Hugh Morgan is quality assurance officer for Somnia Anesthesia Services.
Q: We have a question about the new CMS Conditions of Participation for anesthesia services. We have been made aware by our anesthesia provider that at this time the new regulations are directed at hospitals and hospital-ambulatory surgery centers only. Has there been any information about when they will affect freestanding surgery centers or when they might be incorporated in the Conditions of Participation for freestanding surgery centers?
Hugh Morgan: Without question, it is has become challenging at best for hospitals and ASCs alike to keep abreast of and remain compliant with the ever changing regulatory and accreditation requirements affecting the care and services provided in those facilities and particularly, the unique and specialized changes that impact medical specialties such as anesthesiology. These challenges are some of the very reasons why it is so critically important to have a trusted, transparent and collaborative anesthesia partner who keeps you fully informed and compliant with the ever changing requirements.
The CMS Conditions of Participation (CoP) apply to both hospitals and ASCs regardless of whether the ASC is a standalone center or affiliated with a hospital health system. The hospital CoP contains a separate carve out for anesthesia "interpretive guidelines" which, as of May 2010, contained the new requirements that the hospital-based anesthesia department is now responsible for the provision of anesthesia and analgesia services throughout the entire hospital. Anesthesia services provided in ASCs are contained in the all-inclusive "Interpretive Guidelines for Ambulatory Surgical Centers," CMS Manual Pub. 100-07, Transmittal 56, Appendix L/416.42, 416.52, Dec. 2009.
Within the Interpretive Guidelines for ASCs, the anesthesia-specific sections contain the requirements for the credentialing and privileging of clinicians authorized to provide anesthesia services within the center, as well as details regarding the pre- and post-anesthesia assessment and documentation requirements. There are also numerous other sections relating to anesthesia that include the handling and security of medications, etc. Although the CoP/Interpretive Guidelines for both hospitals and ASCs are typically updated and released annually at the beginning of each year, it's been common practice in the past year for CMS to release multiple updates throughout the year in an attempt to clarify their initial requirements language. Thus, it's good practice to occasionally check in to the CMS website or with your local carrier to ensure that you stay current and compliant with the latest regulations impacting your facility.
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