December 31, 2008

Announcing a Brand New Service from Ortmann Healthcare Consultants: ASC Check-ups!

The health of your patients is foremost on your mind, but what about the health of your Ambulatory Surgery Center? Is your surgery center truly healthy or could it use a little “doctoring?”

The latest Government and ASC industry statistics show that fully 1/3 of all new surgery centers fail within the first three years of operation. Many centers are not ready for their follow-up state, Medicare, AAAHC, AAAASF, or Joint Commission inspection, resulting in loss of licensure, certification, or accreditation. Hunderds of thousands of dollars are lost each year as the result of uncollected revenue, poor managed care contracts, and inadequate case costing analysis.

How does your ASC measure up? Would your center receive a clean bill of health?

Ortmann Healthcare Consultants Check-ups Program offers on-site assistance to ensure that your center is healthy, from a financial standpoint as well as a clinical and regulatory standpoint. Our experienced staff will evaluate your centers health in the following primary areas: Regulatory & Accreditation Services, Financial Management, Center Legal Documents, Center Management, Center Appearance, Compliance Programs, Policy & Procedure Manual, Maintenance of Building & Equipment, Credentialing & Privileging, Information Technology, Ancillary Agreements, Organization of Documents, and Employee Records.

At last, a program designed to help guarantee your success!

Through Check-Ups, Ortmann Healthcare Consultants will provide on-going support and on-site assistance as needed to ensure continuous improvement in the performance of your facility. For a complete and confidential assessment or to schedule services, please call us at your earliest convenience at (803) 252-7979 or toll free at (866) 678-6266.


Becoming Medicare Certified- Part I

December 30, 2008

This post will be in three parts to cover what I have identified as three key components to obtaining Medicare certification for an ambulatory surgery center. The first post will address the enrollment application process through the Medicare carrier. The second post will cover the required forms and process for notifying the State agency, and the third post will cover seeking certification through an accrediting organization and how the three components tie together to complete Medicare certification for your facility.

The first step in obtaining Medicare certification is notifying the Medicare carrier for your state and assembling the required documents and enrollment forms. For an ambulatory surgery center this is the 855B and supporting documents, CMS 588 and CMS 460. All of these forms are available on the CMS website, but you may need to complete a search for them. The required additional documents include a copy of the Articles of Organization, NPI confirmation, CLIA Waiver, EIN verification, and any other documents required by the state, such as state licensure. It is not necessary to have state licensure prior to submitting the 855B, but if you are seeking licensure you will want to notify Medicare of this in your cover letter.

Once you have completed the forms and attached the required documents, you will need to submit the packet to the Medicare Carrier. It is important to start this process well in advance of the anticipated date of opening for you facility to allow time to respond to any deficiencies the carrier may notice in your enrollment packet. Typically you are notified of these deficiencies by letter or fax and are given between 30 and 60 days to respond. If you are not able to respond in this timeframe, your application may be returned to you. This can further delay the enrollment process.

Once your packet is considered complete you will receive notification that Medicare is awaiting the results of the Medicare Certification inspection. This inspection was formerly completed by the State agency, but Medicare has issued a new priority tier for ambulatory surgery centers and many centers are seeking Medicare Certification through an accrediting agency. This process will be covered in Part III.

Please check back for Part II of Becoming Medicare Certified where I will cover the State processes for Medicare Certification.

Submitted by Jessica Kopittke, Director of Regulatory Affairs


Happy Holidays!

December 22, 2008

Ortmann Healthcare Consultants will be taking a break from blogging over the holidays! We will return on Monday, December 29th with new posts! Have a safe and happy Holiday!


ACHE Webinar

December 18, 2008

Fred Ortmann, president and CEO of Ortmann Healthcare Consultants, will be giving an ACHE sponsored Webinar on Wednesday February 18, 2009, from 12:00-1:30 PM EDT. The topic is Ambulatory Surgery Centers- The Basics and Beyond. For more information about participating in this webinar please visit the ACHE website.


