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Jan 03
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Selecting the Right Compounding Pharmacy for Your ASC

Selecting the Right Compounding Pharmacy for Your ASC

By ASC Governance, ASC Management 2 Comments

In 2011, a compounding pharmacy repackaged an anti-cancer drug off label into plastic syringes for the treatment of macular degeneration. The pharmacy had no container closure or compatibility studies. Fifteen plus patients sustained injuries, including blindness, due to contamination of the medication during the repackaging process.[1]

In 2012, more than 60 patients died from fungal meningitis when they were given a steroid that was compounded by New England Compounding Center. This medication was prepared and packaged in an environment in which proper sterile techniques were not used.[2]

From 2016 to 2017, Guardian Pharmacy Services compounded an ABO steroid to replace a FDA approved drug that had gone on back order. The medication was compounded with an improperly treated binding agent, causing loss of visual acuity in more than 30 patients.[3]

Unfortunately, surgery centers purchased and administered these preparations to patients under their care. Understanding how these adverse events happened will help you prevent them from occurring at your center. Knowing what regulations were put in place as a result and the best ways to research the compounding pharmacies you order from will aid your center in mitigating risk.

How did these issues happen?

Historically, compounding pharmacies were created for physicians to have specialized preparations made for specific patients. Perhaps they had a patient with an allergy to a binding agent or dye in a medication and needed the medication to be made without those ingredients. Over time, these pharmacies began to batch produce sterile preparations. Unfortunately, this occurred in pharmacies that did not have the proper sterile processes and equipment in place to ensure safety of the medications being compounded. In addition, the FDA had no statutory authority over these facilities. The facilities were not even required to be registered with the FDA. While some of these pharmacies may have been visited by their state board of pharmacy, most of them flew under the radar.

After the New England Compounding Center debacle, Congress acted, creating the Drug Quality and Security Act (DQSA). The act delineated two classes of compounding pharmacies and granted the FDA the authority to regulate these facilities.

503A & 503B Key Differences

Under DQSA, there are two classes of compounding pharmacies – 503A and 503B. A traditional compounding pharmacy (one script for one patient) is a 503A. The 503B, however, is an outsourcing facility intended for batch production.[4] The table below outlines the new regulations under DQSA for both types of pharmacies.

503A Compounding Pharmacy 503B Outsourcing Facility
Regulatory Authority State Boards of Pharmacy

FDA registration & inspection

 FDA registration & inspection

Additional State requirements
Applicable Standards USP <797>

FDA 503A Policy Guide

 FDA cGMP (21CFR 210 & 211)

Additional State requirements
FDA Inspection Under authority to enforce 503A FDA authority to enforce cGMP regulations
Licensing State Boards of Pharmacy FDA Registration
Inspection FDA

State Boards of Pharmacy

 FDA & States if additional State requirements
Limitation on Services Individual prescription only

Limited anticipatory compounding

 Batch processing

May maintain inventory

Must sell direct to prescriber

 

Additional Differentiators

503A:

  • Laminar flow hood
  • Lack of aseptic technique
  • No qualification of:
    • Active pharmaceutical ingredients (API) & excipient* vendors
    • Container closure
    • Aseptic operators
    • Environmental controls

503B

  • Full current good manufacturing processes (cGMP) qualified[5]
  • API & excipient* vendors
  • Validated sterile procedures
  • Aseptic technique
  • Aseptic operators
  • Environmental controls
  • Environmental monitoring
  • Release assays
  • Stability testing

Best Practices for ASCs

If you need a product and there is no FDA-approved commercial option, it is best to use a cGMP 503B registered outsourcing pharmacy. If a 503B is not available, you can use a 503A facility, but ensure you perform due diligence on both types of facilities first.

