Tuesday, November 20, 2018

Whether Newbie or Seasoned Surgery Center Manager, You Should know of the newest technology.

Whether you be a new surgery center manager/administrator or a well seasoned one, there are technologies that are being invented every day that could be a gem for you.  Regardless of where you are located or how big your facility is, there are certain technologies that are coming in and making major head waves in productivity and patient outcomes.

Here below, we have some of the latest ones.  But only the pictures of the device, you have to realize you do or you do not know anything of what this item is.  Let us know if you are up on these or not, we then will send you the links to the product pages.  It is a fun exercise to check your checker so to say.  So here we go:

Hint:  this technology helps to reduce the potential of airborne bugs that cause an infection post operative.

Hint:  When you do ortho cases, this problem can cause a chaotic moment or two in the operators space.

Hint:  this device aids in reducing an order through out your facility.

Hint:  pink is always symbolic to ?

I hope you enjoyed this quiz, and have a nice day.

Monday, November 5, 2018

A new Fact Sheet for IDTFs as of 2016...

An IDTF is a facility that is independent both of an attending or consulting physician’s office and of a hospital.
However, IDTF general coverage and payment policy rules apply when an IDTF furnishes diagnostic procedures
in a physician’s office (see 42 Code of Federal Regulations (CFR) 410.33(a)(1)).
Effective for diagnostic procedures performed on or after March 15, 1999, Medicare Administrative Contractors
(MACs) pay for diagnostic procedures under the physician fee schedule when performed by an IDTF. An IDTF
may be a fixed location or a mobile entity. It is independent of a physician’s office or hospital.
With the exception of hospital-based and mobile IDTFs, a fixed-base IDTF does not:
1. Share a practice location with another Medicare-enrolled individual or organization
2. Lease or sublease its operations or its practice location to another Medicare enrolled individual or
organization or
3. Share diagnostic testing equipment used in the initial diagnostic test with another Medicare-enrolled individual
or organization
Medicare Enrollment
An IDTF should be open and operational at the time it submits the CMS-855B application to initially enroll
in Medicare.
One Enrollment per Practice Location

• An IDTF must separately enroll each of its practice locations (with the exception of locations that are used
solely as warehouses or repair facilities). This means that an enrolling IDTF can have only one practice
location on its Form CMS-855B enrollment application. If an IDTF is adding a practice location to its existing
enrollment, it must submit a new complete Form CMS-855B application for that location and have that location
undergo a separate site visit. Also, each of the IDTF’s mobile units must enroll separately. Consequently, if a
fixed IDTF site also contains a mobile unit, the mobile unit must enroll separately from the fixed location.
• Each separately enrolled practice location of the IDTF must meet all applicable IDTF requirements. The
location’s failure to comply with any of these requirements will result in the revocation of its Medicare
billing privileges.
Effective Date of Billing Privileges
The filing date of an IDTF Medicare enrollment application is the date that the MAC receives a signed
application that it is able to process to approval (see 42 CFR section 410.33(i)). The effective date of billing
privileges for a newly enrolled IDTF is the later of the following:
The filing date of the Medicare enrollment application that was subsequently approved by the MAC or
The date the IDTF first started furnishing services at its new practice location. A newly-enrolled IDTF, therefore,
may not receive reimbursement for services furnished before the effective date of billing privileges.
IDTFs should note that, if an IDTF application is rejected and a new application is later submitted, the date of
filing is the date the MAC receives the new enrollment application.
Leasing and Staffing
A mobile IDTF does not include entities that lease or contract with a Medicare enrolled provider or supplier to
• Diagnostic testing equipment
Non-physician personnel described in 42 CFR section 410.33(c) or
Diagnostic testing equipment and non-physician personnel described in 42 CFR section 410.33(c). This is
because the provider or supplier is responsible for providing the appropriate level of physician supervision
for the diagnostic testing.
Multi-State Independent Diagnostic Testing Facilities
An IDTF that operates across State boundaries must:
• Maintain documentation that its supervising physicians and technicians are licensed and certified in each of
the States in which it operates and
• Operate in compliance with all applicable Federal, State, and local licensure and regulatory requirements
with regard to the health and safety of patients.
The point of the actual delivery of service means the place of service (POS) on the claim form. When the
IDTF performs or administers an entire diagnostic test at the beneficiary’s location, the beneficiary’s location
is the POS. When one or more aspects of the diagnostic testing are performed at the IDTF, the IDTF is the
POS. (See 42 CFR section 410.33(e)(1)). See Place of Service Issues section below for further information
about coding for POS.
Requirements for an IDTF Supervising Physician
An IDTF must have one or more supervising physicians who are responsible for:
• The direct and ongoing oversight of the quality of the testing performed
• The proper operation and calibration of equipment used to perform tests and
The qualifications of non-physician IDTF personnel who use the equipment

Not every supervising physician has to be responsible for all functions. One supervising physician can be
responsible for the operation and calibration of equipment, while other supervising physicians can be responsible
for test supervision and the qualifications of non-physician personnel. The basic requirement, however, is that all
the supervisory physician functions must be properly met at each location, regardless of the number of physicians
involved. This is particularly applicable to mobile IDTF units that are allowed to use different supervisory physicians
at different locations. They may have a different physician supervise the test at each location. The physicians used
need only meet the proficiency standards for the tests they are supervising. Each supervising physician must
be limited to providing general supervision at no more than three IDTF sites. This applies to both fixed sites and
mobile units where three concurrent operations are capable of performing tests.
Supervising physicians must meet the following criteria:
1. Be licensed to practice in the State(s) where the diagnostic tests he or she supervises will be performed
2. Be enrolled in Medicare; however, the physician(s) need not necessarily be Medicare enrolled in the State
where the IDTF is enrolled
3. Meet the proficiency tests for any tests he or she supervises
4. Is not currently excluded or barred
5. Provide general supervision for no more than three IDTF sites
Requirements for an IDTF Interpreting Physician
IDTFs are not required to have interpreting physicians. If the IDTF does have such physicians, the IDTF
interpreting physician must:
1. Be licensed to practice in the State(s) where the diagnostic tests he or she supervises will be performed
2. Be enrolled in Medicare
3. Not be currently excluded or barred
4. Be qualified to interpret the types of tests (codes) listed in the enrollment application
Requirements for an IDTF Technician
An IDTF technician must:
1. Meet the certification and/or license standards of the State in which tests are performed at the time of the
IDTF enrollment and/or at the time any tests are performed
2. Be qualified to perform the types of tests (codes) listed in the enrollment application
Performance Standards for IDTFs
As part of its enrollment application, an IDTF must complete Attachment 2 Independent Diagnostic Testing
Facilities of Form CMS-855B. This attachment lists the Independent Diagnostic Testing Facilities Performance
Standards, are in 42 CFR 410.33(g). In completing the enrollment application, including Attachment 2, the IDTF
certifies that it meets the following standards and all other requirements consistent with 42 CFR 410.33(g).

