Swine Flu Update

As swine flu becomes an increasing concern, it is important to stay on top of the latest news and information released concerning the virus. The CDC is continually updating their website with information, and as those involved in the healthcare industry, it is extremely important that we monitor this information to protect not only our patients, but our employees, families, and selves. It is especially critical during this time that you inquire about your patients recent travels. Before admitting a patient, we suggest asking if they have traveled lately, especially to Mexico. It is also a good idea to assess their general health, by asking how they are feeling, and if they have had a cough or low grade fever.

If you suspect that you have come in contact with a person infected with the swine flu, the CDC suggests doing the following:

1. If swine flu is suspected, clinicians should obtain a respiratory swab for swine influenza testing and place it in a refrigerator (not a freezer). Once collected, the clinician should contact their state or local health department to facilitate transport and timely diagnosis at a state public health laboratory.
2. Antiviral treatment for confirmed or suspected cases of swine influenza virus infection may include either oseltamivir or zanamavir, with no preference given at this time. Recommendations for use of antivirals may change as data on antiviral susceptibilities become available.

And of course, keep in mind the basics of good health and hygeine:

• Avoid close contact with people who are sick. When you are sick, keep your distance from others to protect them from getting sick too.
• If possible, stay home from work, school, and errands when you are sick. You will help prevent others from catching your illness.
• Cover your mouth and nose with a tissue when coughing or sneezing. It may prevent those around you from getting sick.
• Washing your hands often will help protect you from germs.
• Avoid touching your eyes, nose or mouth. Germs are often spread when a person touches something that is contaminated with germs and then touches his or her eyes, nose, or mouth.
• Practice other good health habits. Get plenty of sleep, be physically active, manage your stress, drink plenty of fluids, and eat nutritious food.

Currently, the WHO has avoided declaring a pandemic, and the more informed and involved the public is in preventing the spread of the disease, the more prepared we will be to fight it.

As a side note, MSN has an interesting article concerning the swine flu and how public reaction can impact the effect of the virus.

Submitted by Jessica Miller, Director of Regulatory Affairs

Physician Credentialing

Physician and allied health professional credentialing is a topic that is often overlooked during the development of any ambulatory surgery center, even though proper employee and physician credentialing files are a federal, state, and accrediting agency requirement. Keeping organized and complete credentialing files makes it easier to assess new staff and can speed up the process of re-credentialing. Here is an overview of a few key elements of a physician credentialing file and how to make sure your records can stay organized and up to date.

Utilize a credentialing checklist:
Create a checklist of the items that are required in each credentialing file. Create a binder system that allows you to personalize a folder for each physician and store items behind appropriate tabs or markers to keep organized. Key items should include Medical License, DEA and any state issued certificates, medical malpractice insurance cover sheets, American Medical Association (AMA) and National Practitioner Data Bank (NPDB) query responses, Board Certificates, and Continuing Medical Education records.

Periodically Review Credentialing files:
Most physician credentials are reviewed for appointment and then often stored away until there is an incident or it is time for re-appointment. Since re-appointment sometimes does not occur for at least two years (depending on how credentialing and physician appointment is addressed in the Medical Staff Bylaws), many items in the file may become expired or obsolete. A physician may get any number of licenses or certifications renewed through the year, as well as changes in insurance and reports to the NPDB. You should be aware of any changes in medical or insurance information and collect any updated documents from the physician as soon as they are available.

Utilize your IT system:
Depending on which scheduling or ASC management software you have purchased, most have a tool included to store and track physician information. Through this tool you are able to set up alerts for physician information and can be notified when a license is about to expire. Some software programs will even suspend scheduling for that physician or bring up an alert until the document is reviewed and renewed. This is a great tool and can make periodically reviewing a physician credential file as easy as reviewing the information in their physician profile in your scheduling software.

Keeping good credentialing files is not only a must to meet federal, state, and accrediting requirements, but it makes good sense in protecting your patients!

Submitted by Jessica Miller, Director of Regulatory Affairs

Preparing for Medicares changes to Conditions for Coverage- Advanced Directives

One other piece of paper must be signed in advance of the date of the procedure, which is information concerning the ambulatory surgery center’s policies on advance directives, including a description of applicable State health and safety laws and, if requested, official State advance directive forms. As a part of this procedure, inform the patient of his or her right to make informed decisions regarding patient care. The law also requires that the ASC document in a prominent part (not defined) of the patient’s current medical record, whether the individual has executed an advance directive. As above, you must make plans to have this information provided and signed prior to the date of the surgery. This website is an excellent resource for finding your state’s laws concerning advanced directives.

