parenteral administration that contains more than one dose of medication.”This does not apply to eye drops. Adherence to this guideline will prevent confusion in a survey.
  6. Create a policy and procedure for the administration of eye drops. Conduct staff training on the process.
  7. Review and be knowledgeable of the questions on the CMS infection control surveyor worksheet found in Exhibit 351.

United States Pharmacopeia Chapter 797 (USP 797) provides guidelines on compounding sterile preparations in ASCs. It is acceptable for a center to compound for immediate use, but the following rules apply:

  1. The compound sterile product (CSP) must be intended for immediate use or an emergency.
  2. The CSP cannot be stored for the purpose of anticipated need or batch compounding.
  3. No more than three (3) commercially available sterile products in original container and no more than two (2) entries into any container/package/device can occur.
  4. Continuous process must be completed within one (1) hour.
  5. Adhere to aseptic technique.
  6. Administer within one (1) hour, or discard CSP.

Examples of immediate use CSPs are antibiotic solutions, blocks, and irrigating solutions. Dilating solutions may also fall into this category. The development of best practices for immediate use CSPs is important and should be included in training and competencies for licensed staff involved in the preparation, transportation, and/or administration of CSPs.

The area where CSP preparation takes place should be quiet and free from distractions. The designated staff member should disinfect the area, complete proper hand hygiene, and wear appropriate personal protective equipment (PPE). The entry ports must be disinfected. Calculations should be verified to ensure accurate mixing takes place. Proper labeling must occur prior to removing the CSP from the preparation area and administering it to the patient.

To ensure safe medication practices and compound sterile preparations are compliant with CMS regulations, ASC clinical leaders may find it helpful to refer to the lists above. Additional information on CMS guidelines is available via the CMS infection control surveyor worksheet and the CMS website.

Jovanna Grissom, Vice President of Operations

Sep 27
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ASC Disaster Response: A Case Study

ASC Disaster Response: A Case Study

By ASC Management, Leadership No Comments

This is the second part of a two-part blog series on ASC disaster response by Diane Lampron, Director of Operations. Click here for part one.

In the blink of an eye, a completely normal day in your ASC, can be upended by a natural or man-made disaster. And it can take days, weeks, or months to return to your pre-disaster routine.

Emergency preparation is not only critical for an effective ASC disaster response, but, as we previously discussed, it’s a Medicare requirement for ASCs. Part of proper preparation is revising your emergency plan based on your response to drills, tabletop exercises, and emergency events. Every revision should improve the helpfulness of your plan. Understanding what it’s like for another ASC to respond to a disaster can further your ASC disaster response preparation.

Below are some of the critical steps taken during a Colorado ASC’s response to a ruptured pipe. The subsequent flooding caused substantial damage throughout the ASC. Areas flooded with the equivalent of sewer water included the waiting room, front hallway, registration desk, pre-op, and recovery room. The sub-sterile area also suffered significant damage. Thanks to a strong, tested emergency plan, hard work by staff, and outside support, the ASC re-opened to full capacity in three months.

Immediate ASC Disaster Response

Steps taken upon discovery of the flood and damage included the following:

  • Called the disaster code
  • Activated the emergency management plan (EMP)
  • Contacted fire department (which turned off water)
  • Ensured there were no patients, visitors, or personnel requiring evacuation.
  • Closed front entrance
  • Notified ASC leadership
  • Assessed affected areas
  • Took pictures of damage
  • Set aside damaged items/equipment (for insurance purposes, this included items that caused the damage, such as a broken sprinkler pipe)
  • Moved unaffected equipment away from damaged areas
  • Notified property insurance carrier
  • Rerouted deliveries

Activating the EMP

Activation of the ASC’s EMP triggered the following actions:

  • Established incident command team
  • Identified who would fill the roles identified in the EMP – Role assignments are critical. Each role guides the activities required to address all aspects of the disaster, from suspension of business operations to the response and through recovery.

Roles assigned included incident commander and staff (e.g., safety officer, infection preventionist, public information officer) as well as sections for operations, planning and logistics, and finance/administration. If you are not familiar with the responsibilities of these positions, the Federal Emergency Management Agency provides helpful resources here. Note: Some of the activities that took place under these sections are discussed below.

