Phenelle Segal, RN CIC, is president of Infection Control Consulting Services based in Blue Bell, Pa.
Q: Our ambulatory surgery center has brought on a new partner who believes we could save money by decreasing high-paid positions, specifically our director of nursing position. This individual oversees our day-to-day clinical operations. Is this an acceptable practice or could we face compliance/safety issues without this position?
Phenelle Segal: I have never heard of a healthcare facility eliminating the director of nursing position. In my professional opinion, it would be a huge mistake.
Here is my backup directly from the CMS surveyor's worksheet (pdf) that every ASC in the nation is required to conform to:
Does the ASC have a licensed health care professional qualified through training in infection control and designated to direct the ASC's infection control program?
NOTE! If the ASC cannot document that it has designated a qualified professional with training (not necessarily certification) in infection control to direct its infection control program, a deficiency related to 42 CFR 416.51(b)(1) must be cited. Lack of a designated professional responsible for infection control should be considered for citation of a condition-level deficiency related to 42 CFR 416.51.
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Thereafter, the following is also a requirement from CMS:
On average how many hours per week does this person spend in the ASC directing the infection control program? (Note: §416.51(b)(1) does not specify the amount of time the person must spend in the ASC directing the infection control program, but it is expected that the designated individual spends sufficient time on-site directing the program, taking into consideration the size of the ASC and the volume of its surgical activity.)
In addition, in the CDC's July 2011 "Guide to Infection Prevention for Outpatient Settings: Minimum Expectations For Safe Care" (pdf), the CDC states the following:
Facilities should assure that at least one individual with training in infection prevention is employed by or regularly available to the facility.
While cost is a major factor in today’s climate, owners and administrators should be well informed of the serious implications of a facility that is not complying with requirements.
In the best interests of patient safety and CMS compliance, I strongly suggest that there be a clinical person with a background in "hands on care" and, at the very least, a basic knowledge of infection control best practices. Some ASCs hire an infection control consultant to provide additional support to the licensed clinical person. If an ASC falls short of these mandates, they can receive deficiencies that can range from minor citations to the extreme of being given an “immediate jeopardy,” which could potentially close down a facility.
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