Today’s question of the day is a question that is asked of Ortmann Healthcare Consultants frequently. Medicare regulations require the ASC to be a separate and distinct entity from other entities sharing space in a medical office building. The ASC cannot use space in other medical offices as ASC space, even for medical record storage. If the ASC is renting space from another office, the office must be closed while the ASC is open. Also, ASC employees must be ASC specific unless an employee lease agreement is in place and the employees are at the ASC during the hours it is in operation, and not moving back and forth between offices.

The only instance where we have seen an ASC “share” space with other medical offices is through the use of a shared reception area, where a patient enters the building through a shared space, registers with the receptionist at the registration desk and is then shown to the waiting room for the ASC. This waiting room must be specific to the ASC and cannot be shared with other offices.

If you have questions for Ortmann Healthcare Consultants, you can post them in the comments section of our blog or send them to Jessica.Miller@ortmannhealth.com.

Ortmann Healthcare Consultants wishes you a safe and Happy Thanksgiving! Check back next week for new postings!

Emergency Management Planning is now a requirement for ambulatory surgery centers. An effective policy should be in place to respond to emergencies and the emergency management plan is an essential part of meeting this requirement. CMS has issued a checklist to assist you in writing your plan.
Here are a few key elements from the checklist to include:

• All Hazards Continuity of Operations (COOP) Plan: Develop a continuity of operations business plan using an all-hazards approach (e.g., hurricanes, floods, tornados, fire, bioterrorism, pandemic, etc) that could potentially affect the facility directly and indirectly within the particular area of location. Indirect hazards could affect the community but not the facility and as a result interrupt necessary utilities, supplies or staffing. Determine all essential functions and critical personnel.
• Collaborate with Local Emergency Management Agency: Collaborate with local emergency management agencies to ensure the development of an effective emergency plan.
• Develop Evacuation Plan: Develop an effective plan for evacuation, by ensuring provisions for the following are specified: Identification of person responsible for implementing the facility evacuation plan (even if no outside evacuation order is given), Multiple pre-determined evacuation locations (contract or agreement) with a “like” facility have been established, Evacuation routes and alternative routes have been identified, and the proper authorities have been notified, Adequate food supply and logistical support for transporting food is described, Procedure for protecting and transporting resident/patient medical records, Determine a method to account for all individuals during and after the evacuation.
• Facility Reentry Plan: Describe who will authorize reentry to the facility after an evacuation, the procedures for inspecting the facility, and how it will be determined when it is safe to return to the facility after an evacuation. The plan should also describe the appropriate consideration for return travel back to the facility.
• Review Emergency Plan: Complete an internal review of the emergency plan on an annual basis to ensure the plan reflects the most accurate and up-to-date information. Updates may be warranted for: Regulatory change, New hazards are identified or existing hazards change, After tests, drills, or exercises when problems have been identified, After actual disasters/emergency responses, Infrastructure changes, Funding or budget-level changes,etc.

The Emergency Management Plan should be incorporated into your Policy and Procedure manual. Make sure you staff is briefed on the plan and that its incorporation into the manual is reviewed and approved by the Board of Directors.

If you need further assistance preparing an emergency management plan to meet the new CMS Conditions for Coverage, contact Ortmann Healthcare Consultants at 803-252-7979. We’d be happy to help!

Submitted by Jessica Miller, Director of Regulatory Affairs

Ortmann Healthcare Consultants is taking today to remember our Veterans. Thank you for your dedication and commitment to making this country and our world a better place.

Sorry for the recent lack of postings. It’s been a week of computer failings and traveling for the Ortmann team, but we are back on track and excited for this weekend! Ortmann Healthcare Consultants will be at Becker’s ASC Review’s 16th Annual Improving Profitability, and Business and Legal Issues for ASCs Conference. Come and visit us at booth space 28 where we will have information regarding our company and projects, and of course, CANDY! Key members of our consulting team will be there to answer your questions as well, including Chris McMenemy, VP of Administration, and Jessica Miller, Director of Regulatory Affairs. The conference runs October 8-10 at the Westin Hotel and Conference Center in Chicago, Illinois. More information can be found at Becker’s ASC Review.Please stop by our booth and say hello-we hope to see you there!

You are a dedicated GI physician who has just completed construction on a single specialty ambulatory surgery center. You’ve got your equipment, staff, and certifications in place and already have a list of patients eager to have their procedures at your beautiful, brand new facility. After months of working with a development team, you are ready to cut the cord and start running your facility. And then the question comes from the head of the consulting team: “Are you thinking about retaining us further for management services of your facility?” And you’re thinking-No way! Spend more money? Have even more hands involved?

Well, here are a few reasons to re-think what a management company can, and should, be doing for you. Finding a management company with these traits can put even more money back in your hands!

1. Expertise-Obviously the most important reason to use a management company is that they have experience and credibility in the ASC industry. This isn’t their first rodeo and good management companies will know how to handle any issue that may arise, whether its related to keeping on top of licensure and credentialing paperwork or preparing the budget.
2. Negotiation skills-Expertise in this area will directly affect the bottom line. A management company can help you save money on contracted services, or collect more when it comes to managed care. A management company can periodically review your managed care contracts and negotiate for new rates based on their experience in the marketplace. They can also review your service contracts and negotiate for better terms based on market conditions.
3. Vigilance- You already have your Center Director playing two roles: administrator and nurse. Don’t add financial ovesight to her already growing list of responsibilities. A management company with access to billing software can provide direct oversight of the billing and collecting process, tracking how much and when reimbursements are applied, and allowing them to react when problems arise.

Ortmann Healthcare Consultants provides management and consulting services to new and existing ASCs. If you are interested in learning more, you can reach us at 803-252-7979.