There are several ways to obtain information on compounding facilities:

  1. Regulatory status / licensure. Know the regulatory status of the pharmacy you are ordering from by checking the FDA website. All registered compounding pharmacies are listed here with their status and survey history. Ensure you verify licensure in the state where the compounding takes place.[6]
  2. Query results of your (receiving state) State Board of Pharmacy for any regulatory infractions.
  3. Qualify your provider.
    • Use the questionnaire from the International Academy of Compounding Pharmacists (IACP). This document guides you through a series of questions that provide you with a good picture of the facility and their record of regulatory compliance.
    • Obtain and review an information release. Most pharmacies will give this to you if you ask. The information release will summarize regulatory status, licensure type, survey history, etc.
    • Obtain and review the pharmacy’s quality manual. If you really want to dive in, you can review their QA plans.
    • Obtain the cGMP certification of Product-503B outsourcing pharmacies. Often, they will provide a copy of the current good manufacturing processes that were used in production. This verifies the medication was made using the appropriate processes and verification methods.
    • Ask for proof of the facility’s Pharmacy Compounding Accreditation Board (PCAB) certificate.

Armed with this information, your ASC should be able to secure products from a reputable compounding pharmacy who is diligent about preparing medications in a safe environment. You can rest easier knowing you’ve performed the due diligence necessary to mitigate risk to your patients and maintain your ASC’s reputation of high quality care.

Jovanna Grissom, VP of Operations

[1]Avastin injections are reported to cause blindness.

[2] Killer pharmacy: inside a medical mass murder case.

http://www.newsweek.com/2015/04/24/inside-one-most-murderous-corporate-crimes-us-history-322665.html

[3] Patients lose vision after routine cataract surgeries at Dallas Key-Whitman center

https://www.dallasnews.com/business/health-care/2017/04/27/patients-lose-vision-routine-cataract-surgeries-dallas-key-whitman-center

[4] https://www.fda.gov/Drugs/GuidanceComplianceRegulatoryInformation/PharmacyCompounding/ucm339764.htm

[5] https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?CFRPart=211

[6] https://www.fda.gov/drugs/guidancecomplianceregulatoryinformation/pharmacycompounding/ucm378645.htm

 

Dec 28
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The Ripple Effect of Reducing Data Entry Errors

The Ripple Effect of Reducing Data Entry Errors

By ASC Management, Leadership, Revenue Cycle Management No Comments

When claims are denied due to data entry errors made during patient registration, a ripple effect occurs. Payments are delayed, increasing accounts receivable days. Back office billing personnel must work with front desk staff to obtain corrected data, then resubmit claims, wasting precious time. Staff may blame one another for the errors, damaging employee morale and creating an unpleasant work environment. If denied claims build up, the potential to miss important follow up grows and valuable revenue can go uncollected. Profit margins decrease and ownership distributions suffer.

These were all concerns of mine when I faced my ASC’s data entry error rate of nearly 11% in January. I knew we could do better. We had to. So, I set a goal for our front desk staff: to reduce their data entry error rate to below 1%.

In August, we achieved that goal. Our error rate is currently 0.69%. Staff want to further reduce their errors. Given their determination and effort to achieve what they have, I believe they can accomplish any goal they set for themselves.

Here are some of the steps we took to achieve this impressive turnaround.

Review and Analyze Data Entry Error Log

Accountability is critical when striving to improve. To ensure we maintained momentum, we implemented weekly reviews of our data entry error logs. During these reviews, we evaluated each error to identify the cause. We then discussed what staff needed to do to avoid making similar errors in the future.

For example, we noticed our team made similar insurance errors month after month. Some of the errors related to not clearly identifying payers. Others were steeped in confusion around different plan types offered by a single payer. To reduce these errors, we printed examples of our most common insurance cards, highlighting key details needed by registration staff on the front and back of those cards. Laminating these examples provided staff with “cheat sheets” that helped improve accurate entry of insurance details.

Data Entry Double Check

Each morning, an assigned member of the front desk team printed out the schedule of the previous day’s cases. This individual then double-checked that patient data in our registration system to ensure accuracy. To minimize interruptions and distractions, this review was performed in a private office.