Requirements for IDTFs:

1 Operate its business in compliance with all applicable Federal and State licensure and regulatory
requirements for the health and safety of patients.
Provide complete and accurate information on its enrollment application. Changes in ownership, changes
of location, changes in general supervision, and adverse legal actions must be reported to the MAC
on the Medicare enrollment application within 30 calendar days of the change. All other changes to the
enrollment application must be reported within 90 calendar days.
Maintain a physical facility on an appropriate site. For the purposes of this standard, a post office box,
commercial mail box, hotel, or motel, is not considered an appropriate site. The physical location must have
an address, including the suite identifier, which is recognized by the United States Postal Service (USPS).
• The physical facility, including mobile units, must contain space for equipment appropriate to the
services designated on the enrollment application, facilities for hand washing, adequate patient
privacy accommodations, and the storage of both business records and current medical records
within the office setting of the IDTF, or IDTF home office, not within the actual mobile unit.
• IDTF suppliers that provide services remotely and do not see beneficiaries at their practice location
are exempt from providing hand washing and adequate patient privacy accommodations.
Have all applicable diagnostic testing equipment available at the physical site excluding portable
diagnostic testing equipment. A catalog of portable diagnostic equipment, including diagnostic testing
equipment serial numbers, must be maintained at the physical site. In addition, portable diagnostic
testing equipment must be available for inspection within two business days of the Centers for Medicare
& Medicaid Services (CMS) inspection request. The IDTF must maintain a current inventory of the
diagnostic testing equipment, including serial and registration numbers, provide this information to the
designated MAC upon request, and notify the MAC of any changes in equipment within 90 days.
Maintain a primary business phone under the name of the designated business. The primary business
phone must be located at the designated site of the business, or within the home office of the mobile
IDTF units. The telephone number or toll free numbers must be available in a local directory and through
directory assistance. IDTFs may not use “call forwarding” or an answering service as their primary method
of receiving calls from beneficiaries during posted operating hours.
Have a comprehensive liability insurance policy of at least $300,000 per location that covers both the place
of business and all customers and employees of the IDTF. The policy must be carried by a non-relative
owned company. Failure to maintain required insurance at all times will result in revocation of the IDTF’s
billing privileges retroactive to the date the insurance lapsed. IDTF suppliers are responsible for providing
the contact information for the issuing insurance agent and the underwriter. In addition, the IDTF must:
• Ensure that the insurance policy remain in force at all times and provide coverage of at least
$300,000 per incident; and
• Notify the CMS-designated MAC in writing of any policy changes or cancellations.
Agree not to directly solicit patients, which include, but are not limited to, a prohibition on telephone,
computer, or in-person contacts. The IDTF must accept only those patients referred for diagnostic testing
by an attending physician, who is furnishing a consultation or treating a beneficiary for a specific medical
problem and who uses the results in the management of the beneficiary’s specific medical problem. Nonphysician
practitioners may order tests as set forth in section 410.32(a)(3).
Answer, document, and maintain documentation of a beneficiary’s written clinical complaint at the
physical site of the IDTF (For mobile IDTFs this documentation would be stored at their home office.) This
includes, but is not limited to the following:
• The name, address, telephone number, and health insurance claim number of the beneficiary
• The date the complaint was received, the name of the person receiving the complaint, and a
summary of actions taken to resolve the complaint
• If an investigation was not conducted, the name of the person making the decision and the reason
for the decision

9 Openly post these standards for review by patients and the public.
10 Disclose to the government any person having ownership, financial, or control interest, or any other legal
interest in the supplier at the time of enrollment or within 30 days of a change.
11 Have its testing equipment calibrated and maintained per equipment instructions and in compliance with
applicable manufacturers suggested maintenance and calibration standards.
Have technical staff on duty with the appropriate credentials to perform tests. The IDTF must be able
to produce the applicable Federal or State licenses or certifications of the individuals performing these
13 Have proper medical record storage and be able to retrieve medical records upon request from CMS or
the MAC within two business days.
Permit CMS, including its agents, or its designated MAC to conduct unannounced, on-site inspections
to confirm the IDTF’s compliance with these standards. The IDTF must be accessible during regular
business hours to CMS and beneficiaries and must maintain a visible sign posting the normal business
hours of the IDTF.
15 Enroll in Medicare for any diagnostic testing services that it furnishes to a Medicare beneficiary,
regardless of whether the service is furnished in a mobile or fixed base location.
Bill for all mobile diagnostic services that are furnished to a Medicare beneficiary, unless the mobile
diagnostic service is part of a service provided under arrangement as described in section 1861(w)(1)
of the Act. (Section 1861(w)(1) states that the term “arrangements” is limited to arrangements under
which receipt of payments by the hospital, critical access hospital, skilled nursing facility, home health
agency or hospice program (whether in its own right or as an agent), with respect to services for which
an individual is entitled to have payment made under this title, discharges the liability of such individual or
any other person to pay for the services.)
If the IDTF claims that it is furnishing services under arrangement as described in section 1861(w)(1), the
IDTF must provide documentation of such with its initial or revalidation Form CMS-855 application.
Billing Issues for IDTFs
Consistent with 42 CFR 410.32(a), the supervisory physician for the IDTF, whether or not for a mobile unit, may
not order tests to be performed by the IDTF, unless the supervisory physician is the patient’s treating physician and
is not otherwise prohibited from referring to the IDTF. The supervisory physician is the patient’s treating physician
if he or she furnishes a consultation or treats the patient for a specific medical problem and uses the test results in
the management of the patient’s medical problem.
If an IDTF wants to bill for an interpretation performed by a physician who does not share a practice with the IDTF,
the IDTF must meet certain conditions concerning the anti-markup payment limitation. If a physician working for an
IDTF (or a party related to the IDTF through common ownership or control as described in 42 CFR 413.17) does
not order the technical component (TC) or the professional component (PC) of a diagnostic test (excluding clinical
diagnostic laboratory tests), it would not be subject to the anti-markup payment limitation (see Chapter 1, Section
30.2.9 of the “Medicare Claims Processing Manual”).
Transtelephonic and Electronic Monitoring Services
Transtelephonic and electronic monitoring services (for example, 24 hour ambulatory EKG monitoring, pacemaker
monitoring and cardiac event detection) may perform some of their services without actually seeing the patient.
Most but not all of these billing codes currently are 93012, 93014, 93040, 93224, 93225, 93226, 93232, 93230,
93231, 93233, 93236, 93270, 93271, 93731, 93733, 93736, 95953, and 95956. These monitoring service entities
should be classified as IDTFs and must meet all IDTF requirements. CMS currently does not have specific
certification standards for IDTF technicians; technician credentialing requirements for IDTFs are at the MAC’s
discretion. They do require a supervisory physician who performs General Supervision. Final enrollment of a
transtelephonic or electronic monitoring service as an IDTF requires a site visit.

