In this posting we will pick up where we left off last week discussing Red Zone Planning.
Mapping the Regulatory Process There is always a pre-determined sequence that each agency follows to inspect an ASC, and scheduling the inspection at the various agencies according to their pre-determined sequence can take weeks. To avoid missing an agency inspection and delaying the project, it is a good idea to map the regulatory process in your state at the very beginning of the project. To properly map the regulatory process, you might want to visit your Department of Health (visit our Blog Post in the Regulatory category for a listing of state agencies) and ensure that you have identified all relevant inspection agencies and learn who schedules the inspections for each agency.
For an ASC, proper execution in the Red Zone includes what you might call Mapping the Regulatory Process. Each state has a process whereby the state licenses and then, under federal contract, certifies the facility for Medicare participation. An uneducated prediction of the state licensure process is certain failure. Unfortunately, it’s rare for any two states to have the same process. It’s also rare to find a publication or guidance describing the various state processes, and rare that the same inspection agencies are used in any two states. Listed below are some of the state agencies this author has encountered in the various states:
The Time-Line
The football coach has a playbook, and the ASC developer/owner should have a playbook, too. Time-Lines are management tools listing sequential step by step actions, matched with their respective start and end times, used by most project planning and management professionals. There should be a project time-line for each ASC to be developed. All project tasks, including those listed above dealing with regulatory aspects and inspection, should be integrated in the overall project time-line so that critical steps are not missed. Many computer software programs are available to help simplify this process for you.
Critical and Linked Tasks Other tasks are directly linked to another task which must be completed before the task can begin. Some of these tasks are:
This is an extremly shortened list, as the number of tasks we have identified as necessary to complete the development of a surgery center number in the 700s!
There are some tasks that quite simply cannot be started and completed if the developer/consultant were to wait to begin the task’s implementation in the Red Zone, with only sixty days remaining on the project. There are also tasks dependent upon or linked to other tasks that must be done sequentially, which makes it almost impossible to start and complete such linked tasks in the “Red Zone” .
The critical tasks are primarily related to the acquisition of construction materials that require long lead times. Some of the products which require long lead times include:
Check back next week for our final posting in this series, covering Planning in the Red Zone.
Submitted by Fred Ortmann, President, CEO
