Sunday, January 30, 2011
The HealthCare Accreditation Specialists!: Compliance Doctor Releases Newly Improved Policy Manual for Home Health Agencies
Saturday, January 29, 2011
The Compliance Doctor has taken the time to update the National Manual for Home Health Agencies recently published in 2008 and has updated it to meet the 2011 standards rolled out by the changes notifications of states in the US and by the regulatory bodies that govern the HHA Accreditations through the government allowed Medicare Deem Status. Visit the Marketplace of the website for more info on how to get your manual with the newest policies necessary to stay current with state and federal regulations.
Wednesday, January 19, 2011
30 States require that the ASC either have a transfer agreement in place with a hospital or physicians performing surgery have admitting privileges at the hospital.14 states require an established transfer agreement.
Medicaid Agency; and
b. All physicians performing surgery in the center shall have admitting privileges at the hospital.
emergency care beyond the scope of the ability or license of the facility.
nature which can’t be handled by the ASC.
the hospital and ensured timely admission to the hospital when physician determines it is
transportation, sharing of services, equipment and personnel, provision of total care or portions
thereof in relation to facility and agency capability, and patient record confidentiality.
time from the hospital for patients requiring attention for an emergency or other condition
- New York
hospitalization is indicated.
- North Carolina
ASC is still considered to be in compliance if it has documentation to support its efforts to
establish a transfer agreement with a hospital and has been unable to secure an agreement.
emergency situations, and for other needs as they arise.
- South Dakota
ambulatory surgical facility’s medical staff.
provide the level of care necessary to meet the needs of the patient.
b.The ASC shall have a written agreement with any and each licensed facility that admits patients
for post surgical care.
14 states require either an established transfer agreement or physicians performing
surgery to have hospital admitting privileges.
physicians performing surgery in the ASC shall have admitting privileges at the hospital.
b.The ASC shall be allowed to have offsite pre-planned transfers to other licensed facilities that
can provide the level of care necessary to meet the needs of the patient.
performed at the ASC at a licensed hospital within reasonable proximity, a transfer agreement
needs to be in place with a local hospital within reasonable proximity (not to exceed 30 minutes
from the facility; or
b. The medical staff at the center has admitting privileges or other acceptable documented
arrangement to ensure the necessary backup for the center for medical complications.
c. The center must have the capability to transfer a patient immediately to a hospital within a
reasonable distance from the facility with adequate emergency room services.
d. Hospitals shall not unreasonably deny a transfer agreement to the center.
who directs/supervises the administration of anesthesia, must have:
a. Admitting privileges at a nearby hospital
b. Transfer agreement with another practitioner who has admitting privileges at a nearby
c. An emergency transfer agreement with a nearby hospital.
b. Practitioners are privileged to perform these procedures in at least one licensed hospital in the
community in which the ASC is located.
hospital that meets the requirements for payments for emergency services under 42
Code of Federal Regulations, Section 482.2.; or
b. All physicians must have admitting privileges at such a hospital.
b. All practitioners performing surgery in the ASC are required to have admitting privileges at a
b. Physicians with surgical privileges at the center must have admitting privileges at the hospital
c. The hospital must be a Medicaid-participating provider, and must be licensed to operate in
accordance with 105 CMR 130,000 or with its own state’s licensing agency.
procedures in at least one licensed hospital in the community in which the ASC is located;
b. Alternatively, need a working agreement with at least one licensed hospital in the community
in which the ASC is located, guaranteeing the transfer for emergency treatment whenever
b. All physicians performing surgery in the ASC shall have admitting privileges at a general
hospital located not more than 20 minutes travel distance from the center.
b. Physicians performing surgery in the ASF shall have admitting privileges at a hospital in close
proximity to the ASF, to which patients may be transferred.
- Rhode Island
b. Permit elective surgery only by licensed practitioners who have similar privileges at a nearby
licensed hospital and approved by the ASC’s governing body.
- South Carolina
agreements with other facilities, as applicable.
b. All physicians performing surgery at the ASC shall have admitting privileges at a local hospital.
b. Shall have a written transfer agreement with one or more full-service licensed hospitals located
within an overall travel time of 15 minutes or less from the facility.
