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Q&A on CMS conditions for coverage in the ambulatory setting
As state survey agencies for the Centers for Medicare & Medicaid Services (CMS) are using extra federal economic stimulus funds to expand the monitoring of ambulatory surgery centers, Congress News discusses CMS conditions for coverage in the ambulatory setting with Marilyn Hanchett, RN, MA, CPQH, CIC. She is infection control technical lead in the division of acute care services at the CMS. The division of acute care services develops the Interpretive Guidelines for the ASC Conditions for Coverage and has primary enforcement responsibility for ASC compliance with applicable regulations. Today at Congress Hanchett will give a presentation on “Medicare ASC Infection Control Requirements.”
Congress News: With the latest round of stimulus funds (late last year) directed at the states to do ambulatory surgery center (ASC) surveys, they seem to be targeted at ASCs that are non-accredited by The Joint Commission, and other accrediting organizations. Why?
Hanchett: ASCs that participate in Medicare on the basis of a CMS-approved accreditation program are not routinely surveyed by the state agencies, hence the Recovery Act funding provided to the states is for surveys of non-accredited ASCs. Accredited ASCs are surveyed every three years by their respective accrediting organization. However, the division of acute care services requires all four of the CMS-approved ASC accrediting organizations to use the same infection control assessment criteria that are currently being used in the surveys conducted by the States.
Congress News: Regarding quality in ASCs, is there any evidence from the surveys that patients have actually been harmed by poor quality, or the ASC was closed because of quality concern?
Hanchett: Results of the ASC Infection Control Pilot Project and special surveys conducted in Nevada in 2008 indicated that there were a number of lapses in some infection control practices. Well over a majority of 28 ASCs subjected to Federal surveys had substantial areas of noncompliance. However, this was not a representative sample of all 51 Nevada ASCs. Nineteen percent of the pilot state ASCs surveyed had substantial areas of noncompliance. Five ASCs in Nevada were terminated by the Medicare program as a result of these and other lapses. More detailed analysis of the pilot findings by the CDC and CMS will be made public this year. With respect to the Nevada ASCs, the CDC has published findings of the spread of Hepatitis C as a result of lapses in injection safety practices discovered in specific ASCs. It is too early to provide results from the Recovery Act funded surveys currently taking place.
Congress News: Is there evidence that ASCs provide good quality care but that their systems for documentation of surveillance is the biggest organizational change that they need to improve, even though that may require hiring part time or outside help?
Hanchett: See response to the previous question. The problems were not simply those related to documentation of surveillance.
Congress News: Does CMS share data on how many surveys have been done, where they have been done (by state), and aggregated general results of those surveys? How do you suggest nurses working in ASCs get CMS updates and information, as well as engage in dialogue about important CMS initiatives and developments that impact ASCs?
Hanchett: There is a considerable lag time, due to the length of enforcement actions when substantial deficiencies are identified, in the incorporation of survey data into the Survey and Certification data base. For this project we are also collecting infection control worksheet data when it is complete. Nurses working in ASCs may find CMS’ interpretative guidelines for the ASC Conditions for Coverage available at http://www.cms.hhs.gov/manuals/downloads/som107ap_l_ambulatory.pdf
They may also review Survey and Certification memoranda that update one or more of the various types of providers subject to survey. This information is updated weekly on the CMS Web site.
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