One in three ambulatory surgery centers are undergoing surveys this year by Medicare, compared to a historical rate of about one in 10. Chris McMenemy, vice president for administration at Ortmann Healthcare Consultants in Columbia, S.C., discusses four common violations found in Medicare surprise inspections.
1. Patient hasn't received required materials before day of surgery. This requirement to provide the patient certain written material is relatively new, stemming from the May 2009 revision of the Medicare Conditions for Coverage. "It is an easy requirement for inspectors to verify," Ms. McMenemy says. "They need only ask patients in the waiting room if they received the material before that day." Since patients may not always remember whether they received the material and when, it helps to keep documentation, she says. Staff members can even ask patients to sign a form indicating they received the information.
2. Incomplete infection control worksheet. The worksheet must document which staff member is overseeing infection control and include the ASC's infection control plan. The person responsible for infection control cannot be a technician and has to have special training in infection control, but exact training is not specified.
3. TB tests are not up-to-date. All physicians and staff members should get a TB test once a year. The Medicare interpretive guidelines, updated in May 2009, state the ASC "must maintain an ongoing program" to prevent communicable diseases. Though the guidelines do not specifically require TB tests, Ms. McMenemy says some surveyors have interpreted it to mean there must be TB tests. She cites a surveyor's written comments after inspecting an ASC, stating: "The ASC failed to annually screen 10 of 18 ASC health care workers (Physicians 1, 2, 3, 6, 8, 9, 11,14,15, and 17) for tuberculosis and other communicable diseases." Since TB tests are relatively inexpensive, she recommends centers should get the tests done rather than argue with surveyors about what the guidelines really meant.
4. Some drugs have expired. Inspectors go through drug cabinets and check expiration dates on the labels. "Every surveyor is different, but these are a few examples I've come across," Ms. McMenemy says. Surveyors have plenty of time to find deficiencies because their visit lasts one to two days.
Submitting a plan of correction. If surveyors find violations, they will inform ASC staff when they leave and a formal notice will come through the mail. The ASC then has 10 days to submit a plan of correction. The 10 days, including weekends and holidays, require fast action. Ms. McMenemy recalls a client had to submit a plan of correction on the Monday after the Thanksgiving break. ASCs that fail to meet the 10-day deadline lose their Medicare certification. Within a few weeks of submission, surveyors pay a second visit to determine whether the plan has been carried out.
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Read more about meeting survey requirements:
- Meeting Medicare Requirements When ASCs and Practices Share EMR
- Guidance to Meet Manufacturers' Recommendations on Diluting the Cleaning Enzymes for Scopes
- CMS Waives Separate Waiting Room Requirement for ASCs Meeting New Criteria