Jan Davidson, RN, MSN, is the AORN perioperative education specialist focusing on ambulatory surgery centers. She is overseeing a new AORN policies and procedures manual for ambulatory settings. The first subsection focusing on infection prevention is scheduled to be available on CD before year's end.
Q: Why did you start with the infection prevention section for this new manual?
Jan Davidson: The reason I started with infection prevention is because that seems to be the primary focus of CMS during their unannounced surveys. It was written with the hope of being able to provide ASCs with a tool they could use to prepare for unannounced surveys should that occur.
Q: As you have been developing the section, what have you found to be the key differences between the content of ambulatory operating room and hospital operating room policies and procedures?
JD: The difference is that the role of the ASC infection prevention specialist, the employee health coordinator, the facility safety officer, etc., are most often positions that are held by nursing staff who have not been trained in that area of expertise. There are very specific requirements from CMS with regard to an ASC having a credible infection prevention program and they specifically want to see that your center follows nationally recognized infection control guidelines. CMS has identified CDC/HICPAC and AORN as having nationally recognized standards to follow for a credible infection prevention program.
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Q: What do you see as the top challenges for ambulatory facilities because of these differences?
JD: I think the primary challenge is that it's a requirement of CMS that there be a specific person designated to oversee the infection prevention program at the ASC and the center has to be able to show that the designated person has undergone training. The person doesn't necessarily have to be certified in infection prevention, but they do have to show they have gone thorough initial training to oversee the program. They also have to have a refresher course thereafter, and while CMS does not define how frequently that refresher course takes place, I would think that it should be no less than annually.
If the center cannot show documentation that the designated person has had sufficient training, both initially as well as ongoing, and that they do not have a credible infection prevention program in place, the center could be given a conditional-level citation. This indicates a standard was not met that may pose a threat to patient health and safety, which is very significant. Should that occur, the center would be given a certain number of days to submit a corrective action plan and then they're typically resurveyed to make sure they have met the standard and it is sustainable.
Q: What do ambulatory facilities need to be doing to meet these requirements?
JD: I think that staffing is always a challenge in an ambulatory setting. When you have people filling these other roles, such as risk manager, patient safety officer or infection prevention officer, that is time they have to devote to that position separate and apart from patient care and their other duties in the OR. Unfortunately that is often seen as non-productive time, and on the payroll that's sometimes hard to explain.
So for surgery center administrators and management companies, I think they need to recognize the importance of having those devoted people, and that in order to have a credible program, whether it be infection prevention, risk management or patient safety, they have to give these people time to devote to that responsibility and for position-specific education and resource material.
The challenge with the manager of an ASC is he/she has to show the productivity. If you have somebody spending four hours a day on infection prevention, that's non-productive time on your payroll. Managers need a way to code the time spent in these roles as administrative time, or some other relevant category to show that really is productive time even though it's not direct patient care.
Q: What are some ways and reasons you can see ambulatory facilities failing to effectively meet the requirements?
JD: I think one of the primary ways the ASC fails its staff is by not providing them with the time to have regular education and in-service training. Even if there was one hour a week set aside for staff meetings, it would be ideal if one of those meetings per month could be devoted to education and training. I think one thing that is always and will always be a constant is that the science of medicine is forever changing. If we don't allow our staff to stay abreast on technology, new ideas, new drugs, etc., then how can we provide ongoing safe patient care? This would be time well spent and returned many times over because employees view it as an investment in them which in turn makes them feel valued.
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