Staff also sought out opportunities to perform data checks during the registration process, particularly concerning error-prone areas. For example, the subscriber date of birth was a troublesome data set. When the patient is not the subscriber, both dates of birth (patient and subscriber) need to be recorded. These repetitive reviews helped our team increase data entry accuracy.

Front Desk Staff Input

To help further secure performance improvement, we frequently asked front desk personnel to share their ideas. After all, working these accounts every day gave them insight into areas leadership did not have. We carved out time during our meetings for staff to share thoughts and let us know where help was needed. We worked on fostering an environment where they felt free to express themselves and ask questions.

These meetings and conversations allowed leadership and staff to develop a closer relationship. I maintain an open-door policy. Staff are comfortable speaking with me outside of meetings which allows us to quickly respond to opportunities to make positive change.

To help our front desk team members succeed, we regularly ask if they have the tools they need to perform their jobs effectively. We are happy to honor requests when we understand how doing so will bring about improvements

Ongoing Front Desk Staff Meetings

Once our front desk staff achieved the data error entry rate goal and demonstrated an ability to maintain it, we didn’t stop our meetings. Rather, we decreased meeting frequency from weekly to monthly. Our monthly meetings provide us with time to review and discuss a summary of the previous month’s data entry error reports. Error trends are now a rarity. Our vigilance ensures new trends aren’t developing and significant time isn’t passing without detection of potential troublesome areas.

Eye on the Prize

Ongoing updates on performance is the primary reason our front desk team members were so successful in lowering their data entry error rate. As we instituted improvements, they anxiously awaited delivery of the next data entry error log. They wanted to gauge their performance and find out if their hard work was achieving the desired results. Disappointment set in when the error rate did not decline or drop as much as they hoped. Fortunately, they used their disappointment as motivation to be proactive and seek additional opportunities for improvement.

I see tremendous value in providing our front desk staff with achievable, measurable goals. This team is now working on a new objective – capturing information about patients’ primary employers. Because this is a new process for them, team members occasionally fail to capture this information. We evaluate staff performance in this area monthly and work to determine reasons why our capture rate is not 100%. That’s our goal, and we know it’s obtainable. Why? Because it is a figure achieved by other Pinnacle III managed facilities, and our staff knows it. Now there’s some friendly competition between facilities.

The Ripple Effect

The positive ripple effect our ASC experienced when our front desk team reduced their data entry error rate to less than 1% was significant.

  • In January, when our error rate was 11%, our average accounts receivable (A/R) days was 28. When we reduced the error rate to 0.69% in August, our average A/R days decreased to 20.
  • Our claims-to-payment days declined – from 34 days in the first quarter of 2017 to 31 days in the third quarter.
  • We experienced a reduction in bad debt – from 4% at the end of 3rd quarter 2016 to 3% during the same timeframe in 2017. While the drop in bad debt is attributable to the improved efforts around upfront collections, it underscores how focusing on troublesome performance indicators can produce meaningful change.

Financial improvements have not been the sole byproduct, however. A transformation has occurred among our front desk personnel.

  • They are more engaged and eager to learn about their performance.
  • They more fully understand how their efforts affect our facility which motivates them to continuously strive for excellence.
  • Their relationship with leadership is truly collaborative.
  • Our governing board, which reviews the financial data, has expressed pride in and appreciation of front desk staff performance.

My concern with the damaging ripple effect that could have occurred when our data entry error rate was 11% subsided as progress was made by our front desk team. Our focus on, and improvement in, this area has made a difference. Our ASC operations were positively transformed in a sustainable way.

