At the 20th Annual Ambulatory Surgery Centers Conference in Chicago on October 26, Amy Mowles, president and CEO of Mowles Medical Practice Management, discussed regulatory processes relevant for ASCs.
According to Ms. Mowles, a little-known fact regarding the regulation of ASCs is that CMS administers the entire ASC program. To be certified, you have to be a participating provider in the Medicare program — even if you do not plan on treating Medicare beneficiaries. Hence, the surgery center will be assigned a Provider Transaction Access Number. CMS also lays out conditions of participation. ASCs must meet every single condition to participate in the program.
State regulations and requirements for licensure are highly specific, said Ms. Mowles. Most states require the surgery center to be licensed by the state before Medicare certification. "But this may not be an absolute in your state," said Ms. Mowles. "Do your homework."
It is essential that surgery centers read into the fine print regarding state regulations as they are nuanced. For example, state requirements for licensure always involve specific physical environmental regulations. Another nuance is that Medicare says that the maximum number of hours allowed for patient stay is 23 hours but some states allow only four hours. "Research is key," said Ms. Mowles. "And it isn't all black and white; it really isn't."
Ms. Mowles also discussed surveys conducted by accreditation organizations. Here are five things to remember about accreditation surveys, she said:
1. If you know you are right, politely challenge. Not everything is black and white.
2. Be pleased and enthusiastic to show the surveyors your facility.
3. Have a good understanding of state regulations, CMS conditions of participation and accreditation standards.
4. Be honest and thorough in your pre-survey materials.
5. If you don't know something — admit it.
Finally, Ms. Mowles suggested if a survey is not going well and you are afraid your surgery center will fail, ask the surveyor if you can change the survey to a "consultative" one rather than the final one.
According to Ms. Mowles, a little-known fact regarding the regulation of ASCs is that CMS administers the entire ASC program. To be certified, you have to be a participating provider in the Medicare program — even if you do not plan on treating Medicare beneficiaries. Hence, the surgery center will be assigned a Provider Transaction Access Number. CMS also lays out conditions of participation. ASCs must meet every single condition to participate in the program.
State regulations and requirements for licensure are highly specific, said Ms. Mowles. Most states require the surgery center to be licensed by the state before Medicare certification. "But this may not be an absolute in your state," said Ms. Mowles. "Do your homework."
It is essential that surgery centers read into the fine print regarding state regulations as they are nuanced. For example, state requirements for licensure always involve specific physical environmental regulations. Another nuance is that Medicare says that the maximum number of hours allowed for patient stay is 23 hours but some states allow only four hours. "Research is key," said Ms. Mowles. "And it isn't all black and white; it really isn't."
Ms. Mowles also discussed surveys conducted by accreditation organizations. Here are five things to remember about accreditation surveys, she said:
1. If you know you are right, politely challenge. Not everything is black and white.
2. Be pleased and enthusiastic to show the surveyors your facility.
3. Have a good understanding of state regulations, CMS conditions of participation and accreditation standards.
4. Be honest and thorough in your pre-survey materials.
5. If you don't know something — admit it.
Finally, Ms. Mowles suggested if a survey is not going well and you are afraid your surgery center will fail, ask the surveyor if you can change the survey to a "consultative" one rather than the final one.