Georgia Certificate of Need Issues New Thresholds

Georgia has recently amended its Certificate of Need capital expenditures thresholds for single specialty physician owned ambulatory surgery centers and joint venture ambulatory surgery centers. These thresholds became effective on July 1, 2009. A copy of the memorandum containing the new thresholds is available here. Georgia CON Thresholds
So what does this mean for physicians and ASCs in GA? Hopefully the new thresholds will positivily impact the physicians ability to develop single specialty centers in GA as the thresholds have been increased from their historical limits. Costs which are not included towards the threshold are according to O.C.G.A. 31-6-40(a)(2)…” the expenditure or commitment of or incurring an obligation for the expenditure of funds to develop certificate of need applications, studies, reports, schematics, preliminary plans and specifications or working drawings, or to acquire sites;”…
For more information regarding the CON program in Georgia, please visit the GA CON website.

Question of the Day- Florida State Reporting

Does Florida require mandatory reporting for ambulatory surgery centers?

Facilities that meet the definition of an ambulatory center are required to report ambulatory patient data in accordance with Chapter 59B-9, Florida Administrative Code (F.A.C.). You can find information regarding state reporting at the Florida Center for Health Information and Policy Analysis website. This website can be used as a reference when submitting and making corrections to your patient data report. Once you have accessed the website you will need to review the following documents:

• Reporting Period Schedule – The patient discharge data reporting schedule (1 page)
• Ambulatory/ED Patient Data Contact Personnel Documentation Form (1 page)
• Facility User Account Agreement Form – Form granting access to secure data upload internet site (3 pages)
• XML Schema – File format for reporting ambulatory patient data (7 pages)
• Sample XML file – Sample file of how your final report should look upon submission (3 pages)
• Chapter 59B-9 F.A. C. – Administrative rule mandating reporting of patient data to AHCA (9 pages)
• Ambulatory Patient Data Elements – A breakdown of all data elements in the file and its description (5 pages)
• AS/ED Audit Dictionary – A spreadsheet of the all audits your data will be processed through and a detailed description of the audit error message. (9 pages)
• Physician License Number Format for state reporting – The DOH Florida Medical License Search website

The Ambulatory/ED Patient Data Contact Personnel Documentation Form and the Facility User Account Agreement Form can be found at the website with the Resources link.

If you are using any type of IT that assist in state reporting you will want to forward the link labeled Ambulatory/ED XML Schema to your vendor/programmer. This document is the file format for reporting. The Ambulatory/ED Sample XML File is how your data should look when it is received by the Agency. This should also be forwarded to your vendor/programmer.
Again, all of this information is available on the AHCA SCHS website.

Submitted by Jessica Miller, Director of Regulatory Affairs

CDC issues 10 pandemic preparedness recommendations for outpatient facilities

The CDC has issued 10 recommendations for outpatient facilities to prepare for the possible flu pandemic they are anticipating this fall. They have also provided a useful “Medical Offices and Clinics Pandemic Influenza Planning Checklist”. Among the CDC recommendations:

• Develop a Business Continuity Plan
• Protect your work place by asking sick employees to stay home
• Provide immunization at no cost to your employees
• Plan now so you will know where to turn to for reliable, up-to-date information in your local community

Many of the recommendations are just good common sense health practices, but developing a written plan to provide for these patients often encourages compliance.
To read the full list of recommendations, visit the CDC Website.

In the News- Morledge Family Eye Clinic

Ortmann Healthcare Consultants is always excited to hear when a town is anticipating the construction of a new ambulatory surgery center and medical office building to improve quality and access to healthcare. This is exactly what is happening for the Morledge Family Eye Clinic, located in Billings, Montana. Ortmann Healthcare Consultants was chosen as the developer for the ambulatory surgery center portion of this project and more details can be seen in this short news video clip that aired on Montana’s KTVQ.

Congratulations Samuel Cho, MD PC!

As noted yesterday, Ortmann Healthcare Consultants was on the front lines of the New York Accreditation deadline. We assisted Dr. Samuel Cho on accrediting his two office based surgery practices, one in Flushing and the other in Downtown Manhattan. Both facilities passed without deficiency continuing the Ortmann tradition of no deficiencies for any survey or inspection we have prepared for. Congrats again to Dr. Cho and his team for their tremendous work in achieving accreditation!

Red Alert- NY Office Based Accreditation Deadline is TOMORROW!

Tomorrow will be a day of reckoning for many office based surgery practices in New York. July 14th is the deadline by which all office based surgery practices must be accredited in order to continue practicing office based surgery in New York. Not only must you be accredited but the state must also have verification of your accreditation status. Those office based practices not in compliance will risk facing serious penalties if they continue to practice without accreditation. More information is available at the NY Department of Health website.

For those not in New York, you probably felt a little of the backlash if you have been trying to reach the accreditation agencies in the past week. They have been swamped with last minute requests and planning surveys.

If you are in New York, hopefully you were among the early birds in recognizing the importance of planning for your survey well before tomorrow’s deadline! If you would like to share your story, please leave it as a comment to this post. Ortmann Healthcare Consultants has personally been involved in the accreditation of two office based surgery practices in New York and it was certainly a challenge to bring our facilities up to speed since there has not been a regulation like this for them in the past!

Managing the Red Zone-Part III

Today’s post is the final in our series covering Management of the Red Zone in ambulatory surgery center development.