Michaela Halcomb, Director of Operations

Dec 18
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Relieving the “Financial Pain” of Surgery via an ASC Financial Counselor

Relieving the “Financial Pain” of Surgery via an ASC Financial Counselor

By ASC Management, Leadership No Comments

With more employers offering high-deductible health plans as an affordable insurance alternative, health care providers recognize their patients’ out-of-pocket financial responsibility is steadily increasing. ASCs often struggle with adeptly handling patient communication regarding this monetary component of surgery. It is challenging enough for most patients to understand the nuances of their health insurance plans without adding the potential stress of thoroughly evaluating their personal financial obligations for each episode of care. Patient satisfaction surveys frequently reflect this stressor. However, this added challenge is easily avoidable with clear, advance communication. Many ASCs have responded to this patient need by adding a financial counselor to their staff.

Educating patients is the most effective way to minimize confusion, maximize time of service collections, and increase patient satisfaction. Reading an explanation of benefits (EOB) can be daunting. Deciphering up to four EOBs for one surgery can be downright overwhelming and, in some cases, shocking. In 2015, 77 percent of consumers reported they were confused by the explanation of benefits they received from their health plan. Seventy-six percent were confused by bills from their providers. By the time a patient is scheduled for surgery, they have often received an estimate of charges and made a payment to their physician’s office, not realizing there is a separate financial obligation to the facility and, in many cases, the anesthesiologist and/or pathologist.

Creating an ASC financial counselor role ensures your facility has a dedicated person responsible for patient communication and financial education in advance of surgery. The ASC financial counselor also plays an integral part in preparing cost-benefit analyses and providing the details to management for consideration.

When contemplating the addition of an ASC financial counselor, items you may want to evaluate include the following:

  • Is the ASC maximizing time of service collections?

    • A financial counselor will improve the percentage of up-front collections through patient education and setting expectations. Advance communication allows patients the time necessary to plan for their financial outlay. By adding an ASC financial counselor, patients receive this information in a timely manner, depending on when the surgery is scheduled.

  • Does the ASC have a high percentage of bad-debt write-offs or accounts in collections?

    • A high percentage of write-offs and accounts referred to collections is indicative of failure to maximize up-front collections or develop formal payment plans. In contrast, a dedicated financial counselor clearly communicates the financial obligation to the patient and formulates a plan for payment in advance of the patient’s episode of care. This includes a written contract if payment is not made in full by the day of surgery, thereby eliminating confusion and creating a firm commitment of payment from the patient.

  • Is the ASC aware of the costs associated with the cases they perform?

    • ASCs, like other businesses, must evaluate which surgeries consistently lose money. The ASC financial counselor is tasked with flagging such surgeries and assisting with minimizing up-front losses. Oftentimes, properly evaluating and documenting these surgeries will provide your payor contracting team with the leverage they need to negotiate proper reimbursement.

  • Is the ASC receiving negative feedback regarding finance on patient satisfaction surveys?

    • Patients will be much more pleased with their overall experience if they fully understand their financial obligation and do not face unexpected or minimal post-surgery expenses when their EOBs arrive.

  • Does the ASC have the case volume to support a full-time or part-time position or can this responsibility be added to an existing employee’s job description?

    • A high-volume center will benefit from adding this position as a full-time role. This person provides a final verification of demographics, as well as confirmation of insurance authorization, leading to fewer avoidable denials. A financial counselor is valuable to every ASC, regardless of size. If the center cannot support this position independently, consider adding the responsibilities to an existing front-desk role.

An ASC financial counselor typically reduces frustration for patients as well as staff. Having a person dedicated to this role improves collections, reduces bad-debt, decreases avoidable insurance denials, and minimizes financial losses due to poor reimbursement, all of which bringing substantial value to the ASC.

Lori Tamburo, Director of Operations

Dec 13
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Responding Appropriately to a Disruptive Employee

Responding Appropriately to a Disruptive Employee

By ASC Management, Leadership No Comments

A thriving ASC runs like a well-oiled machine. However, even the gears of a well-oiled machine can slip creating minor issues that disrupt performance or major issues that can bring performance to a halt.

