Recently, our associate Lani Antonio, CPC, gave a very well-received presentation at the September 13, 2012, WASCA Billing & Coding Compliance and Auditing seminar. Washington State’s Ambulatory Surgery Centers, like many care providers, face increased scrutiny from HHS / CMS and their auditors about billing and coding compliance. In addition to being a Certified Professional Coder, Lani is also an AHIMA-Approved ICD-10-CM/PCS Trainer who helps Derry, Nolan medical practice and ASC clients address issues before they can negatively affect review and audit outcomes. In the presentation, she covers:
- HHS Strategic Plan FY 2010-2015
- Entities performing Part B Claim Reviews
- Strategies for Prevention
With the NYSE resembling a roller coaster ride, 2011 was another tumultuous year for the global economy. It put us much in mind of Derry, Nolan’s own beginnings in 2003. The economy was less than ideal and President Bush had declared war on Iraq. Despite those challenges, we remained focused on our goal to help medical practices.
In the first six years of business, we did a lot of medical practice assessments. We were busy helping physician practices eliminate wasteful processes, streamline staff and improve their bottom line through clean-claim submissions–on the first attempt! Many times we recommended consolidation of resources, right-sized the staff to productivity and restructured practice billing departments.
Over the past couple of years, however, we’ve witnessed a disconcerting trend of physician specialty groups running for cover and entering into employment agreements with hospital systems. We’ve also seen several hospital systems merge—the recent purchase of Swedish Medical Center by Providence, for example. Is the entrepreneurial, independent physician spirit being squashed by such threats as 27% Medicare cuts? (Particularly in light of thirty-three million baby-boomers readying to apply for Medicare benefits!)
Never before has it been more important for physician practices and hospital systems to work as efficiently as possible. If recent trends lead to that, it will be a good thing.
We wonder, though, if hospital leadership can keep promises made, as their institutions face continued dwindling reimbursement. We well remember how in the mid-90s, the trend of HMOs and hospitals purchasing primary care practices resulted in an average loss of $90,000 per physician. Then, many physicians went back into private practice; whether this will happen with specialty services remains to be seen. One thing is certain, whatever form healthcare reform takes, all healthcare providers will need to meet the challenge to deliver quality-driven services, because their reimbursement will be based on outcome measurements.
As for Derry, Nolan, for the past eight years, our initial business goals have not wavered. We hope that medical practices choosing to remain independent will continue to assess how they perform daily work to ensure it is meaningful and value-added.
We end 2011 with fondest wishes to you and your families for a wonderful holiday season. We hope that 2012 will be a better year economically for all of us and that you achieve any New Year’s resolutions you set for yourselves!
Barbara and Crystal
P.S. As you plan 2012 business activities, check to see the last time you had a practice assessment. We’re scheduling operational “check ups” for our physician clients now!
The WASCA conference presentation was one that Derry, Nolan & Associates has been looking forward to for some time. We knew the material needed to be highly relevant to current compliance issues facing Washington State ASCs. Cathy Strauss, our ASC Specialist (and presenter!), has implemented ASC Infection Control Programs and felt strongly that the topic would be near and dear to many WASCA Conference participants.
As you continue to move forward to align your ASC with the 2009 updated CMS Guidelines, consider the experience and resources needed to properly implement the various ASC programs. Compliance makes everyone's life easier - and it certainly helps create a healthy, supportive ASC environment for patients, staff and physicians.
We hope those of you who missed the WASCA Conference, as well as those who attended, will download Cathy's WASCA presentation from our Media page. There are also helpful ASC handouts included on the page that may be useful as you begin to revamp your ASC's Infection Prevention and Control program.
Contact Derry, Nolan & Associates for assistance developing and implementing any of your ASC’s programs.
As the summer draws to a close, it seems as though everyone is already thinking about the holiday season, pushing forward to next year. Hold up – we’re not yet done with this one! There’s plenty still coming down the pike for 2011. Let’s look at your goals – what is there yet to achieve for yourself (and your healthcare organization)? And how are your professional relationships? Have you been able to build and strengthen those?
There are a couple of posts that may help as you continue to work on those 2011 goals. For instance, when it comes to professional relationships, we like one from January about connecting, which included these three tips:
- Be nice to everyone. Make the effort and never underestimate the value of being nice!
- Listen to every voice. When we build teams and redesign workflows, our belief is that every voice matters.
- Bring your ‘A’ game to work – every day.
Now, look at what you planned for this year – not only for your healthcare organization or medical practice, but also for you, personally and professionally. What’s the status? Is it time to revisit those plans and make some course corrections back to where priorities truly lie? Remember these tips from another January post:
Clarify your priorities. It is the first and most essential step to achieving a well-balanced life. Here’s a simple 3-step exercise to use as a tool:
- Write down your Top 5 priorities. Not what you think your priorities should be, but the ones you want!