Planning in the Red Zone
If this were an ideal world and everything was perfect, we could generally rely on our time-line to help us complete the project in an orderly manner. The world, however, isn’t perfect, and rarely, if ever, is the best of time-lines. The successful coach learns quickly how to adjust his plays in the Red Zone when scouting reports prove unreliable during the game. When we are about to enter the “Red Zone”, it is time to stop and determine how well we have achieved our objectives and whether any adjustments must be made.

When entering the “Red Zone”, it is time for the principals on the development team to meet, assess their progress to date, and develop a detailed plan to finalize the project. At a minimum the meeting should include the developer, the architect, the general contractor, the equipment planner, the interior designer, and the Center Director.

The General Contractor is the key player in this meeting and should be asked when the Certificate of Occupancy will be received. The general contractor should be told that the ASC will be scheduling equipment deliveries, hiring staff, and purchasing services based on this date. The date must be accurate and we will expect him to jump tall mountains or hire added staff, if necessary, to meet the date he gives us. Some would say this date is a function of the dates stipulated in the construction contract; however, we don’t mention contract dates at this meeting, and prefer to ask the contractor to commit to an absolute date. We have generally found that a contractor will impose a more demanding date on himself than if we impose an artificial date on him.

In certain circumstances, it may be advisable to offer economic incentives if the contractor can accelerate the schedule. Once we have the absolute date for the C.O., we have our eye on the project goal, and we can identify all remaining key tasks and their required completion time, in order to successfully cross the “Red Zone”. A list of items to be checked is provided as Illustration 1. This meeting and our identification of all remaining tasks becomes our “Red Zone” plan, which should be typed and distributed to all participants.

Red Zone Management
Just as the head coach is in charge of his team, one person should be charged with maintaining the plan and communicating changes to all participants. Each participant must understand that any deviation from the plan must be immediately reported to the person charged with maintaining the plan. The person in charge likewise has to communicate all changes to all participants, and devise a means of overcoming any obstacles that may cause the plan to fail.

Once the plan is distributed to members of the team, weekly conference calls (or more frequently, if necessary) with all team members can reinforce the process, and keep the plan alive.

Our Experience
We have used the Red Zone management method for the past three years, and have finished ninety percent or more of our projects on time. We have learned:

1. Early focus on the completion of the project leads to consensus building and on-time job completion.
2. We are able to eliminate the development of most crises’ near the end of the project.
3. We have been able to achieve better planning among all members of the development team.
4. Working capital budgets are met and pro-formas are generally not exceeded.
5. Medical partners have a higher degree of satisfaction in the process.
6. General Contractors like the process and honor their commitments.
7. The ASC opens on time, sees patients rapidly after opening, and receives reimbursements from patient care early in the process of center opening.
8. We dramatically reduce the time needed to fully develop a center, and thereby, save substantial resources as a result.
9. We cross the “Red Line”.

And as today’s successful football team can only be successful by consistently scoring from the Red Zone, today’s successful ASC was likely coached during the development process by a team that understands the value of Red Zone Management, a team that knows how to cross the Red Line.

Submitted by Fred Ortmann, President, CEO

Congratulations York County Endoscopy Center LLC

York County Endoscopy Center LLC

It doesn’t get any better than this…Ortmann Healthcare Consultants is pleased to announce and congratulate York County Endoscopy Center LLC on the successful completion of their South Carolina State Licensure Survey. This is the second Ortmann Healthcare Consultants project to be successfully state licensed this week and it would not have been possible without the dedication of Dr. Stephen Bott, Susan Ordway, Center Director, and Sarah McKeever. Many thanks to all others involved in getting this project State Licensed! This center continues our tradition of “no deficiencies” on State Licensure surveys!

This facility was designed and constructed by GMK Associates.

Congratulations Harvard Surgery Center LLC

Harvard Surgery Center located in Watkins Medical Building

Ortmann Healthcare Consultants is pleased to announce and congratulate Harvard Surgery Center LLC on the successful completion of their Louisiana State Licensure survey. Harvard Surgery Center LLC is now officially licensed for podiatry ambulatory surgery services in Louisiana! The inspection was completed with zero deficiencies, continuing Ortmann Healthcare Consultants record of “No Deficiencies” for every State Licensure inspection we have been involved in. We also received positive comments on the quality of the work completed and how prepared the center was for inspection. This is indeed a proud day for Ortmann and for all of those who have been involved in the development of Harvard Surgery Center, LLC. Many thanks and special appreciation to Dr. Leon Watkins, Ed Pluta, and Nancy Nemeth!

This facility was designed by Marasco & Associates.

Managing the Red Zone-Part II

In this posting we will pick up where we left off last week discussing Red Zone Planning.

Mapping the Regulatory Process
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:

• State Sanitarian
• State Fire Marshal
• State Department of Construction
• Board of Pharmacy
• Boiler Inspection Department
• Department of Radiation Protection
• Department of Hazardous Waste
• Department of Water Quality
• Department of Health- Licensure Division
• Department of Health- Medicare Division
• Department of Health- Medicaid Facilitation

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.

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
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:

• Heating, ventilation, and air-condition units
• Emergency generators and transfer switches
• Vacuum pumps
• Rated doors and door assemblies
• ADA compliant door hardware
• Concrete (very limited supply in some areas)

Other tasks are directly linked to another task which must be completed before the task can begin. Some of these tasks are:

• Completion of the CMS855-linked to Medicare Certification
• State Pharmacy License-linked to DEA License and necessary to purchase drugs and medical gases
• Acquisition of Center Insurance- linked to Managed Care Contracts

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!

Check back next week for our final posting in this series, covering Planning in the Red Zone.

Submitted by Fred Ortmann, President, CEO