Submitted by Jessica Miller, Director of Regulatory Affairs

In early September 2001, Fred W. Ortmann III, founded Ortmann Healthcare Consultants. Fred had retired as a colonel from the Air Force in the late eighties, and spent his career with the military in hospital administration. Fred then helped found AMSURG in 1991 and served as the Vice President for Center Development, overseeing the development of over 100 facilities. When he retired from AMSURG, Fred decided to move closer to his home town and started his business in Columbia, South Carolina.

The company has grown in the past eight years from a small consulting firm to a major player in the ambulatory surgery center development business. Ortmann Healthcare Consultants (OHC) started its business by developing two large surgery centers in South Carolina. A year later, OLYMPUS America, Inc., conducted a national search and selected Fred as the consultant to develop a new service line for the company. This line includes a sophisticated pro forma development tool called the EndoPlanner, for which Fred is a co-patent holder. The Olympus project gave OHC a good start in the ambulatory surgery center development business. Today the company has a number of development projects across the country, ranging from Kona, Hawaii, in the west, to Goldsboro, North Carolina, in the east, to Fort Lauderdale, Florida, in the south, and North Dartmouth, Massachusetts, in the north. OHC has developed physician-owned ASCs, hospital/physician joint venture ASCs, and is currently working on two hospital outpatient surgery departments that will use physician management to run the departments.

The company is based on three rather simple principles: honesty, integrity, and excellence in all we do. To our knowledge, every ambulatory surgery center we have developed is open and successful. We believe the key to this success is that we know and understand the core concepts that yield successful ambulatory surgery centers.

Since our start in 2001, we have added staff and moved into management and ownership of centers, but continue to stand firmly on our basic principles.
We provide:

• Full, turn key development services for ambulatory surgery centers, regardless of ownership position
• Economic analysis, which we call a Proforma, for those considering development of ambulatory surgery centers
• Consulting studies for existing surgery centers
• Management of ambulatory surgery centers
• Ownership participation interest in ambulatory surgery centers

As a full service development company, we provide in-depth consulting in all aspects of ambulatory surgery development. Our strengths include physician/hospital relationships, ASC negotiation skills, development of financial Proformas, clinical services, managed care contracting, equipment planning and regulatory management.

We have extensive experience in both single and multi-specialty ambulatory surgery center development and have worked on centers featuring all of the medical specialties: orthopedics, ophthalmology, GI endoscopy, urology, ENT, GYN, plastic surgery, podiatry, bariatric surgery, pain management, and general surgery.

We have not had deficiencies on any state, Medicare, or accreditation inspection of the centers we develop. This means these centers open on time, cases begin and budgets are met. This is primarily due to our superb clinical staff that is in almost daily contact with our centers. The quality of our work has been acknowledged in a number of national publications, and our pro-formas have been recognized by many CPAs and financial institutions for their accuracy, honesty and conservative projections. Our greatest strength, however, is our people and their absolute dedication to our clients and our principles.

We also owe many thanks to the clients and business associates who have made the past 8 years such a success. Cheers to the future of Ortmann Healthcare Consultants!

Ortmann Healthcare Consultants will be at Becker’s ASC Review’s 16th Annual Improving Profitability, and Business and Legal Issues for ASCs Conference. Come and visit us at booth space 28 where we will have information regarding our company and projects, and of course, CANDY! Key members of our consulting team will be there to answer your questions as well, including Chris McMenemy and Jessica Miller. The conference runs October 8-10 at the Westin Hotel and Conference Center in Chicago, Illinois. More information can be found at Becker’s ASC Review.

York County Endoscopy Center, a recently completed Ortmann Healthcare Consultants project, is hosting an Open House tomorrow, Wednesday, September 2, from 4-7pm. This will be the official unveiling of the new facility and the event is open to the community! We hope to see you there!

In late June, the Massachusetts Department of Health began sending letters to ambulatory surgery centers across the state notifying them of the changes to licensure requirements for clinics under the new Chapter 305 regulations. According to the new regulations, ambulatory surgery centers are no longer exempt from licensure requirements. All ambulatory surgery centers will be required to seek licensure status by December 12, 2009.
For facilities that are Medicare certified or accredited, there is a deemed-by-accreditation licensure option. This option is available to Medicare certified and accredited ambulatory surgery centers that were in operation on August 10, 2008, or an ASC that was under construction on August 10, 2008 and that is in operation on December 12, 2009.

Furthermore, the Department expects that those ASCs planning to take advantage of the grandfathering provisions in chapter 305 will be applying for licensure as substantially the same entity that was in operation in August of 2008. The grandfathering provision does not apply to, for exmaple, a surgery center with one physician and one OR that in the interim has added two more physicians or another operating room. The Department would find that the newly-configured ASC was not in operation on August 10, 2008 and the ASC would be required to obtain a Determination of Need (DoN) prior to licensure. Similarly, if an ASC that operated as a single-specialty practice on August 10, 2008 seeks clinic licensure as a multi-specialty practice, the Department would find that the multi-specialty practice was not in operation on August 10 and therefore would need DoN approval prior to licensure. You can seek an advisory opinion from DoN if you have specific questions regarding changes in your facilities operation.

If you need more information, here is a copy of the updated regulations 105 CMR 140.000: Licensure of Clinics. Copies of the circular letters and required forms can be found at the DOH ASC Licensure website.

If you are an ambulatory surgery center in the state of Massachusetts and your facility needs assistance becoming compliant with the new regulations, contact Ortmann Healthcare Consultants. We have worked in Massachusetts, are familiar with the changes, and can assist your facility in completing the required paperwork for licensure. And as always, the sooner you complete this paperwork, the better!

Submitted by Jessica Miller, Director of Regulatory Affairs