Want to build your own surgery center?Author:
After you estimate your square footage, re-run the pro-forma and subtract 500 or 1,000 feet from the building program and re-run the numbers. The cost to construct the shell and interior of an ASC can be between $165 per square foot to as much as $300 per square foot. The reduction of 1,000 square feet from your construction estimate could save you as much as $165,000 to $300,000 in construction costs, and $30,000 or more in annual operating costs. If the center is properly designed, the reduction in square footage may not cause any change in the function of the building.
New vs. Existing Facilities
There are nonetheless some disadvantages to a completely new construction site. If you select a previously constructed building, the architect will have existing structures which may somewhat limit the facility design, but, conversely, all site development work will have been done and paid for, and construction time can possibly be substantially reduced.
Those who have not previously developed Ambulatory Surgery Centers often believe that ASC construction is the same as medical office building construction, when, in fact, the two types of structures are different. Because of the obvious life-safety concerns, a single city inspection is now replaced by multiple inspections at the city, state, and federal levels.
Federal Level Regulation
On the federal level, some limited construction information can be found in the Code of Federal Regulations-Title 42, Volume 2, Chapter IV, Part 416-Ambulatory Surgical Services. Some consider the 'Guidelines for Design and Construction of Hospital and Health Care Facilities,' published by the American Institute of Architects, as the bible for construction of Ambulatory Surgery Centers.
State Level Regulation
When you research the construction standards for Ambulatory Surgery Centers, you will find, unfortunately, that there is little uniformity among the states. Some states have no regulations regarding Ambulatory Surgery Centers, while other states have quite lengthy regulations which include many facility standards. For example, Florida has adopted many national construction codes and includes a listing of those codes in their ambulatory surgery state regulation.
Often the city or local entity will require that your construction documents be approved by the city construction office before you can receive a construction license.
The Construction Team: You Can\'t Afford Rookies
Often we tend to think of the construction team as simply the general contractor, when in fact the team has many members. The construction team consists of the architect, the engineer, and on occasion structural and civil engineers. The cost for each of these team members should be reviewed as a part of the overall construction costs. An ASC is a complex facility, which requires special knowledge and experience on the part of the entire design team.
Selecting a General Contractor
When selecting a contractor, always look for one who has done medical projects, preferably Ambulatory Surgery Centers. Check not only the references of your general contractor, but the references of the proposed sub-contractors as well to ensure they have had experience meeting healthcare requirements. The construction process can be an adversarial process, and at times confrontational, so be careful when selecting a friend as your contractor. If there is a very important person (VIP) on your project, it is the construction superintendent.
The Construction Contract
Once your construction contract has been either bid or negotiated, the general contractor will ask you to sign a construction contract. Look for changes to the standard form which were made by your contractor, and don\'t hesitate to have your attorney review the contract. You should always specify a time of completion for the project, and in some states you can even include special penalty clauses to charge the contractor, in the event the work is not finished on time.
Once the construction contract has been signed, a representative of the ASC gives the contractor a notice to proceed, and the contractor will obtain building permits from the local building authority. Thereafter, monthly progress meetings should be held with the contractor, architect and ASC representative (consultant) to resolve outstanding issues, ensure that the facility is being constructed based on the architect\'s plans, and ensure that the timeline for construction is being met.
If the contractor finds a problem with the architectural drawings or if a change is requested by the ASC, then a change order may be requested by the general contractor. Change orders can increase contract costs significantly and must be closely monitored. It is quite common to experience change orders that increase building costs as much as 10 to 20 percent of the total construction cost.
During the construction process, the construction will be monitored on a daily basis by the superintendent, and the city or county having jurisdiction will make numerous inspections to ensure all city codes are being met. In addition, some states will make periodic inspections, as well as full inspections at the completion of the project.
Boiler inspection if you have boilers on your sterilizers
Emergency power system
Nurse call system
Fire sprinkler system
Depending on the state, the following inspectors may be sent to evaluate the ASC: fire marshal, sanitarian, boiler inspector, construction department, pharmacy board, and licensure office. Construction of an ASC is a complex and heavily regulated process, which requires knowledgeable and experienced participants at every step in the process.
Troy Lair, founder of The Compliance Doctor, LLC has been in health care for over 20 years. Providing expert consulting the past six years, Lair has focused his last decade on the ambulatory business of health care. Having working in acute care settings in Kentucky, Chicago, and most recently worked as an executive for Tenet Health Care in Pasadena, CA. Lair resides in Los Angeles, and provides his services to the entire nation with over 350 Clients served to date. www.thecompliancedoctor.com
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