For any entity that lists and will bill codes 93012, 93014, 93268, 93270, 93271, or 93272, the MAC must make
a written determination that the entity actually has a person available on a 24-hour basis to answer telephone
inquiries. Use of an answering service in lieu of the actual person is not acceptable. The person performing the
attended monitoring should be listed in Section 3 of Attachment 2 of Form CMS-855B. The qualifications of the
person are at the MAC’s discretion. The MAC shall check that the person is available by attempting to contact
the applicant during non-standard business hours. In particular, at least one of the contact calls should be made
between midnight and 6:00 AM. If the applicant does not meet the availability standard, they should receive a
denial of enrollment.
Ordering of Tests
All procedures performed by the IDTF must be specifically ordered in writing by the physician or practitioner who is
treating the beneficiary, that is, the physician who is furnishing a consultation or treating a beneficiary for a specific
medical problem and who uses the results in the management of the beneficiary’s specific medical problem. (Nonphysician
practitioners may order tests as set forth in CFR 410.32(a)(3).)
The order must specify the diagnosis or other basis for the testing. The supervising physician for the IDTF may not
order tests to be performed by the IDTF, unless the IDTF’s supervising physician is in fact the beneficiary’s treating
physician. That is, the physician in question had a relationship with the beneficiary prior to the performance of the
testing and is treating the beneficiary for a specific medical problem. The IDTF may not add any procedures based
on internal protocols without a written order from the treating physician.
Diagnostic Tests Subject to the Anti-Markup Payment Limitation
In most instances, physicians working for an IDTF do not order diagnostic tests because such tests are generally
ordered by the patient’s treating physician. If a physician working for an IDTF does not order a diagnostic test, the
test is not subject to the anti-markup payment limitation. However, if a physician working for an IDTF (or a physician
financially related to the IDTF through common ownership or control) orders a diagnostic test payable under the
Medicare Physician Fee Schedule (MPFS), the anti-markup payment limitation may apply (depending on whether
the performing physician or other supplier meets the “sharing a practice” requirements). For further information in
this case, IDTFs should refer to the “Medicare Claims Processing Manual,” Chapter 1, Section 30.2.9, Payment to
Physician or Other Supplier for Diagnostic Tests Subject to the Anti-Mark-up Payment Limitation, available at http://
Therapeutic Procedures
An IDTF shall not be allowed to bill for any CPT or HCPCS codes that are solely therapeutic.
Place of Service Issues
CMS released MLN Matters® Article MM7631 on April 1, 2013, which advises physicians, providers, and suppliers
of the national policy and coding instructions for Place of Service (POS). The importance of this national policy is
underscored by consistent findings, in annual or biennial reports from Calendar Year (CY) 2002 through CY 2007,
by the Office of the Inspector General (OIG) that physicians and other suppliers frequently incorrectly report the
POS in which they furnish services.
This article advises that CMS establishes that, for all services, with two exceptions, paid under the MPFS, the POS
code to be used by the physician and other supplier will be assigned as the same setting in which the beneficiary
received the face-to-face service. Because a face-to-face encounter with a physician or other provider is required
for nearly all services paid under the MPFS and anesthesia services, this rule will apply to the overwhelming
majority of MPFS services.
In cases where the face-to-face requirement is obviated, such as those when a physician or other provider
provides the professional component (PC) interpretation of a diagnostic test from a distant site, the POS code
assigned by the physician or other provider will be the setting in which the beneficiary received the technical
component (TC) of the service. For example, a beneficiary receives an MRI at an outpatient hospital near his/her

home. The hospital submits a claim that would correspond to the TC portion of the MRI. The physician furnishes
the PC portion of the beneficiary’s MRI from their office location –POS code 22 will be used on the physician’s
claim for the PC to indicate that the beneficiary received the face-to-face portion of the MRI, the TC, at the
outpatient hospital. IDTFs should review this article in order to use the correct POS code when billing for services.
For more details about this policy, you should refer to MLN Matters® Number MM7631, Revised and Clarified
Place of Service (POS) Coding Instructions. The article is available at http://www.cms.gov/Outreach-andEducation/Medicare-Learning-Network-MLN/MLNMattersArticles/downloads/MM7631.pdf.

Additional clarification about this policy may be found at Frequently Asked Questions Related to Change
Request 7631(Revised and Clarified Place of Service Coding Instructions), dated April 25, 2013, available at

The following resources will help IDTFs understand Medicare requirements:
For More Information About… Resource
“Medicare Claims Processing Manual,” Chapter 35 http://www.cms.gov/Regulations-and-Guidance/
42 CFR 410.33 http://www.gpo.gov/fdsys/pkg/CFR-2010-title42-vol2/
“Medicare Program Integrity Manual,” Chapter 15 http://cms.hhs.gov/Regulations-and-Guidance/
Medicare Enrollment Application CMS-Form 855B http://www.cms.gov/Medicare/CMS-Forms/CMSForms/downloads/cms855b.pdf

MLN Matters® Number MM7631
“Medicare Claims Processing Manual,” Chapter 1 http://cms.hhs.gov/Regulations-and-Guidance/
Hyperlink Table

Embedded Hyperlink Complete URL
42 CFR section 410.33(i)) http://www.gpo.gov/fdsys/pkg/CFR-2010-title42-
Form CMS-855B http://www.cms.gov/Medicare/CMS-Forms/CMSForms/downloads/cms855b.pdf


“Medicare Program Integrity Manual,” Chapter 3,

Saturday, September 22, 2018

Bias written article on surgery center integrity only paints the bad side of the ASC industry in California. Where is the good?