  • Developed incident action plan which established objectives throughout response to the incident and underwent regular updates as recovery progressed
  • Notified the facility’s governing board

Communication

The following steps were taken to disperse information regarding the incident and closure:

  • Changed telephone greeting
  • Posted notice on center’s website
  • Notified physicians’ offices
  • Notified the state’s Department of Public Health
  • Issued press release
  • Notified the state’s Department of Fire and Life Safety
  • Notified the facility’s accreditation organization

Disaster Recovery Work

The project was separated into five phases to be completed prior to a re-opening phase:

  1. Mitigation/ restoration
  2. Safety
  3. Demolition
  4. Rebuilding/construction
  5. Risk reduction

Mitigation/Restoration

Steps taken included the following:

  • Restoration company commenced water cleanup and mitigation activities working 24/7 to mitigate further damage
  • Industrial hygienist conducted assessment and took samples
  • Infection control risk assessment (ICRA) performed

Safety

Steps taken included the following:

  • With fire sprinklers offline, fire watch implemented
  • Conducted and documented fire watch walkthrough every 30 minutes during recovery period
  • Created signage for emergency fire exits

Demolition

Steps taken included the following:

  • Brought in contractor for demolition and construction phases of the work
  • Obtained permits needed for demolition and renovation/construction

Rebuilding/Construction

Renovation plans previously scheduled for a future date were incorporated into the disaster recovery work to save on construction costs.

Risk Reduction

Planning included efforts to help reduce the risk of a reoccurrence. For example, additional insulation was installed and a new checklist was created for facility personnel to follow when investigating leaks.

Incident Command Officers and Sections

The incident command officers and sections oversaw the ASC disaster response work described above. Additional responsibilities are described below.

Safety Officer

The safety officer performed the following tasks:

  • Daily walkthroughs for interim Life Safety measures, ICRA, and hazard control risk assessment ensuring corrections were made as needed
  • Daily count of narcotics and medication storage security checks

Infection Prevention Officer

The infection prevention officer performed the following tasks:

  • Daily ICRA assessment walkthroughs
  • Ongoing communication with industrial hygienist regarding assessment and safety tests

Public Information Officer

The public information officer performed the following tasks:

  • Issued regular press releases providing updates on repairs
  • Kept website notices and telephone greeting current
  • Developed wayfinding signage and maps
  • Provided weekly briefings with facility employees

Planning and Logistics Section

The planning and logistics section performed the following tasks:

  • Determined staff availability and work assignments
  • Determined staff pay structure during recovery
  • Worked with local hospital to accommodate ASC patients and coordinate ASC staff support
  • Provided hospital with necessary supplies, equipment, and instrument sets to accommodate procedures rescheduled from the ASC
  • Identified replacement items to be ordered immediately due to lag time in ordering and delivery (e.g., cabinets, counters, doors, carpeting)
  • Maintained communication/phone system and information technology (IT)
  • Coordinated re-establishment of services (e.g., housekeeping, waste removal, linen)
  • Maintained “disaster book” of all response activities

Operations Section

The operations section performed the following tasks:

  • Obtained temporary storage for unaffected equipment that required relocation
  • Identified need for replacement equipment and IT
  • Ensured the hard drives of damaged computers were stripped/wiped before disposal
  • Developed risk reduction plans

Finance/Administration Section

The finance/administration section performed the following tasks:

  • Conducted walkthrough with insurance adjustor
  • Compiled all invoices to be paid
  • Tracked lost revenue
  • Provided cost analysis and cash flow data to governing board
  • Provided insurance carrier with all requested information (e.g., projection of business loss amount, list of damages, photos)

Reopening

The following steps were taken to ensure a successful reopening:

  • Conducted mock patient walkthrough of new space
  • Posted required documentation previously removed (e.g., ASC license, patient rights and responsibilities, HIPAA, accreditation certificate)
  • Reinstated facility logs (e.g., refrigerator temperature, malignant hyperthermia cart check, defibrillator test and cart check)
  • Changed telephone greeting and website notice
  • Issued press release
  • Planned, publicized, and hosted open house
  • Celebrated re-opening and facility’s return to normal operations!

You Can Never Be Too Prepared

As I write this, Hurricane Harvey has wreaked havoc on Texas. Fires are consuming hundreds of thousands of acres across multiple western states. Hurricane Irma has Florida in its crosshairs. There is no shortage of news about the extensive damage that occurs in the wake of these disasters.

