Every four years, the not-for-profit Facility Guidelines Institute (FGI) publishes revised guidelines for the design and construction of health care facilities, including ASCs and other outpatient surgery facilities. These guidelines are then used by The Joint Commission, many federal agencies and authorities in 42 states as a code or a reference standard when reviewing, approving or accrediting newly constructed health care facilities.

After FGI issued a set of proposed changes recently, the Ambulatory Surgery Center Association (ASCA) convened a task force of industry experts to prepare a response. The task force reached consensus on many of the amendments that were proposed, and ASCA submitted those comments through FGI’s formal comment process in December 2012. At the same time, ASCA also submitted a special letter to FGI to express some of its greatest concerns with the proposed changes and the process by which the standards
are revised.

ASCA’s greatest concern about FGI’s proposed changes to its outpatient surgery facilities guidelines is that the suggested
amendments more closely represent ideal standards, rather than the minimum standards building designers and inspectors rely on FGI to provide. If adopted, the top-tier standards that FGI is proposing would be excessive and burdensome, particularly for smaller ASCs.

A second key concern that ASCA expressed to FGI related to a provision that would increase the minimum operating room size requirement from 120 square feet to 360 square feet. In addition, the provision would increase the minimum operating room size requirement from 400 square feet to 600 square feet if there are “additional personnel or large equipment” needs, although those terms are not defined. From what we ave heard from our members, this dramatic increase in size would be costly and unnecessary.

Other suggested changes about which ASCA raised concerns included provisions that would require:
• Every door in an ASC to be wider than ever before;
• Toilets to be “provided adjacent to” procedure rooms, rather than directly accessible to those rooms;
• A dedicated staff toilet in the recovery area, which would replace an earlier requirement for such a toilet only in facilities with more than two operating rooms;
• A two-position scrub sink at every operating room, which well exceeds the minimum standard;
• All staff lounges to have doors directly into the semi-restricted corridor, which would effectively turn all of these lounges into “surgical staff lounges;” and
• The removal of a section of the guidelines that sets specific requirements for office-based surgical facilities, which are little used today but could prove useful to states and others seeking guidance in the future.

ASCA and our members are committed to meeting reasonable licensing and other regulatory requirements aimed at improving the quality of care that is delivered to patients and ensuring patient safety. At the same time, we are concerned that if these proposed guidelines are finalized as drafted, states that implement them will be imposing undue financial burdens on these facilities. We are urging FGI to reconsider these changes. We are also encouraging FGI to work more closely with us in the future to develop appropriate and meaningful guidelines for ASCs and others.

William Prentice is the chief executive officer of the Ambulatory Surgery Center Association.

For more information about the association, call (703)836-8808 or go to www.ascassociation.org.