This article in Friday's LA Times paper, written by CHRISTINA JEWETT, only expresses the side of the wrongdoing of a few surgery centers in California.  Where is the article of all the good and "right" management of a surgery center?

Read the article yourself and get a feeling that I have in that it was not written for the better of the integrity of the ASC industry.  But the affiliation with Kaiser health care system, that speaks the truth in a whole different world as we know Kaiser has been anti-asC industry development for years.  their influence is still prominent today and will be for a long time, no doubt.  

read the article here.

Tuesday, July 31, 2018

Bylaws language for your temporary privileges needs an ASC may have.

Here is the language for the bylaws you need in order to meet the Joint Commission demands of accreditation standards.  It is:

Temporary privileges may be granted by the ASC CEO or designee on the recommendation of the medical staff president or designee in the following circumstances.

Patient Care Need: In the case of a circumstance in which privileges are required to fulfill a patient care need, temporary privileges may be granted upon written request of the practitioner. Such privileges are limited to 10 days. Prior to granting of such privileges, documentation of the patient care need will be obtained, as will verification of current licensure, current competency, and National Practitioner Data Bank (NPDB) information.

New Applicants: Upon receipt of a complete application (as described in section _______) for medical staff appointment, including a request for specific temporary privileges, an applicant may be granted temporary privileges for a period not to exceed 120 days while awaiting approval of the application. In order to be eligible for temporary privileges, there must be no evidence of a current or previously successful challenge to licensure or registration; involuntary termination of medical staff membership at another organization; or involuntary limitation, reduction, denial, or loss of clinical privileges. Prior to granting temporary privileges, verification of the following must be obtained:
§ Current licensure
§ Relevant training or experience
§ Current competence
§ Ability to perform the privileges requested
§ Query and evaluation of the NPDB information

Friday, June 15, 2018

For the first time since 1999, the CDC makes new recommendations for the prevention of surgical related infections...

CDC used thousands of studies to the relevant situation such as prevention in SSI surgical site infections, they narrowed it down to a mere 170 studies in order to issue these final recommendations, the first of any recommendations since 1999.  Remeber that the CDC states that most of the recommendations that were made back in 1999, these recommendations were made based on expert opinion rather than evidenced-based recommendations.

So these new recommendations are evidenced-based recommendations and should be taken very seriously.  These recommendations are:

-Patients should shower or bathe (full body) with soap (antimicrobial or nonantimicrobial) or an antiseptic agent on at least the night before surgery.

-Antimicrobial prophylaxis should be administered only when indicated and timed such that a bactericidal concentration of the agents is established in the serum and tissues when the incision is made.

-Skin prep in the OR should be done with an alcohol-based agent unless contraindicated.

-Clean and clean-contaminated procedures, additional prophylactic antimicrobial agent doses should not be administered after the surgical incision is closed in the OR, even when a drain is being used.

-Topical antimicrobial agents should not be applied to the surgical incision.

-During surgery, glycemic control should be implemented using blood glucose target levels less than 200 mg/dL.

-Normothermia should be maintained in all patients.

-For patients with normal pulmonary function undergoing general anesthesia with endotracheal intubation, an increased fraction of inspired oxygen should be administered during surgery and immediately after extubation in post-op.

-Blood transfusions should not be withheld from surgical patients as a means to prevent SSIs.

Which ones of these will you be making your surgery center compliant too?  For the better quality outcomes for all surgical patients, these techniques should be adopted immediately and invited across the continuum of care of the entire US region of the world. 

Tuesday, June 12, 2018

You won't believe how much registered nurses are making today?

Registered nurses in California and Hawaii earn the highest average annual wage for RNs in the U.S. at $102,700 and $96,990, respectively, according to the Bureau of Labor Statistics. After California and Hawaii are the District of Columbia, Massachusetts, and Oregon.

Here is the average hourly and annual wage for registered nurses in all 50 states, plus the District of Columbia, based on the most recent BLS data gathered in May 2017, listed in alphabetical order.

