Why Quality Outcomes are in the Spotlight
In 2008, an outbreak of hepatitis C in patients treated at a GI center in Nevada placed infection control practices in ambulatory surgery centers (ASCs) in the national spotlight. The Centers for Medicare and Medicaid Services (CMS) revised the Conditions for Coverage for ASCs in 2009, placing the responsibility for patient rights and infection control squarely on the shoulders of a facility’s governing body. This was the beginning of increased regulation on patient quality outcomes.
Patient infections and deaths resulting from improper infection control measures at the New England Compounding Center (NECC) made national news in 2012-13 and again placed ASCs in the spotlight, as some of the compounded medications had been administered in ASCs across the United States.
Most ASCs, particularly those with active accreditation status, were already meeting the bulk of the new CMS regulations pertaining to infection control. For facilities that were not accredited, but participating in Medicare programs, these changes required a significant revision to their practices and procedures.
The importance of quality outcomes was further underscored with the implementation of the Ambulatory Surgical Center Quality Reporting (ASCQR) Program. The ASCQR is a pay-for-reporting, quality data program finalized by CMS requiring ASCs to report quality of care data for standardized measures in order to receive the full annual update to their ASC annual payment rate. This program started in October 2012 with the reporting of G-codes at the time of billing for procedures performed on patients with Medicare coverage. ASCs were now on the same playing field with hospital counterparts that had been providing quality data to CMS for years.
Quality Reporting Overview
G-code reporting identified the frequency of events in ASCs related to patient falls, burns, transfer, wrong site/side procedure, patient and/or implant and the timeliness of prophylactic IV antibiotic infusion. January 1, 2013, ushered in the requirement to verify use of a surgical safety checklist. Rounding out 2013 reporting requirements, ASCs reported on case volumes performed in 2012 on specific procedures which included ophthalmology, pain, GI, arthroscopic and others.
The ASCQR program added new measures to report in 2014 and will continue to add new measures each calendar year. ASCs that do not meet the reporting requirements, including allowing the data to be publicly available, may incur a 2 percentage point reduction to any annual increase provided under the revised ASC payment system for that year.
The Big Picture on Quality
With these new requirements to report quality data, there is now a direct impact on financial outcomes. Savvy consumers can now view quality data, and select facilities with high-quality outcomes. This visible data can now also be evaluated by managed care organizations in deciding whether to bring an ASC into their network.
Hospitals are currently paid through value-based purchasing by CMS. For example, when a patient presents with a surgical site infection or a readmission for the same health diagnosis, the hospital is not reimbursed for the care provided. The CMS stated goal is “to promote higher quality, more efficient health care for Medicare beneficiaries through quality of care measurement,” and it is likely that in the near future ASCs will have payment tied to quality outcomes in addition to reporting on quality measures.
There are other ways in which poor quality can negatively impact the financial well-being of ASCs. Accredited facilities seek to provide an even higher level of quality care, but failure to achieve the standards can result in financial losses. Should an immediate jeopardy situation arise during a survey, a facility may be closed until it can correct the cited issues. This same scenario can also occur when surveyed by the state health department. The loss of cases during the closure is an obvious financial blow, but the collateral damage from the subsequent negative publicity may impact case volumes for months or longer until the facility re-establishes its credibility.
Quality is comprised of many moving pieces including: infection control, risk management, patient satisfaction, quality studies, peer review, credentialing, OSHA and compliance issues. Separating these pieces, or failure to recognize the linkage, can result in missed opportunities for improvement. Think of these elements as overlapping/linked puzzle pieces. The diagram below illustrates this interconnection.
Providing Quality Care and Achieving Positive Financial Outcomes
These headline-grabbing negative outcomes can be averted. Using best practices can keep your facility finely tuned both in the quality and the financial areas; and meeting or exceeding quality requirements helps prevent the decrease of payments, facility closure or unwanted publicity from negative outcomes.
A supportive governing body engaged in providing quality care lays the foundation for success. Facility management must stay informed of federal, state and accreditation standards, regulations and laws and maintain compliance at all times; and a thorough self-assessment of the facility’s operations can identify areas of non-compliance. The management team, in collaboration with the governing body, can then develop action plans to implement changes to correct any deficiencies.
Ongoing survey readiness is the key to ensuring quality and financial success in your ASC. There are many resources available, including accrediting organizations such as AAAHC, state ASC associations, and the Association for Ambulatory Surgery Centers (ASCA) to name a few. Frequently, publications provide information and sample documents on websites, often at no cost – and don’t overlook networking with peers to find solutions to problem areas. ASCs as a whole have consistently provided quality patient outcomes, and now these efforts are linked to reimbursement for services provided and will continue to evolve in the years ahead.
About the Author
Sarah Martin has over 34 years of experience in health care, focusing on ambulatory services for the past 15 years. A registered nurse with an MBA, she holds the CASC credential and has served on the boards of ASCA, AAASC, Tennessee Ambulatory Surgery Center Association (TASCA), and the ASC Quality Collaboration. She is a frequent speaker at national ASC meetings; has held SVP and VP positions in both operational and clinical/quality roles with national ASC companies; and is a surveyor for AAAHC.