- Next, analyze where you spend the majority of your time. Does it align with your Top 5?
- Finally, those that don’t align, consider how to eliminate them. After all, if they didn’t make it into the Top 5, perhaps it’s time they go away.
Every choice has a consequence. Each leads us down a particular path. There’s still time to listen to every voice, including your own. If you need some assistance to complete a few “to do” items, give us a call!
Patient Rights. We all have them. But what do they entail? When we walk into an ASC, what notifications should we receive?
Patient Rights is perhaps the most neglected of the CMS Guidelines, unintentionally. These rights state the responsibilities that ASC staff has towards patients and their families during care in their facility. A patient has the Right to Treatment with respect, the Right for an Informed Consent, the Right to have an Advance Medical Directive, the Right for Privacy and Confidentiality. Plus, the ASC must disclose if the physician has a financial interest or ownership in the ASC. All rights must be provided before the date of service. ASCs need to post patient rights in the facility and gain confirmation, by signature, from the patient that all information was given prior to the service-date.
Use these suggestions to help your ASC avoid overlooking and under-documenting the Patient Rights process:
- Implement a simple form that lists the Patient Rights requirements, and obtain the patient’s signature. Some ASCs include the opportunity for the patient to listen to the rights and notifications via a recording, to assure understanding. Post the recording on your website, too, under the Patient Rights section!
- Routinely ask the patient if they understand their rights and answer any questions promptly.
- Contact the Washington State Medical Association for Advance Directive informational brochures.
- Create small packets covering the Notice of Rights, Financial Disclosure and Advance Directive to mail to the patient prior to surgery. Include signature pages and collect them the day of surgery.
- Reiterate “any questions” on the day of surgery, maybe even include one final sign off!
Our Washington State ASCs have a choice. Either do nothing and risk everything ASCs have worked so hard to achieve. Or be proactive; recognize that we have fallen behind and need to get up to speed on regulations ASAP. The do-nothing approach simply isn’t feasible for any ASC committed to patient safety and quality. Frequent DOH visits affect morale and potentially the ASC’s reputation. The pro-active approach means a serious look in the mirror – assessments and very likely, corrective activities and training. But in the long run, your ASC, your staff and your patients win.
Is your ASC Compliant with CMS? Contact Derry, Nolan & Associates; we can get you there.
Those three issues popped to the top for ASCs during the CMS/DOH surveys. Today, let’s look at Infection Control and Quality Assessment & Performance Improvement.
Is your ASC Infection Control program in compliance? Your ASC needs to go beyond having solid Infection Control policies and practices in place, you also need an IC officer – a licensed healthcare professional, such as a RN. An effective IC program will replicate guidelines from a nationally recognized one, such as APIC regarding hand hygiene, injection practices, sterilization guidelines and monitoring of environmental and infection control practices. Ongoing training is key to instilling good hygiene habits. Display hand washing posters, wash hands before and after meeting with a patient and use hospital approved germicide cleaners.
Have a program in place? Review the survey to see how well you’d do!
Quality Assessment and Performance Improvement programs require an ongoing effort of data collection, observation, documentation, reporting trends, findings and outcomes to the Governing Body Meetings – all in an ongoing effort to improve patient care services and the quality of that care. Implementing an ASC QAPI program takes time, and for it to work, vigilance. Begin with a specific topic and work through to the end of the current process, note issues, safety concerns, how often they occur, and how often they are in compliance (or not) with the ASC’s policy. Conduct a policy review meeting with staff to report findings and concerns, as well as train (and re-train). Then conduct regular follow-ups. Document the same process, and hold a Review meeting.
The data tells all! Have issues improved, or not?
Next time, Patient Rights – the often unintentionally neglected process. How does yours measure up?
Is your ASC compliant with CMS? We can get you there!
Catching up or revisiting those updated CMS Guidelines? Great! Now let’s move on to Quality Communication. If you want your team to be the “most likely to succeed” in achieving a successful CMS/DOH survey, you need a firm foundation – which begins with Quality Communication. Only then do you begin to build the high performance team to take you into the future. Plus, communication excellence is critical to unlocking team performance and quality outcomes.
Ask yourself: “Does my ASC leadership team demonstrate these attributes?”
- Thoroughly understands principles and rationale of the CMS guidelines.
- Provides ongoing constructive communication with ASC staff.
- Conducts frequent, relevant staff meetings that discuss the quality improvement (QI) process and successes.
- Holds quarterly meetings that cover QI, infection control, peer review, fire drills, incident reports, sharps injury log, etc.
- Elicits ongoing feedback from the ASC team.
