Before the shift towards most outpatient surgeries being performed in ASCs, Medicare and Medicaid surgical patients were primarily cared for in hospital settings. But as reimbursement models shifted, and surgical and anesthesia innovations progressed, more Medicare/Medicaid patients found their way to an ASC. Naturally, this change focused the surgery center’s attention on maintaining their certification from the Centers for Medicare and Medicaid Services.
The vast majority of ASCs are Medicare certified, and to date, very few have lost their certification. When they do, it isn’t pretty. Because Medicare and Medicaid payments comprise a median of 39% of gross charges per ASC, losing certification makes it hard to keep the doors open. Less catastrophic, but still damaging is the dreaded 2% reduction in Medicare payments if reporting requirements are not submitted in a timely manner.
The compliance and certification criteria has created a significant administrative burden for the average ASC. But in typical fashion, surgery center administrators tackle this new challenge by marshaling all the tools they have at their disposal. Here’s what you need to know to lighten the CMS compliance workload.
CMS Certification 101
The regulatory compliance requirements are grouped under CMS’ 42 CFR, into Conditions for Coverage (CfCs) and Conditions of Participation (CoPs). They include health and safety standards, governance, maintaining medical records, infection control, patient admissions and discharge. In short, everything that goes on inside the four walls of an ASC must be documented, categorized and continuously reported on in order to be reimbursed by CMS.
In addition, some states and private payers require that ASCs observe Medicare CfCs. Savvy surgery center administrators turn to Appendix L of the CMS State Operations Manual to make sure they’re on track for remaining in compliance — no matter who’s demanding it.
CMS Documentation
Spend some time in Appendix L and you’d swear that CMS must think we sit around eating bon bons all day and have plenty of time to assemble and maintain the reams of documentation they require: medical records (and how securely they are kept), credentialing, maintenance records of all equipment, policy and procedure manuals, transfer agreements (more on this one later) contracts, board meeting minutes — the list goes on. Yet just because CMS wants hard copies of all this documentation doesn’t mean your ASC has to store them that way. Increasingly, centers are storing this valuable information via ASC software tools, and working hard to make it shareable. New regulations, especially regarding patient health information practically make digitization a requirement.
New Regulations from ONC
Earlier this year, CMS and the Office of the National Coordinator for Health Information Technology (ONC) announced the Information Blocking Rule to ease the flow of healthcare information, and the Interoperability and Patient Access Rules to add more detail regarding Electronic Health Information. The public comment period for these proposed changes recently concluded, and finalized rules are expected to be released in early fall of this year. While the impact of these new regulations on ASCs is uncertain, it adds pressure for centers to adopt EHRs, or an EMR system.
Trace Data Capture from Beginning to End
Transitions and hand-offs between outpatient settings, while not part of CMS guidelines, have downstream effects that can land any ASC in hot water. Incomplete patient records and care notes, and electronic review of lab and imaging results, create information gaps that can lead to infection, adverse reactions and more. Surgery centers should have policies and procedures in place to assure they have captured the data necessary to facilitate safe handoffs.
The Burden of Change is on the ASC
CMS publishes a raft of updates and clarifications, and in some cases they scale back on, for example, ASC quality measures. Still, it’s each center’s responsibility to remain clued into the current framework. Understand the difference between a measure being removed (this primarily has to do with quality measures) and when a measure is suspended. Removed usually means ‘good riddance, we’ll never see this again’. But suspended means it may come back again. Keep tracking it. For example, the flu vaccine requirement for all ASC employees may have been lifted at the federal level, but some states still require it.
Technology Lightens the CMS Certification Load
Maintaining CMS certification doesn’t have to be a compliance nightmare. With an EMR system, tracking data points and generating reports has never been easier. The Simplify ASC platform has a quality reporting tool that allows you to customize reporting for whatever your facility needs. There’s modules for everything from Risk Management and Infection Reporting to Chart Audit, Peer Review and Satisfaction Surveys. You can modify dates of existing reports for regulatory purposes without starting from scratch or further software development. We’ve got you covered.
We’ve also made it easy to discover how quality and other data points can be used to generate the data insights you need to improve performance and grow your business. It’s all in our latest white paper. Ready to start?