Hourly: $27.83
Annual Wage: $57,890

Hourly: $42.07
Annual Wage: $87,510

Hourly: $36.11
Annual Wage: $75,110

Hourly: $28.28
Annual Wage: $58,810

Hourly: $49.37
Annual Wage: $102,700

Hourly: $34.89
Annual Wage: $72,570

Hourly: $38.56
Annual Wage: $80,200

Hourly: $35.18
Annual Wage: $73,180

District of Columbia
Hourly: $43.32
Annual Wage: $90,110

Hourly: $31.20
Annual Wage: $64,890

Hourly: $32.09
Annual Wage: $66,750

Hourly: $46.63
Annual Wage: $96,990

Hourly: $31.02
Annual Wage: $64,520

Hourly: $34.66
Annual Wage: $72,090

Hourly: $30.02
Annual Wage: $62,450

Hourly: $27.85
Annual Wage: $57,930

Hourly: $28.82
Annual Wage: $59,940

Hourly: $29.58
Annual Wage: $61,530

Hourly: $30.56
Annual Wage: $63,560

Hourly: $31.68
Annual Wage: $65,890

Hourly: $36.18
Annual Wage: $75,250

Hourly: $42.95
Annual Wage: $89,330

Hourly: $33.23
Annual Wage: $69,120

Hourly: $37.28
Annual Wage: $77,540

Hourly: $27.74
Annual Wage: $57,700

Hourly: $30.43
Annual Wage: $63,300

Hourly: $31.87
Annual Wage: $66,280

Hourly: $29.91
Annual Wage: $62,210

Hourly: $40.86
Annual Wage: $84,980

New Hampshire
Hourly: $33.67
Annual Wage: $70,040

New Jersey
Hourly: $39.43
Annual Wage: $82,010

New Mexico
Hourly: $33.58
Annual Wage: $69,840

New York
Hourly: $40.12
Annual Wage: $83,450

North Carolina
Hourly: $30.08
Annual Wage: $62,560

North Dakota
Hourly: $30.35
Annual Wage: $63,140

Hourly: $31.49
Annual Wage: $65,500

Hourly: $29.63
Annual Wage: $61,640

Hourly: $42.68
Annual Wage: $88,770

Hourly: $33.57
Annual Wage: $69,820

Rhode Island
Hourly: $36.85
Annual Wage: $76,650

South Carolina
Hourly: $30.59
Annual Wage: $63,630

South Dakota
Hourly: $27.41
Annual Wage: $57,010

Hourly: $28.87
Annual Wage: $60,050

Hourly: $34.65
Annual Wage: $72,070

Hourly: $30.31
Annual Wage: $63,050

Hourly: $33.44
Annual Wage: $69,560

Hourly: $32.69
Annual Wage: $67,990

West Virginia
Hourly: $29.03
Annual Wage: $60,380

Hourly: $38.37
Annual Wage: $79,810

Hourly: $33.27
Annual Wage: $69,200

Hourly: $31.20
Annual Wage: $64,900

Thursday, May 24, 2018

Google (YOUTUBE) deactivated our YouTube Account. No reason why, no response from letters sent. u2?

That's right, not that our account on YOUTUBE was that big of an account or because of the amount of traffic that surfed there to our youtube page daily, but it was our account and we had put a lot of work into the videos that we had developed.

The way it was handled was the worst part.  No notice, no suspension then allowing us to correct something we had done wrong or even given the opportunity to ask questions about why they felt it had gone against youtube's code of content.

Just woke up, said there were a complaint and bam! Account closed.

I have written letters asking for an explanation, nothing.  nothing.

That's cold.  Real Cold, but then again, it is Google and Google has their own set of rules we have to live by or we may not wake up at all one morning.  LOL. 

If you have had a similar experience, share yours here in the comments and let's see if we can get our account redeemed.  Thanks to all you and your support. 

Friday, April 20, 2018

Have a Surgery Center, but don't know the abbreviated words language we talk? Compliance Doctor defines them here.

(a) “Adjusted Conversion Factor” is determined as follows: unadjusted conversion factor x {1-labor-related share + (labor-related share x wage index)}. For each update, the unadjusted conversion factor for the preceding period is adjusted by the rate of change in the market basket inflation factor. The market basket inflation factor and labor-related share are specified in the Federal Register notice announcing revisions in the Medicare payment rates. See Section 9789.39(b) for the unadjusted conversion factor, market basket inflation factor, and labor-related share by date of service.
For services rendered on or after February 15, 2006, in accordance with Section 411 of Pub. L. 108-173 and the final rule published in the Federal Register of November 10, 2005 (CMS-1501-FC, 70 FR 68516) at page 68556, the “Adjusted Conversion Factor” for a rural Sole Community Hospital (SCH) includes an adjustment factor of 1.071, which document is incorporated by reference and will be made available upon request to the Administrative Director.

(b) “Ambulatory Payment Classifications (APC)” means the Centers for Medicare & Medicaid Services' (CMS) list of ambulatory payment classifications of hospital outpatient services.

(c) “Ambulatory Surgical Center (ASC)” means any surgical clinic as defined in the California Health and Safety Code Section 1204, subdivision (b)(1), any ambulatory surgical center that is certified to participate in the Medicare program under Title XVIII (42 U.S.C. SEC. 1395 et seq.) of the federal Social Security Act, or any surgical clinic accredited by an accrediting agency as approved by the Licensing Division of the Medical Board of California pursuant to Health and Safety Code Sections 1248.15 and 1248.4 to use anesthesia, except local anesthesia or peripheral nerve blocks, or both, in compliance with the community standard of practice, in doses that, when administered have the probability of placing a patient at risk for loss of the patient's life-preserving protective reflexes.

(d) “Ambulatory Surgical Center Payment System” means Medicare's payment system for specific ambulatory surgical center covered surgical procedures published in the Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems final rule for the relevant payment year.

(e) “Annual Utilization Report of Specialty Clinics” means the Annual Utilization Report of Clinics that is filed by February 15 of each year with the Office of Statewide Health Planning and Development by the ASCs as required by Section 127285 and Section 1216 of the Health and Safety Code.

(f) “APC Payment Rate” means CMS' hospital outpatient prospective payment system rate. The APC payment rate is specified in the Federal Register notices announcing revisions in the Medicare payment rates. See Section 9789.39(b) for the Federal Register reference to the APC payment rate by date of service.

(g) “APC Relative Weight” means CMS' APC relative weight as set forth in CMS' hospital outpatient prospective payment system. The APC relative weight is specified in the Federal Register notices announcing revisions in the Medicare payment rates. See Section 9789.39(b) for the Federal Register reference to the APC relative weight by date of service.

(h) “CMS” means the Centers for Medicare & Medicaid Services of the United States Department of Health and Human Services.

(i) “Cost to Charge Ratio for ASC” means the ratio of the facility's total operating costs to total gross charges during the preceding calendar year.

(j) “Cost to Charge Ratio for Hospital Outpatient Department” means the hospital cost-to-charge used by the Medicare fiscal intermediary to determine high-cost outlier payments.

(k) “Facility Only Services” means services, defined by Medicare, that rarely or are never performed in the non-facility setting, and are not: 1. emergency room visits; 2. Surgical procedures; or 3. An integral part of the emergency room visit or surgical procedure, in accordance with section 9789.32. See section 9789.39(b) for the CMS Physician Fee Schedule Relative Value File which contains the description of the Facility Only Services by date of service.

(l) “HCPCS” means CMS' Healthcare Common Procedure Coding System, which describes products, supplies, procedures and health professional services and includes, the American Medical Associations (AMA's) Physician “Current Procedural Terminology”, Fourth Edition (CPT-4) codes, alphanumeric codes, and related modifiers.

(m) “HCPCS Level I Codes” are the AMA's CPT-4 codes and modifiers for professional services and procedures.