On a positive note, there are reports highlighting the improved preparation and response effort thanks to lessons learned from disasters like Hurricane Katrina and Rita. There will undoubtedly be lessons learned from Harvey and Irma that will help with future disaster planning.

Hopefully the Colorado ASC disaster response outlined above helps your surgery center identify opportunities for its own preparation improvement. If your ASC experiences a disaster, I encourage you to share your own response efforts. Relaying your story to an industry publication or presenting on it at a state or national meeting could ensure other ASCs benefit by learning from your experience.

I will leave you with this key takeaway. You cannot plan for everything. However, the more you prepare, the better off you should be when faced with the unexpected.

Diane Lampron, Director of Operations

Sep 19
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2017 OAS CAHPS: Should Your ASC Implement CMS’ Survey in 2017?

2017 OAS CAHPS: Should Your ASC Implement CMS’ Survey in 2017?

By ASC Management, Payor Contracting No Comments

The Outpatient and Ambulatory Surgery Consumer Assessment of Healthcare Provider and Systems (OAS CAHPS) collects information about patients’ experiences of care in ambulatory surgery centers (ASCs) and hospital outpatient departments (HOPDs). The survey gathers patient perceptions related to communication and care provided by surgery staff, expectations prior to surgery, and planning related to discharge and recovery. Enforced implementation of the survey has been delayed until 2018, with the specific date being released this November. Surgery centers across the country are deciding if they should implement the survey as planned, or wait until the Centers for Medicare and Medicaid Services (CMS) begins enforcing survey implementation.

To assist in decision making, it’s helpful to review information regarding the OAS CAHPS Survey.

Why is CMS developing this survey?

  1. The number of ASCs has increased considerably in recent years as has the surgical case volume at both ASCs and HOPDs.
  2. Medicare expenditures from outpatient surgical sites for ASCs and HOPDs also continues to rise.
  3. Implementation of OAS CAHPS will provide CMS with statistically valid data on the patient experience to inform quality improvement and comparative consumer information about outpatient surgery facilities.

The results of the OAS CAHPS will be used to:

  1. Provide CMS with information for monitoring and public reporting purposes,
  2. Provide a source of information enabling prospective patients to make informed decisions in outpatient surgery facility selection, and
  3. Aid facilities with their internal quality improvement efforts and external benchmarking comparatively with other facilities.

What modes are available to administer the OAS CAHPS?

  1. Mail only
  2. Telephone only
  3. Mixed mode (mail survey with telephone follow-up of non-respondents)
  4. An electronic mode of surveying is currently under review.

How often is the OAS CAHPS administered?

  1. Surveys are administered on an ongoing basis.
  2. An annual minimum of 300 surveys must be completed for each facility.
  3. Participating facilities will provide a monthly sample of patients who received at least one surgery or procedure during the sample month to their survey vendor.
  4. Vendors will initiate surveys within three weeks after the sample month closes.
  5. Once a survey has been initiated it must be completed within six weeks.

The OAS CAHPS may be administered in conjunction with other surveys but sampling methods need to be followed to ensure patients are not overburdened by multiple surveys.

  1. For each sample month, the survey vendor must select the OAS CAHPS sample prior to selecting the samples for any other ASC survey.
  2. The ASCs cannot select the sample for any other facility survey they may choose to implement.
  3. The vendor must select the sample because the sample selection for OAS CAHPS cannot be disclosed to the facility.

OAS CAHPS Survey Implementation

  1. National voluntary implementation began in January 2016 with required participation scheduled to begin January 2018. CMS has proposed delaying implementation of the mandated 2018 date. The decision will be released in Medicare’s final 2018 ASC payment rule this November.
  2. It is unlikely the delay will be permanent because CAHPS surveys are already mandated in hospitals, home health, hospice, and dialysis centers.
  3. ASCs that have voluntarily participated in OAS CAHPS have received valuable information about the quality of outpatient care provided at their facility.

There are pros and cons to implementing the survey now versus waiting until CMS mandates the survey next year. It is often better to prepare early. What should administrators consider in determining what is best for their center?