Accreditation Sampler

December 17, 2008

Accreditation has become an important step in certifying an ambulatory surgery center. Some states have gone so far as to make it mandatory for certain providers, and in some instances it is the most viable option for receiving Medicare certification for new centers. The accreditation process can be time consuming and overwhelming to a center director, whether it is your first or one in a series of many. To help you make a decision about accreditation for your surgery center, I have put together a synopsis of two of your options. The Joint Commission has a program for certifying and accrediting ambulatory surgery centers, but we have not had the opportunity to work on a project involving JCAHO so it will not be covered in this post.

Accreditation Association for Ambulatory Health Care(AAAHC)

AAAHC, or Triple A as I like to call it, accredits a number of different types of facilities. Their accreditation program for ambulatory surgery centers is well recognized. The process begins with a comprehensive, but lengthy application which covers everything from the services of your facility, to the physicians, and environment of care. To receive an accreditation survey, your facility needs to have been in operation for at least 6 months. If you are a new facility and are trying to get accreditation as soon as possible there is an Early Accreditation Option, where you are granted accreditation for a year and must be resurveyed to be granted the typical 3 year status. The cost can vary depending on specialty and the location of the facility. You can receive your Medicare Certification through Deemed Status Accreditation and AAAHC is widely recognized in the managed care market.

American Association for the Accreditation of Ambulatory Surgical Facilities (AAAASF)

AAAASF, also known as Quad A, is another option when seeking accreditation. Their application is much shorter but the survey process is just as extensive. Part of the process of the application is the completion of 15 cases, from which you will need to select 6 for random peer review. Your survey can occur anytime after the reports for these 6 cases are reviewed. To receive accreditation with Quad A your physicians must be board certified or board eligible. The cost also varies depending on the number of physicians and their specialties. Quad A is also recognized by Medicare and authorized to perform Medicare Certification surveys.

Both organizations have informative websites and their staff is easily contacted when questions arise, but using a consultant, like Ortmann Healthcare Consultants, can take the stress out of the preparation process. We have developed a program to “pre-survey” your facility and compare your policies and procedures to the actual accreditation guidelines.

Disclaimer: Ortmann Healthcare Consultants feels it appropriate to disclose that a staff member is also a surveyor for an accrediting organization, however, the selection of an accrediting agency is the sole responsibility of the facility and Ortmann Healthcare Consultants does not exercise any preference, nor do they accept any rebates, or kickbacks from vendors or business associates. For more information, please see our Statement of Integrity.

Submitted by Jessica Kopittke, Director of Regulatory Affairs


NPI Resource

December 16, 2008

Hopefully by now your facility has received its National Provider Identifier, or NPI. This identifier, which was mandatory for all providers on May 23, 2007, will replace the UPIN and all other Medicare identifiers. Providers are now required to obtain an NPI and provide this information to Medicare during enrollment and on all claim forms and correspondence.

Existing centers should already have an NPI but for those just developing a surgery center, obtaining your NPI is another essential piece of the puzzle. There are several ways to apply for your NPI. The fastest way is with the online application which is available here. If you need to learn more about the NPI or have specific questions regarding its issuance or use however, CMS is the best resource. They have a large Frequently Asked Questions database and a copy of the final ruling printed in the Federal Register.

Before applying for your NPI you will need to have a few pieces of information handy. This information is different for facilities, who receive an organizational NPI, and providers. Ambulatory Surgery Centers are assigned an organizational NPI. The information needed is facility’s legal name, physical and mailing address, telephone and fax numbers, Medical Director’s name and contact information, Tax ID information, Taxonomy, and contact person information. Typically a repsonse is generated in 7-10 days, but it is not often that I wait more than an hour to receive notification of the NPI, which can be obtained through email. You will want to print or save a copy of the notification. If you are a new center this notification is a required part of your Medicare Enrollment application, but that’s a post for a different day.

