It seems that every week we read about a new procedure being done in ASCs. This is good news because evidence points to the quality and safety of the ASC environment. Femtosecond laser cataract extraction, total knee and/or hip replacements and ultrasound guided blocks are some recent examples. For 2016, CMS finalized the addition of 17 codes to the ASC-payable list.
Providers may be eager for the opportunity to perform new procedures in your facility, but there are many things to think through before taking the leap. Of course you know that your governing body must approve (and document approval) for new procedures. But before asking for a change to the approved procedure list, use AAAHC Accreditation Standards as a framework for considering the implications.
Before your surgeons, proceduralists, or anesthesiologists can begin performing a new procedure in your center you must grant them privileges. Start by reviewing what your medical staff by-laws say about adding new privileges.
- What education, training, and experience do you require?
- How will you evaluate current competence?
- What documentation will you look for?
- What time frame is applied to the new privileges?
Operational factors – personnel, equipment, and costs
- Are you subject to Certificate of Need (CON) constraints?
- Will new or additional staff training be required to accommodate these new procedures? How will that training be delivered?
- Is there anything that should be added to your pre-op evaluation?
- Will the new procedure(s) add extra time to your OR and recovery room scheduling?
- Will these new procedures require you to purchase or lease new equipment? How long will it take you to get the new equipment?
- How will you clean, disinfect and or sterilize the new equipment?
- Are there significant costs for “disposable,” one-time use devices needed in conjunction with the newly purchased equipment?
- Are there implications for your physical environment, e.g. new construction required?
- Do you need a special power source, e.g. 240 volts, to be added to your operating room to accommodate the new equipment?
- Do you have to make changes to your existing space?
- Do you have policies in place for obtaining blood or blood products or “recycling” blood lost by the patient?
- Do you need to send the patient home with special dressings or devices that qualify as durable medical equipment (DME)? Who will apply the dressings and who will educate the patient and/or family member on how to maintain these or change them if necessary? If there are devices, who will educate the patient on device use and will there be follow-up provided on device maintenance?
- Will in-home nursing care follow-up be required? Will the surgeon be arranging this or are you expected to do this?
- Do you know how to code for the procedure(s)? Will your third-party payers cover these procedures in your center?
- Will you have to adjust your charges?
And don’t forget:
- Have you met notification requirements from your accrediting organization prior to the implementation of new services?
This is not an all-inclusive list of questions to answer before you add new procedures but, at a minimum, these are topics you should be able to answer. If you have not considered these kinds of likely-to-arise issues before you add the procedures, you may be forced to deal with economic and/or medical-legal questions arising later.
Be progressive – but be cautious.
About the author
Jack Egnatinsky, MD, has been a surveyor for AAAHC since 1996, and currently serves as the AAAHC Medical Director. Egnatinsky is an anesthesiologist who lives in Christiansted, U.S Virgin Islands. He is Board Certified by the American Board of Anesthesiology and a Fellow of the American College of Anesthesiologists.