Reasons to delay the OAS CAHPS Survey until 2018:

  1. Financial and administrative burden of submitting the data.
  2. Decision on the electronic survey mode option.

Reasons to implement the OAS CAHPS Survey now:

  1. You will know where your surgery center stands before mandatory reporting begins.
  2. You will have an opportunity to address identified issues for improved survey results.
  3. You can learn and understand your patients’ perceptions and make changes to increase overall satisfaction.
  4. Post-discharge surveying allows for a better assessment of the entire surgery process.

Peak One Surgery Center located in Frisco, Colorado has chosen to move forward with implementation of the OAS CAHPS survey now. It was an easy decision for us because it will allow us to get ahead of the competition. We can build out processes with our vendor and adjust our internal reporting systems. There will also be time for staff, physicians, and administration to learn the program. When my fellow administrators ask, I advise them to begin work with a vendor on voluntary implementation of the OAS CAHPS survey to avoid being at a disadvantage when the survey becomes mandatory.

Michaela Halcomb, Director of Operations

Sep 13
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ASC Emergency Preparedness: Checklist for Compliance

ASC Emergency Preparedness: Checklist for Compliance

By ASC Governance, ASC Management, Leadership No Comments

Disasters come in many forms. They can be natural – a hurricane, tornado, flood, earthquake – or man-made – a chemical spill or cyberattack. While the impact of disasters varies greatly, what ultimately matters is how your ASC responds. An effective response, outlined in an ASC emergency preparedness plan, can protect and save lives, reduce facility damage, and make recovery easier.

Critical to such a response is the development of an ASC emergency preparedness program. I witnessed its value firsthand at a Colorado ASC that suffered a significant disaster in 2015. The ASC’s plan was instrumental in containing the damage, ensuring patients received the care they needed, and expediting repairs.

If your ASC is certified by Medicare, meeting emergency preparedness regulations is a requirement. Centers for Medicare & Medicaid Services (CMS) outlined these regulations in their final rule posted in September 2016. While the regulations went into effect in November 2016, providers and suppliers have until November 15, 2017 to comply with and implement them.

Earlier this year, Pinnacle III published a blog on “What the CMS Emergency Preparedness Rule Means for ASCs.” With the implementation deadline fast approaching, I thought it would be helpful to publish the ASC emergency preparedness program requirements below. They are organized for your convenience with the intent of helping you achieve and maintain compliance.

Your program must include, but is not limited to, the following four elements:

1. ASC Emergency Preparedness Plan

Develop and maintain an ASC emergency preparedness plan. The plan must:

  • Include a risk assessment. The plan should be based on a facility- and community-based risk assessment that employs an all-hazards approach. This approach focuses on capacities and capabilities critical to preparedness for a full spectrum of emergencies or disasters specific to the location of your ASC.
  • Factor in the types of hazards most likely to occur in your area. Take into consideration facility damage, care-related emergencies; equipment and power failures, and communication interruptions, including cyberattacks.
  • Include strategies for addressing emergency events identified in your risk assessment.
  • Address the needs of the patient population, including services your ASC can provide in an emergency.
  • Address continuity of operations, including delegation of authority and succession plans.
  • Include a process for cooperation and collaboration with emergency preparedness officials (e.g., local, regional, state, federal) in their efforts to maintain an integrated emergency response.
  • Include documentation of your ASC’s efforts to contact emergency preparedness officials and participate in collaborative, cooperative planning efforts.
  • Undergo a review and update at least annually.

2. Policies and Procedures

Develop and implement ASC emergency preparedness policies and procedures. Base them on the emergency plan and risk assessment discussed above and communication plan discussed below. Review and update policies and procedures at least annually. At a minimum, policies and procedures must address the following:

  • A system to track the location of on-duty staff and sheltered patients in your care during an emergency. Note: If you relocate on-duty staff or sheltered patients during an emergency, document the name and location of the receiving facility/location.
  • Safe evacuation from your ASC, including consideration of care and treatment needs of evacuees, staff responsibilities, transportation, identification of evacuation location(s), and primary and alternate means of communication with external sources of assistance.
  • Means to shelter in place patients, staff, and volunteers who remain in your ASC.
  • A system of medical documentation that preserves patient information, protects information confidentiality, and secures and maintains records availability.
  • Use of volunteers in an emergency and other staffing strategies, including the process and role for integration of state and federally designated health care professionals, to address surge needs.
  • Your ASC’s role in the provision of care and treatment as an alternate care site identified by emergency management officials, in the event of a waiver declared by the U.S. Health and Human Services Secretary.