Submitted by Jessica Kopittke, Director of Regulatory Affairs


Calculating your 2009 reimbursement

December 11, 2008

As the end of the year approaches, many centers are beginning their financial planning for 2009. A large part of this planning will include accounting for the gains or losses in reimbursement from Medicare. Depending on your specialty, it is important to know if the Medicare rates for 2009 will help or hurt your bottom line. The ASC Association has a great tool for determing the effect new rates will have on your reimbursements, per code. Visit their website and clink on the Medicare tab. On the right sidebar you will see a link to their 2009 Medicare Rate Claculator. In some locations, the wage index has also been changed, and you will be able to find that information there as well.

If you need additional help with your budgeting, Ortmann Healthcare Consultants can put together a proforma showing exactly what codes have changing reimbursement and how this will affect your business. Please feel free to contact us.


Financing Your ASC Part II

December 11, 2008

It wasn’t that long ago that if you had an M.D. after your name, it wasn’t that difficult to get funds. Now, it’s best to prove that not only are you an outstanding physician, but that you also have a sound business plan prepared. Putting together a financial proforma as a part of your request for financing is essential. Not only will the proforma prove to a lending institution that your venture will be profitable and that you will be able to pay back all of your loans, it will give you a sense of security that you are not crazy to think about building an ASC in this economy.

What does a good financial proforma contain? The starting point is expected revenue. You need to have a good idea of how much revenue you can expect to collect from your facility fees in the ASC. The proforma’s revenue should never include physician professional fees. You will receive these fees whether performing surgeries in your own ASC or in another location. If these fees are needed in order to make the ASC financially feasible, then you should not be building the ASC, or you need to find more partners. Make sure you are looking only at your facility fees for expected revenue.

Be as accurate as possible in determining your workload. Use one year’s worth of actual patient data to determine the amount of revenue to expect. Be sure to discount for secondary procedures and for patients you might want to leave in a hospital setting because of age or health issues. Look up the facility fees for each CPT code from your patient data at the Medicare Rate; then, you may increase the fee for non-Medicare patients based on a percentage of Medicare, similar to what your practice receives from insurance companies. Too often revenue is calculated with guesswork of what is currently happening in the physicians’ practices—a guess of the number of cases and a guess at the expected reimbursement. You may be surprised at the effect Medicare patients can have on the average facility fee. When it comes to the type of money needed to build an ASC, the word “guess” should not be in your vocabulary.

Using accurate data that can be supported in discussions with a financial institution is essential. You should be able to answer all questions of how you arrived at a particular revenue figure and show supporting evidence. Money is available, but only to those who can prove a venture makes sense.

Once your revenue is determined, it’s time to look at expenses. You will need three loans: construction, equipment and working capital. Here it is best to work with a consultant who can help you obtain these figures accurately. Too much goes into this process for the scope of this article but it’s important to work with a developer who can give you accurate information. If you can show a bank that you have carefully considered what goes into a surgery center, that you really have a knowledge of revenue versus expenses, you should be able to obtain funding. Financial institutions have to make loans—that’s their business. But they have to make good business decisions, and if you can show the people you work with that your project is sound, you will be successful at obtaining funding.

Your construction loan should be an accurate accounting of what it will take to build your center. You will need to decide on size of the center first, because that is what will drive your costs. You may find that you need to adjust your size downward as you go through this process, but with research you can find a size that is reasonable. You will also need to make sure your size meets the requirements in Medicare and State regulations. Your costs could include purchase of land, construction of shell and interior (or if using an existing building, construction of space to meet ASC regulations), architectural fees, and interior design. Working with an experienced consultant can make this process easier. When requesting funds for construction, you will need to give an accounting of how your total request will be used.