You should begin planning for the process you will use to accomplish the task of getting this paperwork signed and verbally presented to your patients. May 18 isn’t that far away! If you feel you may need assistance bringing your policy manual or patient documents into compliance, contact Ortmann Healthcare Consultants at 803-252-7979 today!

Submitted by Chris McMenemy, VP Administration

Preparing for Medicare’s changes to the Conditions for Coverage

Are you working in an ambulatory surgery center? Does the date May 18 mean anything to you? It should! That’s the date you are expected to comply with CMS’s new Conditions for Coverage for ASCs. The ASC Association has helpful information on this topic and Scott Becker’s ASC Review has a nice, easy-to-read document that shows the changes in the law.

It’s important that those in charge of ASCs read this information and make plans now to be in compliance by May 18. We are waiting for the Interpretive Guidelines to Surveyors to be published and will share that information as soon as we have it. These new Conditions for Coverage apply to all patients seen in the ASC, not just Medicare patients. This is somewhat of a departure from recent years.

In the next two blog postings, we will be talking about what you should be doing now to prepare for May 18. The first topic is Patient Rights and Reponsibilities.

Patient Rights and Responsibilities

A document outlining patient rights must be provided to the patient both in written format and verbally, in advance of the date of the procedure. The ASC Association is interpreting this rule to mean that you must have this document signed prior to the date of the procedure. If the document is not signed before the surgery, you are to turn the patient away.

How can you prepare for this? For many surgeries, the easiest thing to do will be to get this paperwork signed when the patient comes in for his or her initial appointment before the surgery. Don’t let that patient leave without signing the appropriate paperwork or without verbally explaining the paperwork contents. If you have a problem with a language barrier, consider contracting with a service such as Language Line, so that you have a way of calling someone to translate for you if necessary. Be prepared for this need now!

What about patients who will not be seen in the ASC prior to their procedure? You will need to have a workflow plan. You may want to have this document placed on your web site, so that your patient may download, print and sign the paperwork before coming into the ASC. And/or you may want to mail this information to your patients for signature prior to the procedure. In both of these cases, the ASC will need to call the patients to give the verbal notice to the patients. Document this call! Describe how important it is that the patient brings this signed paperwork into the office the day of the surgery.

Whether the patient is expected to sign in the office, sign via documents downloaded from the internet, or sign via documents that have been mailed, in all cases the ASC must verify that this has not “slipped through the cracks.” When compiling the chart for the surgery, make sure that the documents signed in the office are in the patient’s folder, so that you can know before it’s too late that the documentation has actually been signed. Don’t assume that the Office staff took care of this! You do not want to be in the position of turning a patient away at 7 am the day of the surgery. For those patients who are not signing in the office, make sure that one of your pre-procedure call questions has to do with patient rights. “Have your read and signed your Patient Rights document?” “Were these rights explained to you verbally?” Document the answers to these questions. If the answer is no, you are going to have to fax the written information to the patient or reschedule the surgery. Make sure your patients understand the consequences of not bringing this documentation with them to the ASC.

Do I like these new requirements? Absolutely not and I have written in a previous blog about this. (See the archives of the General category) But, it is a requirement of the ASC to participate in the Medicare program, and you must follow these requirements or risk losing certification.

In addition to the signed paperwork on Patient Rights, you must also post written notice of the patient’s rights in a location within the ASC likely to be noticed by patients waiting for treatment. The Waiting Room itself is likely the best location. The ASC’s notice of rights must include the name, address, and telephone number of a representative in the State agency to whom patients can report complaints, as well as the web site for the Office of the Medicare Beneficiary Ombudsman. (Click here for sample copy of Patient Rights Posting, this document can also be a template for the signed Patient Rights document)

The ASC must also disclose, if applicable, physician financial interests or ownership in the ASC facility. This disclosure must also be in writing and given to the patient prior to the date of the procedure. So, either combine this document with the Patients Rights document or create a separate document, and follow the procedures noted above. (Click here for a sample copy of a financial disclosure form)

Check back next week for the post covering Advanced Directives

Submitted by Chris McMenemy, VP Administration

Response to VA Reform Comments

It’s interesting to note that Aneesh Chopra, secretary of technology for the state of Virginia, said that Medicare payment reform is essential and critical to Healthcare IT efforts. And, while his statements are in regard to participation in federal healthcare information technology stimulus efforts, it’s a statement that his own state officials and legislators should look at when it comes to reforms in their own state.