3. Communication

Develop and maintain an ASC emergency preparedness communication plan. Review and update the communication plan at least annually. The plan must include the following seven components:

  • Names and contact information for staff, organizations providing services under arrangement, physicians, and volunteers.
  • Contact information for emergency preparedness staff (e.g., federal, state, regional, local) and other sources of assistance.
  • Primary and alternate means for communicating with your staff and emergency management agencies.
  • A method for sharing information and medical documentation for your patients with other providers to maintain continuity of care.
  • An appropriate means to release patient information in the event of an evacuation.
  • An appropriate means of providing information about the general condition and location of patients under your care.
  • A means of providing information about your ASC’s needs and its ability to provide assistance to the appropriate authority.

4. Training and Testing

Develop and maintain an ASC emergency preparedness training and testing program based on the emergency plan, risk assessment, policies and procedures, and the communication plan discussed above. Review and update the training and testing program at least annually.

With regard to training, your ASC must:

  • Provide initial training in emergency preparedness policies and procedures to all staff, individuals providing on-site services, and volunteers (consistent with their expected roles).
  • Provide emergency preparedness training at least annually.
  • Maintain documentation of all training.
  • Demonstrate staff knowledge of emergency procedures.

To meet the testing requirements, your ASC must conduct at least two exercises annually to test its emergency plan. You must:

  • Participate in a full-scale community-based exercise. If a community-based exercise is not accessible, participate in an individual, facility-based exercise. Note: If your ASC experiences a natural or man-made emergency requiring activation of your emergency plan, you are exempt from engaging in an exercise for one year following the onset of the event.
  • Conduct an additional facility-based exercise. This can be another individual, full-scale exercise or a tabletop exercise that includes a group discussion.
  • Analyze your response to and maintain documentation of all drills, tabletop exercises, and emergency events.
  • Identify and implement improvement opportunities, revising the emergency plan as needed.

Note: If your ASC is part of an integrated health care system with a unified and integrated emergency preparedness program, you may choose to participate in the system’s coordinated program. If you do so, there are additional requirements your ASC must meet. Review the CMS final rule to identify those requirements.

Quick Tips

To achieve compliance, follow the steps provided above. Some tips that will further assist you in your emergency preparation efforts are:

  • Designate an incident commander. This individual is responsible for the overall management of the emergency response.
  • Pre-assign other incident command roles. This could include a deputy incident commander whose responsibilities include filling the incident commander role in the event the incident commander is not on-site during the emergency. It could also include command staff (e.g., public information officer, safety officer, liaison officer) and general staff (e.g., operations, planning, logistics, finance/administration).
  • Make sure your ASC has the appropriate insurance and coverage for the emergencies and disasters you are likely to face.
  • If financial, patient, and other data is stored on-site, plan for how you will protect servers and other critical information technology.
  • Consider any “what ifs.” If there is something you think could happen during an emergency, plan for it.

Improving Your Emergency Preparedness Program

Development of an ASC emergency preparedness program can help a center achieve a more successful response to a disaster. But disasters are unpredictable. An ASC emergency preparedness program can only account for so much. That’s why it is critical to take advantage of every exercise to identify areas of your plan to revise and improve.

It’s also valuable to study how other health care providers responded to actual disasters. Doing so provides an opportunity to incorporate tried-and-tested processes and practices into your plan. In an upcoming blog, I will share many of the steps the Colorado ASC I mentioned took in response to its disaster. By doing so, I hope to help your ASC prepare for what you may face one day.

Diane Lampron, Director of Operations

Sep 06
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Patient Registration Issues? Consider a Front Desk Audit

Patient Registration Issues? Consider a Front Desk Audit

By ASC Management, Revenue Cycle Management No Comments

Inaccurate patient registration can quickly derail a facility’s revenue cycle management efforts. Delayed reimbursement is costly. If your ambulatory surgery center is experiencing patient registration issues leading to lost or delayed reimbursements, consider conducting a front desk audit. Audit results often help identify training, communication, and process gaps that, once addressed, can get your center back on track.