(n) “HCPCS Level II Codes” are national alphanumeric codes and modifiers maintained by CMS for health care products and supplies, as well as some codes for professional services not included in the AMA's CPT-4.

(o) “Health facility” means any facility as defined in Section 1250 of the Health and Safety Code.

(p) “Hospital Outpatient Department” means any hospital outpatient department of a health facility as defined in the California Health and Safety Code Section 1250 and any hospital outpatient department that is certified to participate in the Medicare program under Title XVIII (42 U.S.C. SEC. 1395 et seq.) of the federal Social Security Act

(q) “Hospital Outpatient Department Services” means services furnished by any health facility as defined in the California Health and Safety Code Section 1250 and any hospital that is certified to participate in the Medicare program under Title XVIII (42 U.S.C. SEC. 1395 et seq.) of the federal Social Security Act to a patient who has not been admitted as an inpatient but who is registered as an outpatient in the records of the hospital.

(r) “Hospital Outpatient Prospective Payment System (HOPPS)” means Medicare's payment system for outpatient services at hospitals. These outpatient services are classified according to a list of ambulatory payment classifications (APCs).

(s) “Labor-related Share” means the portion of the payment rate that is attributable to labor and labor-related cost determined by CMS, pursuant to Section 1833(t)(2)
(D) of the Social Security Act and as specified in the Federal Register notices announcing revisions in the Medicare payment rates. See Section 9789.39(b) for the Federal Register reference that references the labor-related share by date of service.

(t) “Market Basket Inflation Factor” means the market basket percentage change determined by CMS as set forth in the Federal Register notices announcing revisions in the Medicare payment rates. See Section 9789.39(b) for the Federal Register reference to the market basket inflation factor by date of service.

(u) “Other Services” means Hospital Outpatient Department Services rendered on or after September 1, 2014, but before December 15, 2016, to hospital outpatients and payable under the CMS hospital outpatient prospective payment system that are not: 1. Surgical procedures; 2. Emergency room visits; 3. Facility Only Services; or 4. An integral part of the surgical procedure, emergency room visit or Facility Only Service.
For services rendered on or after December 15, 2016, “Other Services” means Hospital Outpatient Department Services rendered to hospital outpatients and payable under the CMS hospital outpatient prospective payment system that are not: 1. Surgical procedures; 2. Emergency room visits; or 3. An integral part of the surgical procedure or emergency room visit.

(v) “Outlier Threshold” means the Medicare outlier threshold used in determining high-cost outlier payments.

(w) “Price adjustment” means any and all price reductions, offsets, discounts, rebates, adjustments, and or refunds which accrue to or are factored into the final net cost to the hospital outpatient department or ambulatory surgical center.

(x) “OMFS RBRVS” means the Official Medical Fee Schedule for physician and non-physician practitioner services in accordance with sections 9789.12 through 9789.19.

(y) “Total Gross Charges” means the facility's total usual and customary charges to patients and third-party payers before reductions for contractual allowances, bad debts, courtesy allowances and charity care.

(z) “Total Operating Costs” means the direct cost incurred in providing care to patients. Included in operating cost are: salaries and wages, rent or mortgage, employee benefits, supplies, equipment purchase and maintenance, professional fees, advertising, overhead, etc. It does not include start-up costs.

(aa) “Wage Index” means CMS' wage index for urban, rural and hospitals that are reclassified as described in CMS' Hospital Outpatient Prospective Payment System (HOPPS) and wage index values as specified in the Hospital Inpatient Prospective Payment Systems set forth in the Federal Register notices announcing revisions in the Medicare payment rates. See Section 9789.39(b) for the Federal Register reference that contains the description of the wage index and wage index values by date of service.
(ab) For services payable under Sections 9789.30 through 9789.39, “Workers' Compensation Multiplier” means the multiplier to the Medicare rate adopted by the AD in accordance with Labor Code Section 5307.1, or the multiplier that includes an extra percentage reimbursement for high-cost outlier cases, by date of service.
Image 1 within § 9789.30. Hospital Outpatient Departments and Ambulatory Surgical Centers - Definitions.

Thursday, February 8, 2018

DME Owners in Florida, Are you compliant to the Emergency Management Plan?




Developed by __________________________________________________________
(Name of Licensed Home Medical Equipment Provider, license #)

In compliance with sections 400.934(20)-(22) and 400.935(11), Florida Statutes;
and 59A-25.006, Florida Administrative Code

Basic Home Medical Equipment (HME) Provider Information

Street Address:
City, Zip Code:
Phone Number: Fax Number:
Emergency Service Phone Number (outside normal business hours):
General Manager’s Name:
Geographic Service Area:
ο All counties in Florida are served by this provider
ο Only the following counties are served 

Person in Charge during Emergency

Home Address:
Phone Numbers - Home: Work:
Pager: Cell:

Alternate - If the above person is not available during emergency/evacuation, who would be in charge?

Home Address:
Phone Numbers - Home: Work:
Pager: Cell:
Insert additional names as appropriate

HME Owner (   check if same as ‘Person in Charge during Emergency’ listed above)

Home Address:
Phone Numbers - Home: Work:
Pager: Cell:
Insert additional owners as appropriate
Table of Contents

A.  Summary of Types of Equipment and Services Provided _____
B.  Life-Supporting or Life-Sustaining Equipment _____
C.  Other Equipment and Equipment Services _____
D.  Equipment and Equipment Services to Be Provided in Emergencies  _____

A.  Personnel Responsibilities in Emergency Situations _____
B.  Planning and Information for Consumers before an Emergency _____
C.  Notification of a Possible Emergency _____
D.  During an Emergency _____
E.  Evacuation _____
F.  After the Emergency and/or upon Re-entry to Affected Area _____


A.  Agreements and Understandings _____
B.  Information for HME Consumers _____
C.  Support Materials _____

Instructions:  This form is designed so that the requested information may be typed directly below each topic heading, allowing as much space as necessary to capture the needed details.  This will also permit the plan to be easily transmitted by e-mail to the local reviewer (see below).