Some of the gears in your ASC are your employees. When they follow outlined procedures and fulfill their job responsibilities, operations typically run smoothly. However, when an employee becomes disruptive, like a malfunctioning gear, significant problems can occur. Disruptions can –

  • Undermine the culture of safety,
  • Distract staff from attending to their responsibilities which can affect safety, financial performance, and regulatory compliance,
  • Contribute to a decline in staff morale,
  • Increase staff turnover,
  • Weaken staff confidence in management/leadership, or
  • Create legal issues (e.g., patient negligence, physical or verbal abuse).

While there are common steps taken in response to any disruptive employee, different types of disruptive employees require different approaches.

Long-Term Well-Performing Employee Who Suddenly Becomes Disruptive

Good employees are hard to find. Well-performing, experienced employees are difficult to replace. But even the best employees can become disruptive. An employee may act out due to an internal conflict or an external issue that carries into the workplace.

Make time to have a one-on-one discussion with this employee. Be honest and direct about why you are engaging in the conversation. Provide the employee with a description of the disruptive behavior and share personal observations. Straightforwardly pose the question, “What’s going on?” That may be all it takes to obtain an explanation. Provide assistance, when it’s appropriate to do so.

If this conversation fails to bring about a resolution, turn to your human resources policies. If you are dealing with a safety and/or behavior issue, and a policy speaks to these matters, review the applicable language with the disruptive employee. Share a copy of the policy with the employee. Then provide a performance improvement plan outlining expected behavioral changes. Identify a specific timeframe to demonstrate improved performance. Clearly explain the consequences of failure to comply with the plan.

New Hire

You’ve put in the time to find, interview, hire, and orient a new employee. When you learn this individual is disruptive, take a deep breath. Before you stress about having to go through the hiring process all over again, understand that new hires often struggle during their initial employment period.

But don’t stop there! Immediately sit down with the employee and discuss the disruptive behavior. Share your observations. Explain why the employee’s actions are not acceptable. Review your employee handbook with the employee, specifically focusing on pertinent areas – your code of professional conduct and disciplinary procedures, for example. Outline what the employee needs to do to avoid discipline and possible loss of position.

Note: The hiring and training process is time-consuming. Losing a new employee, while easier to handle than losing a senior employee, is not optimal. Ensure you employ a sound interview process that affords you the best chance of hiring the right people the first time around. Ask appropriate questions and dig below the surface to gain insight into your candidates’ answers. Develop a comprehensive onboarding process and sound competency training program. Hiring smart and clearly establishing expectations at the outset positions new employees for success.

Well-Performing Employee in Their Department, Disruptive Employee Elsewhere

You have an employee who is great at their job. They fulfill their responsibilities and receive high marks from managers and co-workers within their department. But when they step outside of their work area, they become disruptive. It’s an unfortunate development that requires action.

Investigate the situation. Speak with the individuals affected by the employee’s disruptive behavior to learn as much as you can about the employee’s actions. Sit down with the employee and explain how his or her actions may be indirectly affecting the performance of their own department and the ASC’s ability to deliver the best possible patient experience. Sometimes, these employees need to be reminded they are expected to maintain the high level of professionalism and excellence they demonstrate in their department throughout the entire facility.

Long-Term Disruptive Employee Who Was Never Disciplined

A new ASC manager learns of an employee whose disruptive actions and/or behavior were ignored by previous leadership. Unfortunately, this is not an ideal start to a new position. If the new leader wants to earn the respect of all ASC staff, action is imperative.

Review the employee’s personnel file to find out if previous managers spoke to the individual or took any action. Speak with affected staff members to learn all you can, documenting any information not included in the file.

Again, sitting down with the employee is necessary. Make it clear the disruptive actions were never acceptable and must now stop. Establish clear expectations regarding future behavior. Provide the employee an opportunity to share their perspective and address whether they believe they can meet your expectations.