When conducting your front desk audit, review how facility personnel collect the following items from patients:

  • Are scanned copies of patients’ insurance card(s) obtained and retained for future reference?
  • Does data entry in the patient registration sections of your patient accounting system match the scanned insurance card(s) on file? If not, what variances occurred?
  • Were the proper benefits eligibility and verification checks performed prior to the date of service?
    • Were eligibility and verification activities performed via a phone call or online?
    • If verified by phone, were the following elements – phone number, person spoken to, and reference number – recorded in patients’ accounts?
    • Were eligibility and verification details noted in patients’ accounts?
  • Were co-pay, deductible, and co-insurance details obtained and noted in patients’ accounts during the eligibility and verification process?
    • Were patients’ copays and deductibles collected on or before the date of service?
    • If not, were explanations recorded in patients’ accounts?
  • If required, were prior authorizations obtained before the date of service?
    • If not, was there information listed in patients’ accounts explaining why?

Recording audit results in a simple spreadsheet will provide you with an easy tool to assess your findings and identify trends.

Consider having staff members perform front desk audits on each other. Involving them in the assessment, education, and training aspects of patient registration auditing often yields lasting process improvements. Perhaps your ASC will realize the added benefit of a team inspired to collectively work towards an error free patient registration process.

Share this formula with them: Error free patient registration = clean claims = faster reimbursement = patient satisfaction = happy investors and staff. That’s a win-win for all involved!

Carol Ciluffo, VP of Revenue Cycle Management

Aug 30
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Diagnosis Please: It Pays to be Specific!

Diagnosis Please: It Pays to be Specific!

By ASC Management, Revenue Cycle Management No Comments

Payors often update their clinical policies in ways that modify how ambulatory surgery centers and physicians must document their interactions with, and sometimes even how they treat, their patients. Staying informed of these updates is crucial to an ASC billing team’s success in obtaining the expected reimbursements. As surgical procedures proliferate, payors are demanding an increased focus on diagnosis specificity. Physicians, surgery schedulers, coders, and billing departments all have a role in expeditiously implementing payor clinical policy changes to ensure reimbursement losses are minimized when policies change.

For example, Aetna’s Clinical Policy Bulletin #0673 changed how ASCs approach meniscectomy cases – procedures billed via CPT codes 29880 and 29881. From Aetna’s perspective, meniscectomies billed without a current injury diagnosis are deemed experimental and investigational (not reimbursable). Therefore, at time of scheduling facility personnel should be able to anticipate whether the meniscectomy case will result in payment or denial based on the patient’s history. Surgeons who add time parameters and other adjectives to the patient’s post-operative notes can clarify the type of tear to ensure medical records and letters of medical necessity do not need to accompany the claim.

The time parameters acute, chronic, acute on chronic, and recurrent are important documentation factors in ICD-10-CM. The difference between billing a specified and an unspecified code may rely on one of these time parameters. Additionally, the distinction in the operative note between an old and a new injury assist coders with proper diagnosis specificity. The indications heading of the operative note is the ideal section to include details regarding injury, trauma, acute, chronic, recurrent, or degenerative conditions.

For example, without knowledge of the patient’s medical history, the postoperative diagnosis “right knee medial meniscus tear” is coded as “M23.231 – Derangement of other medial meniscus due to old tear or injury, right knee.” According to ICD-10-CM coding guidelines, if acute or chronic is not specified, the default diagnosis – chronic – must be assigned. Your surgery center coders should query the physician to obtain greater diagnosis specificity and to gain access to the History & Physical or other parts of the patient’s medical record that clarify the condition.

Ideally, a stand-alone diagnosis reads “medial meniscus tear of right knee, current injury” with a sentence in the indications section of the operative note such as: “The patient is an 18-year-old male who suffered an acute injury to his left knee while playing basketball.” This example yields diagnosis code “S83.231A – Complex tear of medial meniscus, current injury, right knee, initial encounter.”

Other key descriptive words to include about meniscus tears in post-operative documentation are:

  • Lateral, medial, bucket handle
    • Complex, peripheral, bucket handle

Sample key descriptive words to include in post-operative documentation about rotator cuff tears include:

  • Complete, incomplete, traumatic, non-traumatic, capsule

On average, it takes payors two weeks to issue a claim response (payment or non-payment). When the diagnosis specificity in the operative note is lacking and the carrier requests medical records, an additional 30-60 days is tacked onto the carrier’s payment processing time.