If your ASC Leadership lacks these attributes, expect communication barriers. Communication barriers prevent achievement of quality communication and successful outcomes. Quality Communication begins with the ASC Governing Body, particularly the medical director, administrator, nursing supervisor and physicians, who must take the time to read and thoroughly understand – and here’s where we continue to beat the drum – the updated CMS Guidelines.
It’s a lot to take in, and it often takes assistance to interpret. Don’t hesitate to ask for help – either from DOH, knowledgeable colleagues or ASC consultants who have experience working with the guidelines. After all, your ASC’s success and your patient’s safety and satisfaction rely on it.
Next, we’ll run through the Top 3 – Infection Control, Patient Rights & Quality Assessment and Performance Improvement.
Contact us if you need help getting in compliance with the updated CMS Guidelines. We can set you on your way to a successful survey!
ASCs Then & Now
Those of us who began ASCs under the previous regulations often saw ourselves as standing out from the pack. We broke away from a traditional hospital environment to provide better patient access and quality control over services provided and to use physician time more effectively. We took pride in our facilities and accomplishments. So it’s no wonder we were dismayed by recent survey results, which reflected an apparent lack of understanding of the 2009 guidelines.
Back when most ASCs received their CMS certification, the guidelines were around 44 pages. In 2009, that grew to 167 pages – a 73.6% content increase. And where the old guidelines gave us some leeway in interpretation – not so much in the new ones. They’re specific and detail-oriented. The result? Knowledge gaps that need to be filled – quickly.
Let’s look at where we go from here. To help your ASC address some of the key attributes necessary to achieve a successful DOH Medicare Survey, we’ve put together some key points. The state DOH (conducting surveys on CMS’ behalf) is understandably concerned with results to-date. We’ve taken 3 top areas to focus on (based on those results & DOH feedback ), as it’s apparent ASCs need more education and training in these areas to meet CMS guidelines:
Top 3 Areas for Improvement
- Infection Control
- Patient Rights
- Quality Assessment & Performance Improvements
Before we dive into any of those , we’ll need to close the knowledge gap. So next blog, we’ll start with Quality Communication. As we’ve stated before – it lays the foundation for high performance teams. And those types of teams are the most likely to achieve a successful CMS/DOH survey.
In the meantime, if you’d like to get a head start on closing that knowledge gap, read through the updated CMS Guidelines.
Communication is the key to unlock team performance and quality outcomes.
It seems a simple enough concept. In healthcare, everyone seems to be talking to each other – patients to doctors, nurses, staff and providers to each other. Yet, despite all the talking, actual communicating doesn’t always occur.
Communication gaps create service quality gaps. In turn, those service limitations lead to patient and staff dissatisfaction and frustration. The improvement and standardization of certain communication strategies can eliminate the costly wastes resulting from bad communication: inefficiency, ineffective and potentially unsafe care, rework, unintended outcomes and a diminished capacity for team performance.
Remember, healthcare systems deliver services. So, if you’re going to measure the quality of healthcare, then you have to go beyond clinical measures, incorporating patient’s perceptions and experiences. Taking this into account, we’ll add two dimensions to the usual five for measuring service quality:
- Empathy PLUS
Group approaches to the complex issues in healthcare help build cohesiveness. Working as a team allows for creativity, sharing expertise, developing new skills, increasing personal autonomy and influencing decisions. Bonus benefits: job satisfaction and communication improves, mutual respect grows.
If your healthcare organization can build high performance teams, you will naturally evolve to improved quality and outcomes.
Before we can work on the five key areas with 65 quality indicators of an ACO, we must improve our listening skills and really communicate!
“The single biggest problem in communication is the illusion that it has taken place.” – George Bernard Shaw
ACOs are a type of payment and delivery reform model that begin to tie provider reimbursements to quality metrics (measures of quality indicators) and reductions in the total cost of care (performance and process improvement) for an assigned population of people; i.e. Medicare patients.
These indicators and data derive from 5 Key Areas:
- Patient and providers’ experience of care (patient and staff satisfaction scores)
- Care coordination (information sharing across the continuum of care)
- Patient safety (reporting, analysis and error prevention)
- Preventive health (treatments to minimize illness and hospital admissions)
- At risk population, frail and elderly health (using proven care standards to assist with care provision)
The overall quality performance score will be calculated on 65 quality metrics within the 5 defined key areas, equally weighted. CMS will define the quality performance benchmarks based on Medicare Fee-For-Service (FFS), Medicare Advantage or ACO perfomance data over time.
Note that the ACO is eligible for monetary compensation only if it demonstrates to CMS that it has fulfilled the required quality performance elements and achieves the other regulatory performance criteria.
“Quality is remembered long after the price is forgotten.” —Gucci Family Slogan