ASC Management
We Handle the Inspection Process
Our new ASC had to pass four inspections to open. Just one failure would have set us back months.

By Larry Patterson, M.D., and Ray Mays

Our nurse administrator came on board with us on Jan. 1 of last year. We wanted to be seeing patients in our new ASC by April 15, which we were able to accomplish, and to be operating in our ASC by June 1, 2002.

Our plan -- and budget -- called for us to begin receiving reimbursement for ASC procedures in July, so we were understandably highly motivated to expedite the licensing and certification process. This month, I'll explain how we handled that process.

Coordination Is Key

The first 5 months of 2002 was a very hectic and stressful time, especially for the nurse administrator. We were dealing with four separate agencies, and attempting to coordinate the necessary inspections was challenging.

The state engineering department must determine that the ASC is built and equipped in accordance with state hospital codes. The state fire department must determine that the life safety and fire codes are met. The state department of health ensures that operationally the ASC is ready to perform procedures. And finally, the Medicare inspector has to certify that the facility is in compliance with Medicare regulations and assign an "official" number in order for us to begin billing Medicare.

As simple and clear cut as this sounds, the frustration is that each inspector must be scheduled individually and they all have facilities all over the state that they need to inspect. The order and timing of the inspections also must be coordinated. The fire marshal won't inspect until the engineer has conducted his inspection, and so on. We discovered that each of the inspectors required a 30- to 60-day lead time to ensure a date.

Any Failure Spells Trouble

Your ASC consultant will save you time and money during this period. The key to getting your ASC up and running on time is that you simply must pass each inspection -- a failure notice from any of the inspectors will result in the cancellation of the next inspector's visit, and on down the line. Our nurse administrator and our ASC consultant contacted each of the agencies and got the name and number of the assigned inspector, and then remained in contact with them throughout this period.

We were pleasantly surprised to find that all of the inspectors had the attitude that they were there to help us get up and running. They ended up being valuable resources for us. The Medicare inspector was especially helpful in aiding us in writing our by-laws and operational manual.

The actual inspections are straightforward. The contractor and architect need to be on hand for the engineer's inspection; the contractor, administrator and the nurse administrator must be available for the fire inspection; the nurse administrator will take care of the state health department inspection, and the administrator, nurse administrator, and the doctor(s) need to be available for the Medicare inspection. In our state, we had to perform three procedures between the state inspection and the Medicare inspection. The Medicare inspector reviews the charts, op notes and all records for those cases to determine if the operational procedures outlined in the manuals (that you wrote) were followed.

These inspections are emotionally draining. Your people need to be prepared to answer tough questions from the inspectors. Although the ASC consultant will assist in preparing you for the state and Medicare inspections, and someone else will most likely flesh out the manuals -- the doctors, nurse administrator and the ASC administrator must be familiar with the entire operation. A huge investment is at stake.

Next, I'll discuss the legal structure and governance of the ASC.

Larry Patterson, M.D., is practice owner, and Ray Mays is practice administrator of Eye Centers of Tennessee, a general ophthalmology practice serving 300,000 residents of middle and east Tennessee. You can reach Ray Mays at raym@ecotn.com.