Amy Mowles, president and CEO of Mowles Medical Management, identifies five truths and misnomers about pain management in ambulatory surgery centers.
1. Office-based Accreditation is not an avenue for private practitioners with an in-office procedure room to receive facility fees. Local and state law and third-party payor policies (commercial and workers' compensation) require the facility to be licensed (if state applicable), Medicare-certified and usually accredited in order for facility fees to be paid, Ms. Mowles says.
2. Regulatory process is the same regardless of specialty. Do not be fooled by thinking that pain management procedures are percutaneous in nature, she says. "In the eyes of the programs that have jurisdiction, in does not matter if you are doing major, invasive, diagnostic or minor procedures," she says. "If you want to be paid as an ASC, you will be building the appropriate space and meeting the conditions, regulations and standards."
3. Asking and then expecting large waivers on physical environment, particularly in a state with strict guidelines, is perhaps the biggest myth of all. The operating room for pain management procedures is not what the full ASC environment is all about, Ms. Mowles says. The operating room itself (size, piped gases, finishes, electrical system and backup power) is based on level of anesthesia used in that room. States with strict guidelines on physical environment for licensure typically require 15-20 additional rooms to support that one Class B operating room that is standard for pain procedures (Class B is limited to moderate (conscious) sedation). This would make a one Class B OR facility about 2,200-3,000 square feet in total. Remember, too, that it must be separated from the physician's office by a one-hour rated fire wall.
4. Who can run the C-arm? Radiology regulations vary from state to state and/or individual payor, Ms. Mowles says. Questions your ASC needs to answer before purchasing or leasing a C-arm include: Does the state radiation safety division require lead lining in the procedure room? Do they need to certify the equipment? Do you have to go through a state certification program even for physicians? Is there a radiation safety course? Do you have an emergency service agreement? If you do not employ a certified radiology technician, can a non-physician operate the C-arm? Do you have a mandatory training program? Do you have a physicist and radiologist consultant?
5. Policies and procedures. Make sure they are specific to pain management, she says. They should address issues including what to do in an emergency, who can administer and monitor sedation and your case selection. "Live by them," she says.
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