An equipment loan will be needed to fully equip the ASC. This loan should include not only the “big ticket” items for the ORs (lights, scopes, crash carts, anesthesia machines, microscopes, video equipment, sterilizer, instruments) but funding for every bit of furniture, shelving, cart, computer, printer, locker, filing cabinet, and so on—every item that will be placed in the ASC. The equipment should be researched carefully so that you will ask for the funds necessary to fully furnish and equipment the center. It is more difficult to go back later and ask for additional funds. If you are working with a consultant, estimates should be available. Equipment planners can also be contacted.

Don’t forget Information Technology when creating your equipment list. You will need funds at a minimum for software that will do scheduling and billing for your ASC as well as the necessary hardware to run this software. You may also wish to consider electronic physician documentation and electronic charting. Creating an electronic medical chart will cost, but it will also save the cost of building space for storing paper charts.

The final loan is the Working Capital loan, funds to pay pre-opening expenses that don’t involve construction or equipment. Examples could vary from stocking the ASC with supplies, to paying for staff, fees for licensure/accreditation applications, and legal fees for agreements. More importantly, the Working Capital should include a line of credit to pay for the center’s first three to four month’s expenses: lease, utilities, staff, benefits, surgical supplies, and so forth. It takes time to get the state to come in for its licensure inspection and more time to achieve Medicare Certification. Even though you may begin performing Medicare cases as soon as you pass your inspection, it may take two months to get your information in the Medicare system so that you can send your first bill.

After you have your state licensure and Medicare certification, then it’s time for insurance contracting. That can take anywhere from weeks to months more. Working Capital is important during this time in order to pay your staff, utilities, lease payments, etc. Securing Working Capital should be in the form of a line of credit—that way you can borrow only what you need.

All of this takes some work upfront, but in the end your project will go much more smoothly. Ortmann Healthcare Consultants can help you with this process. Please feel free to contact us if you have questions or need assistance with the financial planning of your facility.

Submitted by Chris McMenemy, VP Administration


The Changing Face of ASC Reimbursement

December 9, 2008

Caryl Serbin of Serbin Surgery Center Billing, LLC, recently wrote a great article for SURGistrategies about the Changing Face of ASC Reimbursement. While there is too much information to condense for you here, I have provided a link to the article here. It is a great read for those interested in a broken down synopsis of the changes to come for ASC reimbursement in 2009.This is a must read for owners, physicians, administrators, and others with their hands in the financial side of an ambulatory surgery center.


Listing of ASC State Regulatory Requirements Links-Revised

December 5, 2008

Every state that licenses ambulatory surgery centers has its own set of licensing regulations. Reading the regulation can be a time consuming task but is an important step in developing an ambulatory surgery center because it outlines exactly what clinical, physical, administrative, and other requirements will need to be met for the facility to achieve State Licensure.

Thankfully, in this day and age, this information is easily accessed on the internet. To make it even easier for those of you interested in developing an ambulatory surgery center but don’t know where to begin looking for the regulations, we have compiled this listing of links to the state specific regulations! Just click on your state to access the regulation. If you don’t see your state listed, they probably did not have their regulations accessible. You can typically contact your Department of Health and request a copy of the regulation. Or bonus points if you find it and let me know!

Alabama

Alaska

Arizona

California

Colorado

Connecticut

Delaware

Florida

Hawaii

Illinois

Indiana

Kansas

Kentucky

Louisiana

Maine

Maryland

Michigan

Mississippi

Missouri

Nebraska

Nevada I, II

New Jersey

New Mexico

North Carolina

Ohio

Oklahoma

Oregon

Pennsylvania

South Carolina

Texas I, II

Utah

Washington-rules currently under revision

Wyoming

District of Columbia

Keep in mind the state licensure regulations are only one of the regulatory documents that ASC’s have to follow. There are separate Federal regulations, as well as an extensive listing of building codes and Life Safety regulations that have to be met during design and construction. And who can forget the Certificate of Need requirements if you happen to develop a center in a CON state. If you are interested in learning more about ambulatory surgery center development, contact Ortmann Healthcare Consultants at 803-252-7979.