To improve claims processing efficiency, maintain open, direct communication between the patient’s record keepers and the ASC billing department. Regularly review medical necessity denials in the context of clinical policies and operative note documentation. Doing so ensures you are well apprised of payor clinical policy updates and minimizes reimbursement losses.

Bethany Bueno, Director of Billing Operations

Aug 24
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What is Your Surgery Center’s Online Reputation?

What is Your Surgery Center’s Online Reputation?

By ASC Management No Comments

Trista Sandoval, Director of Business Development & Physician Relations, expands on an excerpt from PINNACLE III’s February 2017 White Paper “Looking Ahead: 10 ASC Trends to Watch in 2017.”

How is your online reputation management coming along this year? This question may seem intrusive. For those of us who have done nothing, it may seem flat out invasive. Many of us started the year with great intentions, perhaps even creating an initiative to develop an online reputation strategy, launch a program, or reach a target number of views or responses. For many, those objectives have fallen by the wayside, long forgotten whilst putting out day-to-day fires, onboarding new physicians, developing new service lines, or implementing new software.

Unfortunately, allowing online reputation to fall off our radar has negative ramifications. Why? Let’s start with what online reputation management is.

Online reputation management is the practice of crafting strategies that shape or influence the public perception of an organization, individual, or entity on the internet. It helps drive public opinion about a business and its services. Undeniably, it influences, and is influenced by, your overall reputation.

What happens when your reputation is tainted? Simply put, you lose business – and customers. In a market where the competition is high and physicians are known for being highly competent, experienced, certified professionals with proven track records, there is no room for a tainted reputation. Further, healthcare entities are beginning to favor models in which the patient experience is prioritized and continuously enhanced based on patient feedback.

Patients gravitate to their preferred provider through engaging websites, mobile-optimized scheduling features, healthcare portals where they can access their recent visit information, and pay-your-bill online features. With patients more responsible than ever for satisfying upfront co-pays and deductibles, they are more willing to research top healthcare options to obtain the highest quality, most cost-effective care.

In a study from Nielsen Report Global Trust Advertising and Brand Messages, consumers were asked to what extent they trust various forms of advertising. Ninety-two percent (92%) of individuals surveyed indicated they completely trust recommendations from people they know. Seventy percent (70%) responded that they completely trust consumer opinions posted online. This is significant, telling information on how our consumers perceive our brands and who influences their choices. It is no wonder healthcare organizations are prioritizing the patient experience and improvements based on patient feedback.

Every healthcare entity should be focused on learning how to better communicate with patients and how to better gain their trust when it comes to helping with surgical care needs.

If you find yourself in the category of most individuals who have completed little to no online reputation management efforts this year, or have put in limited effort, all is not lost. Start now!

First, identify what is being said about you. Managing reviews or creating operational changes that enhance your patients’ experience requires knowing exactly what your customers are relaying to others. Review top consumer resources – Google, Facebook, Yelp, etc. – to gauge the status of your online reputation. Take a moment to evaluate how your current online reputation differs, and aligns, with your online reputation goals.

Second, identify the platforms on which most of your patient reviews are being posted. This will be helpful in determining which platforms are most utilized and warrant efforts to improve your reputation as well as which platforms are under-utilized. You can then create your strategic initiatives based on how you want to tackle each platform.

Here are some helpful hints to remember when managing your online reputation:

1. Use Google Alerts to notify you when your brand is mentioned on the internet. You can also use the same method to alert you when your competition is mentioned to compare your popularity.

2. Respond timely to any negative reviews. Show customers you care about their experience and you value their input.

3. Remain factual. Ensure you carefully craft your responses.

4. Capitalize on bad reviews by improving your processes.

5. Avoid sharing protected health information (PHI), including pictures of patients or staff members.

6. Monitor your online platforms and identify potential pitfalls. If this is not your area of expertise, reach out to a trusted expert for guidance.

It is important you and/or your third-party advisor understand your market, industry, strategy, and goals. Define these in the early stages of your strategic planning.

Online reputation management is a process. There is no better time than now to start protecting and enhancing your brand in the digital world.

To uncover more ASC Trends in 2017, visit our white paper page.