Virginia is one of the most restrictive Certificate of Need states in the nation. I don’t believe I exaggerate when I say that it is almost impossible for physicians in Virginia to obtain a Certificate of Public Need to establish an ambulatory surgery center without participating in a joint venture with a hospital. Medicare pays Outpatient surgery performed in an Ambulatory Surgery Center at about 62% per procedure in comparison to what it pays to a hospital for the same surgery. Medicare pays more for hospital outpatient surgery and patients pay higher deductibles and co-pays. Both save when outpatient surgery is performed in a freestanding ambulatory surgery center. (For more information on this topic, please see Dear President Obama in our Ortmann Healthcare Blog under the General Topics Category.)

Outpatient surgery has its place in the hospital and in the ambulatory surgery center. Technology continues to change the nature of surgery in this country. Surgeries that were unthinkable as outpatient procedures just a few years ago are now routinely done on an outpatient basis. And while there are procedures and/or patients that for safety’s sake need to be performed in the hospital in case a quick and easy admission becomes necessary, there are many, many surgeries that are perfectly safe and effective in the ASC.

And one of the continuing arguments given by CON states—that ASCs take the best business away from hospitals and leave only charity cases—has not been proven. In fact, taking some of the simpler procedures from the hospital is freeing up OR schedules in hospitals, allowing more time for more complex, high paying procedures.

Despite the very good reasons for allowing physicians to setup ambulatory surgery centers, Virginia’s restrictive Certificate of Public Need statue and policies obstruct this process. I do not disagree with Mr. Chopra that healthcare reform is needed; however, Virginia could certainly do its own part in this vital process.

Submitted by Chris McMenemy, VP Administration

Ortmann Healthcare Consultants Selected for Morledge Family Medical Village

Ortmann Healthcare Consultants is pleased to announce they have been selected as the ambulatory surgery center development firm for the highly anticipated remodeling of the College Park Professional Building in Billings, Montana. More information about this project can be found in this article from the Big Sky Business Journal.

NY Times Article

The NY Times has an interesting article on their website this morning regarding the difficulty of finding a physician who accepts Medicare. The most obvious reason for a doctor opting out of Medicare: low reimbursement rates. This shouldn’t be a surprise to anyone in the surgery center business, as we have been watching our reimbursements steadily decline for those procedures most often received by Medicare beneficiaries. This is a good recreational read and fairly accurately documents what may be a sign of things to come in terms of physician shortages and decreased access to care as many surgery centers are choosing to remain out of network or declining Medicare participation. A full copy of the article is available on the NY Times website.

Infection Control Surveys

The ASC Association released some information in an email update published yesterday regarding the Department of Health and Human Services intention to develop a new infection control survey tool for ambulatory surgery centers. If you do not currently receive ASC Association email updates you can sign up on their website. Copied below are the comments from the News Flash released by the ASC Association.

“Testifying before Congress today about preventing infections acquired in health care settings, an official from the US Department of Health and Human Services (HHS) announced plans to launch a new survey tool for ASCs. The ASC Association will provide more information on this new HHS initiative as it becomes available. A copy of the HHS official’s remarks directed specifically at ASCs follows.”

“To help prevent serious infections resulting from services performed in Ambulatory Surgical Centers, CMS will use the funds provided in the ARRA [American Recovery and Reinvestment Act of 2009] to implement the nationwide application of a new infection control survey tool developed in consultation with CDC [Centers for Disease Control and Prevention] and a case tracer methodology that tracks a patient’s care from admission to discharge. In addition, CMS will use the ARRA funds to survey Ambulatory Surgical Centers using this survey application at the rate of approximately once every three years during this national pilot.”

“A CMS[Centers for Medicare and Medicaid Services]/CDC pilot program tested the enhanced survey process in Maryland, Oklahoma, and North Carolina in 2008 and demonstrated superior results in the ability to detect deficient infection control practices. The particular focus on Ambulatory Surgical Centers for this funding was chosen because the available infection control tool was developed for Ambulatory Surgical Centers and because of the likely continuing infection control deficiencies in this setting.”

“The primary use of these dollars will be to pay for the expansion of Ambulatory Surgical Center surveys (both in quality, time, and number) using the new infection control tool and case tracer methodology. The funds will allow states to hire additional surveyors (one to four per state dependent upon Ambulatory Surgical Center growth), which will increase a state’s capacity to maintain expected levels of Ambulatory Surgical Center inspections while building greater capacity to use the improved survey tool nationwide. In recent years, funding for survey and certification activities supported recertification of Ambulatory Surgical Centers once every ten to fourteen years; this new funding will enable CMS to perform targeted survey and certification activities much more frequently.”

Reference: ASC Association News Flash Email update, published April 1, 2009.