Section 381.0303(7), F.S., states, “The submission of emergency management plans to county health departments by … home medical equipment providers is conditional upon receipt of an appropriation by the department to establish disaster coordinator positions in county health departments unless the secretary of the department and a local county commission jointly determine to require that such plans be submitted based on a determination that there is a special need to protect public health in the local area during an emergency.”  It is the home medical equipment provider’s responsibility to contact the county health department of each of the counties listed on the provider’s license to determine and document whether the Comprehensive Emergency Management Plan (CEMP) should be submitted to that county and, if submission is required, whether the county health department will be reviewing the plan for compliance with Florida Statutes and rules.  If the plan is to be submitted, e-mail with ‘read receipt requested’ or certified mail with return-receipt requested is recommended in order to document proof of submission.

A CEMP must be prepared by every licensed home medical equipment provider regardless of whether it will be reviewed by the local county health department.

The CEMP must be updated on an annual basis or as needed per s. 400.934(20)(a), F.S., and 59A-25.006(2).

A. Summary of Types of Equipment and Services Provided

In the chart below, check () each type of equipment that the HME sells and/or rents and then check the HME services provided for each type checked.


Equipment selection
Setup and installation
Patient training
Ongoing service and maintenance

Respiratory modalities

Ambulation aids

Mobility aids

Sickroom setup

Disposable supplies

(list below)

*Equipment types might include:
Respiratory modalities - airway pressure machines, apnea monitors, oxygen & ventilator equipment
Ambulation aids - walkers, canes, crutches
Mobility aids - motorized scooters, wheelchairs, passive motion devices, electrostimulation equipment
Sickroom setup – hospital beds, lifts, suction machines, enteral feeding pumps, dialysis equipment
Disposable supplies – diabetic, ostomy, urological and wound care

B. Life-Supporting or Life-Sustaining Equipment

As defined in Florida Statute (law) 400.925(13), “’Life-supporting or life-sustaining equipment’ means a device that is essential to, or that yields information that is essential to, the restoration or continuation of a bodily function important to the continuation of human life. Life-supporting or life-sustaining equipment includes apnea monitors, enteral feeding pumps, infusion pumps, portable home dialysis equipment, and ventilator equipment and supplies for all related equipment, including oxygen equipment and related respiratory equipment.”

Does the HME sell and/or rent such equipment? YES       NO  

If yes, please note s. 400.934(20)(a), F.S., requires HME provider’s CEMP “shall provide for continuing home medical equipment services for life-supporting or life-sustaining equipment, as defined in s. 400.925, during an emergency that interrupts home medical equipment services in a patient’s home.”  The continuation of these services should be included in each section of the plan as outlined below.

C. Other Equipment and Equipment Services
The types of equipment, services and consumers of each HME provider will determine the detail required in that provider’s CEMP; thus, some of the sections in the CEMP may not apply to all providers and may be marked ‘N/A’.  Please check the correct response for this HME provider under each item below:

1. HME services to consumers:
a. HME provider services equipment or delivers supplies to consumers
YES       NO  

b. HME provider does not service equipment or deliver supplies to consumers
YES       NO  

If an HME provider does not service equipment or deliver supplies to a consumer, then the provider would not be expected to offer continuing services to that consumer during an emergency.

2. HME provider only sells/rents and services equipment for consumers in a licensed health care facility YES       NO  

If an HME provider only sells to and services equipment in a licensed health care facility such as a skilled nursing facility or assisted living facility, then the HME provider would not be responsible for continuing services to the individual patients during an emergency situation; however, the HME provider would be responsible for maintaining equipment and equipment services as was being done prior to the emergency.

3. HME provider only sells/rents and services equipment to consumers for use by home health agency or hospice with patient YES       NO  

Maintenance of the equipment would be expected and provision of related supplies as was being done prior to the emergency would be expected.

4. Other unique equipment/services situation:  (Describe)

D. List and describe the equipment and equipment services that the HME would provide should there be a natural disaster or other emergency situation in the area the provider is licensed to serve:  (List and describe)

(Insert any appropriate introductory or overview remarks.)

A. Personnel Responsibilities in Emergency Situations

1. Provide a chain of command to ensure continued leadership and authority.

2. Describe how the HME provider will timely activate the CEMP and staffing of the HME during an emergency.  (This would include a listing of the potential hazards that the provider is vulnerable to such as hurricanes, tornados, flooding, fires, hazardous materials, transportation accidents, proximity to a nuclear power plant, power outages during severe weather, etc.  The provider should have a pre-determined time of activation such as wind speed, flood water level, the proximity of wildfire, etc. as well as a plan when no warning is given.)

3. Identify the personnel that will manage equipment services for consumers who will continue to receive services in their residence or at the special needs shelter by the HME’s staff or contractors during an emergency.

B. Planning and Information for Consumers before an Emergency - describe how the HME provider will:

1. Assist local emergency management agencies with special needs registration
a. Inform special needs clients about registration and provide information

b. Collect registration information from special needs clients for the special needs registry, in accordance with the established procedures of the local emergency management agency

NOTE:  This must be done prior to an emergency and not when an emergency is approaching or occurring. If the consumer is already receiving services from a home health agency, a hospice, the Agency for Persons with Disabilities, Medicaid Waiver, Community Care for the Elderly, Older Americans Act or other state and federal funded programs, check to determine whether the other provider has offered assistance to the client with special needs registration. Home medical equipment providers are not required to assist patients residing in skilled nursing facilities assisted living facilities or adult family care homes with special needs registration as those licensed facilities are responsible for evacuation and alternative sheltering of their patients. If the local emergency management agency does not permit providers to collect the registration information, please note that here.

2. If the consumer is registered for the special needs registry by the HME provider:
a. Describe who will provide the information to the consumer and caregiver, e.g. family members, friends, etc., regarding the guidelines provided in Appendix B when there is mandatory evacuation underway due to the emergency

b. Establish and update an equipment and supply list, in accordance with Appendix B, in the consumer’s place of residence that can accompany them if they are relocated

3. For those consumers that receive HME services that are not registered with the special needs registry, find out if the consumer will need continued services in their residence prior to, during and immediately following an emergency.