Trista Sandoval, Director of Business Development & Physician Relations

Aug 16
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We all Wear Many Hats – An ASC Staffing Guide

We all Wear Many Hats – An ASC Staffing Guide

By ASC Management, Leadership No Comments

Ambulatory surgery centers (ASCs) are cost effective because they employ a highly efficient staffing model. In addition to traditional roles various employees and departments perform, ASC administrators and facility staff assume other non-traditional responsibilities. Every staff member wears many hats on any given day. When hiring ASC personnel, it is imperative to outline for candidates all the duties expected of them, many of which often go beyond solely providing direct patient care. ASC leaders know staffing a surgery center requires flexibility and careful consideration.

How do you devise a staffing plan that incorporates the multiple roles staff will be expected to perform while ensuring your facility remains cost effective and efficient? In this post, we highlight some of the diverse functions your surgery center staff perform to help you visualize a plan for effectively allocating your ASC’s operational responsibilities among them.

Nurse.

A registered nurse is typically solely responsible for patient care. However, in an ASC, one or more nurses may also be tasked with facility infection prevention and/or monitoring the center’s adherence to the infection control program. Ensuring nurses complete infection control duties requires building sufficient time into the schedule. Infection control may occur during non-clinical hours, on slower days when the schedule permits, or by scheduling an extra nurse on certain days to allow infection control tasks to be routinely completed.

Surgical Technician.

A surgical technician takes charge of preparing operating rooms, ensuring all the necessary equipment is prepped and assembled. Due to the nature of their role, your ASC’s surgical technician may also function as your materials coordinator. Organization and prioritization are paramount for this dual role. As materials coordinator, the surgical technician will need to order supplies, check on special orders, receive products, document purchases, account for shipments received, and remain on hand to cover procedures. Specific ordering days can be established to ensure supplies are effectively managed. Consider adding an additional staff member on ordering days, or scheduling ordering on slower procedure days. Other team members may also assist with putting away received supplies and restocking supply areas.

Nurse Manager.

A nurse manager is expected to contribute to direct patient care while also attending to their administrative duties. A facility’s nurse manager typically maintains managerial authority over the entire clinical staff. As the title suggests, the nurse manager needs to possess expertise in both clinical and administrative duties, including direct patient care and staff management, respectively. An effective nurse manager is organized and competently harnesses the assistance of facility personnel to accomplish daily, monthly, quarterly, bi-annual, and annual tasks.

A clinical nurse manager can help alleviate some of the administrator’s burden by handling the administrative and hiring responsibilities of clinical staff, as well as monitoring the use of implants and corresponding reimbursement. This delegation works particularly well because nurse managers are often in close conversation with physicians where they can adeptly advocate for the use of more cost-effective implants. Train these leaders to manage their staff members and implants, and to operate with autonomy.

Clinical Staff.

There are many other roles your clinical staff will be expected to perform in addition to their direct patient care duties. Quality assessment and control, managing safety protocols, pharmacy ordering, and data input are a few examples. The person responsible for quality assessment and control will need allocated time to run reports, conduct research, compile items for meetings, assist with staff education, etc. The safety officer will need to conduct audits, assist with staff education, and compile items for meetings, among other tasks. Clinical staff must fulfill many important roles. They can accomplish smaller tasks between patients or as the schedule starts to slow down.

Front Office Personnel.

These employees wear multiple hats every day and many times in a day. They can be responsible for reception, registration, medical records, scheduling, verification and authorization of benefits, and patient collections. They may perform some HR functions assisting the administrator with onboarding, benefits administration, personnel file maintenance, and payroll. The unique skills they possess should not be overlooked when special projects or mini-task force committees arise.

The size of your facility and the processes you put into place will determine how many hats you need and who will wear them. Try to allocate tasks based on employee strengths.

Make a list of the crucial roles, then designate each role to a specific title (e.g., RN). Doing so will help you identify what type of person you may need to hire or move into each role.

Hire personnel who are willing to function in multiple roles. Understand this multiple role mindset may be a departure from an employee’s previous environment. Set expectations accordingly.

Incorporate time to achieve these multiple roles into your staffing schedule. Take advantage of low volume times. Set aside staffing time for special tasks/projects. Use flexible hours to effectively staff for projects and clinical time on the floor.

To employ the use of an efficient flexible staffing ASC model, ASC administrators and leadership teams must ensure staff have comprehensive job descriptions with clearly defined responsibilities that collectively cover the entirety of an ASC’s operational responsibilities.

These steps will help unleash the power of your ASC team.

Kelli McMahan, Vice President of Operations