Sharon Morrison, RN, director of clinical support for Physicians Endoscopy in Doylestown, Pa., cites 10 recent changes in how CMS surveyors deal with ambulatory surgery centers, including aspects of the May 2009 change in Medicare Conditions for Coverage for ASCs, updated in Dec. 2009.
1. Surveys are more frequent. Under the stimulus bill, Congress allocated $10 million more for ASC surveys. Surveyors for 43 states were expected to visit one-third of non-accredited ASCs in 2010.
2. Surveyors now work in teams. In the past, usually one person surveyed one ASC and typically stayed for just one day. Now a team of 2-4 surveyors, depending on factors such as the size of the facility, shows up and typically stays for two days, sometimes three. Each has a different area of focus, such as reviewing center policies, following patients through the entire process, checking adherence to safety codes or examining medications.
3. Individual patients followed. "Surveyors generally interact more with patients than they did before," Ms. Morrison says. They now select at least one patient to follow from admission to discharge. This is called the tracer methodology, which The Joint Commission introduced a few years ago for hospitals.
4. Infection control program now required. This new Conditions for Coverage requires ASCs to maintain an infection control program to prevent, control and investigate infections and communicable disease, based on nationally recognized infection control guidelines. A designated infection control officer trained in infection control must oversee the program.
5. More interaction with physicians, staff. Surveyors are interacting more with ASC staff and physicians. "Rather than challenging the physicians' clinical approach, they are focusing on adherence to aseptic requirements," Ms. Morrison says.
6. Sound policy and procedures. Due to the new requirements, "our centers are more meticulous about documenting training of staff," Ms. Morrison says. Surveyors may ask for such documentation, which may include a sign-in log for attendees, a copy of the agenda and list of the materials used.
7. Longer worksheet for infection control. The surveyor's worksheet for infection control is now 17 pages long. The section on Infection Control Practices Assessment focuses on specific practices in five areas: hand hygiene and use of personal protective equipment, injection safety and medication handling, equipment reprocessing (such as sterilization and high-level disinfection), environmental cleaning and handling of point-of-care devices (such as blood glucose monitoring equipment).
8. Patient rights requirement. This new condition requires ASCs to inform patients of their rights and responsibilities. The list includes the right to make informed treatment decisions, voice grievances on care, be fully informed about treatments and expected outcomes, be guaranteed personal privacy, receive care in a safe setting, and be free from discrimination, abuse or harassment.
9. Advance directives. The ASC must develop policies and procedures on advance directives as well as grievance procedures. Caregivers must document in a prominent part of the patient’s medical record whether or not the individual has executed an advance directive.
10. Information before the day of the procedure. Before the day of the procedure, ASCs must provide the patient with a list of patients' rights and advance directives, as well as a list of physicians with financial interests in the center. The information must be provided verbally and in writing.
Learn more about Physicians Endoscopy.
Read more about surgery center surveys and their requirements:
- 10 Points on Giving Patients Written Material Before the Date of Surgery
- Medicare Clarifies Same-Day History and Physical Guidance for Surgery Centers
- 4 Common Medicare Violations Found by Inspectors of Surgery Centers