C. Notification of a Possible Emergency – describe how the HME provider will:

1. Receive warnings and alert staff in charge of the CEMP implementation of impending emergency situations including during off hours, weekends and holidays

2. Alert staff and contractors of impending emergency situations including during off hours, weekends and holidays

3. Provide information to provider personnel regarding reporting to work when the HME remains operational

4. Provide alternate means of notification should the primary system fail (may include cell phones, satellite phones, contact with a community-based ham radio group, public announcements through radio or television stations, face-to-face contact and, in medical emergency situations, contact with police or emergency rescue services)

5. Alert consumers of the precautionary measures that will be taken including, delivering additional oxygen or supplies to those that are in areas not likely to be evacuating, and confirm plans of those that will be relocating with family members and friends

6. Maintain a prioritized list of consumers who need continued services during an emergency, including those who relocate to special needs shelters, which complies with the requirements of s. 400.934(21), F.S., and the procedures for furnishing this list to the county health department and local emergency management agency when requested  (the list shall indicate the means by which services shall be continued for each consumer, whether the consumer is to be transported to a special needs shelter and whether the consumer has life-supporting or life-sustaining equipment, including the specific type of equipment and related supplies)
D. During an Emergency – describe how the HME provider will:

1. Provide every reasonable attempt to assure that all consumers (including those residing in a skilled nursing facility, assisted living facility or adult family care home) needing continuing equipment/service for life-sustaining or life-supporting equipment will receive it, either from the HME or through arrangements made by the consumer, the consumer’s family or caregiver, when there is not a mandatory evacuation and the consumer decides to stay in their residence

2. Provide equipment and related supplies necessary to perform the same type and quantity of services to its consumers who evacuate to special needs shelters, which were being provided prior to evacuation per s. 400.934(20)(a)1, F.S.

3. Establish links to the local emergency operations center to determine a mechanism by which to approach specific areas within a disaster area in order to reach its consumers per s. 400.934(22), F.S.

E. Evacuation – describe how the HME provider will:

1. Provide updated equipment and supply list, in accordance with Appendix B, to be kept in consumer’s residence for consumers that will be transported from their homes if evacuation is ordered

2. Deliver essential equipment, services and/or referrals to other organizations subject to written agreement including how the HME will continue to provide services to consumers who relocate within or outside the geographic service area  (If consumers residing in a skilled nursing facility, assisted living facility or adult family care home relocate to another skilled nursing facility, assisted living facility or adult family care home in the geographic area served by the home medical equipment provider, the provider will continue to provide equipment services to those consumers. If those consumers are relocated outside the area served by the home medical equipment provider, the provider will assist the skilled nursing facility, assisted living facility or adult family care home in obtaining the equipment services of another home medical equipment provider already licensed for that area until the consumer returns to their original location.)

F. After the Emergency and/or upon Re-entry to Affected Area – describe how the HME provider will:

1. Re-establish contact with and services to consumers, as prioritized, after their return to their residence

2. Re-establish contact with contractors in order to resume services

3. Prioritize services should the emergency result in fewer provider personnel or contractors being available immediately following the disaster

(Insert any appropriate introductory or overview remarks.)

In each of the sections below, describe how the HME will:

A. Inform administrative staff, provider personnel and contractors prior to an emergency of their roles and responsibilities during times of emergency (This could be accomplished during new employee orientation and should include the expectation of each key employee’s personal emergency preparation plan that would allow the employee to remain at work.)

B. Train provider personnel on emergency preparedness procedures (This should include the training content, such as a definition of what constitutes an emergency, when the CEMP will go into effect, the roles and responsibilities of essential and non-essential staff, etc.)

C. Train new employees and contractors regarding their disaster-related responsibilities

D. Train assigned staff on what is a special needs client and special needs registration procedures in the county(ies) they are assigned to cover, including Appendix B

E. Identify when the CEMP will be reviewed with staff and on an annual basis


The appendices that follow are provided in support of the HME’s CEMP:


(List any mutual agreements between the HME and any local, state or county entities or any other health care or service providers having responsibility during a disaster and attach a copy of each.  This is to include agreements needed to ensure the operational integrity of the CEMP.  These agreements should be updated annually along with the plan.)


(Insert copy of information provided to educate consumers about the procedures that may be necessary for safety during disasters.  The information listed on ATTACHMENT 1, SPECIAL NEEDS SHELTERS, should be included for consumers on the special needs registry in preparation for a possible evacuation to a special needs shelter.)


(List any materials necessary to support this CEMP and attach a copy of each.)


Please note:  The special needs shelter should be used as a place of last refuge.  The evacuee may not receive the same level of care received in the home and the conditions in a shelter may be stressful.

(1)  It is the expectation of the special needs shelter that a caregiver accompany and remain with the consumer throughout the stay.

(2)  The following is a suggested list of what consumers need to bring to the special needs shelter during an evacuation; the consumer should check with the assigned shelter to confirm the necessary items and/or those items which may not be accommodated:

Identification and current address
A copy of the consumer’s plan of care, if applicable
Medication listing including directions for the dose, frequency, route, time of day and any special considerations for administration; equipment and supplies list including the phone, beeper and emergency numbers for the consumer’s physician, pharmacy and, if applicable, oxygen supplier; necessary medical equipment and supplies; Do Not Resuscitate Order (DNRO), if applicable
Bed sheets, blankets, pillow, folding lawn chair, air mattress
Prescription and non-prescription medications needed for at least 5 to 7 days; oxygen for 5 to 7 days, if needed and shelter space allows
Special diet items, non-perishable food for 5 to 7 days and 1 gallon of water per person per day 
Glasses, hearing aids and batteries, prosthetics and any other assistive devices
Personal hygiene items for 5 to 7 days (including adult diapers, colostomy supplies, etc.)
Extra clothing for 5 to 7 days
Flashlight and batteries
Self-entertainment and recreation items such as books, magazines, quiet games
Labeled shoe box or other small closed container to hold the majority of the smaller items listed above to facilitate storage and ease of use

(3)  All persons using the special needs shelters need to know the following:

Space allotted for the consumer includes space for the caregiver.  A special needs shelter can accommodate only one caregiver at a time; any other family members, friends, etc. should go to a regular shelter.
The caregiver must provide his or her own bedding.
Caregivers who regularly assist the consumer in the home are expected to continue to provide the same care in the shelter.
Service dogs are allowed in the shelter.  Check with the local Emergency Management office to see if other pets are permitted.
Bring food items as listed above.  It is possible only sparse meals will be provided.
Smoking is not allowed in the shelter.

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