While a new manager will not know this employee well, a respectful discussion is vital. Avoid a confrontational tone and negative expressions. The employee may not have realized their behavior was disruptive or understood the harm caused by their actions. A supportive manager who provides positive guidance may be all that is necessary to resolve even a long-term problem.

Rely on Your Policies

Managers faced with any type of disruptive employee behaviors are well-served when they follow their ASC’s policies and procedures. Doing so helps ensure consistency in addressing behavioral incidents and maintaining regulatory compliance.

Managers should prepare to follow through on outlined consequences even if it means firing a valued employees. A disruptive employee can place significant strain on your well-oiled ASC; but a manager who does not respond appropriately may cause irreparable damage.

Jennifer Arellano, Director of Operations

Dec 06
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Overcoming ASC Management Nightmares: Physician Engagement

Overcoming ASC Management Nightmares: Physician Engagement

By ASC Management, Leadership No Comments

Third installment in the “Overcoming ASC Management Nightmares” blog series. Click here for Part 1 and Part 2.

ASC Management Nightmare #3: Physician Engagement

There’s no denying the importance of physicians performing procedures in ASCs. After all, without procedures, there is no ASC business. When physicians view performing procedures as their primary purpose in supporting an ASC, they may overlook the importance of physician engagement – a vital component of ASC operations.

Regulatory bodies expect to see ASC physicians – specifically owners – involved in all aspects of the organization. Compliance issues may arise when physicians fail to take an active role.

In addition, when physician engagement is lacking, financial problems can quickly arise. For example, in the absence of physician oversight, an individual’s desire to perform more procedures may lead to the addition of cases or purchasing of equipment that does not deliver a positive return on investment.

When physicians hire ASC management staff, they often intend to pass off the responsibility of running the ASC business. Managers must ensure physicians understand their required role in operations and its critical importance to the ASC’s success. This task is typically easier said than done.

Solution

Data is naturally attractive to physicians. Many of them likely chose to pursue a career in health care because it is a data-driven business. Consider statistics like life expectancy, death expectancy, surgical success rate, percentage of risk – physicians are used to sharing this type of information with patients.

To improve our ASC’s physician engagement, we’re working to cater to their love of empirical decision-making. In the past, we often relied on providing hand-collected and anecdotal data to help physicians make informed decisions regarding business operations. But since this data was not scientifically objective, it was not always effective in achieving our desired results.

To combat this perception, we are implementing computer programs that allow us to refine that data so it’s “hard and true.” These programs measure numerous data points in areas such as quality, volume, and case costing. We have used this concrete data in presentations to physicians and witnessed an emotional change. They are more willing to accept, assess and respond to the information. Physician engagement in ASC management is shifting from passive to active.

Lisa Austin, VP, Facility Development

Nov 30
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Managing a Non-Compliant Patient in an ASC

Managing a Non-Compliant Patient in an ASC

By ASC Management, Uncategorized No Comments

ASCs fortunate to remain in business long enough are likely to have the unfortunate experience of a non-compliant patient. When non-compliance occurs, patient and staff safety may be jeopardized.

Patient non-compliance in an ASC can take many forms. These include not taking medications, personal removal of an oxygen mask, and getting out of a wheelchair or bed without caregiver approval. A non-compliant patient can disrupt the delivery of care and an ASC’s workflow. They can also injure themselves as well as individuals around them, including staff. In most cases, that harm is unintentional, such as a patient fall due to a failure to follow instructions. However, an aggressively resistant patient may intentionally hurt caregivers.

To help prepare your ASC to respond effectively and appropriately to a non-compliance scenario, follow these steps.

1. Simulate non-compliant patient events.

If you don’t practice your response to an incident, you can’t emulate what you want to achieve. That’s why it is critical to practice non-compliant events. You can do so through drills or use of “mock patients” where an employee acts like a difficult patient. Consider scripting the experiences to more accurately represent what may happen. Emphasize the importance of remaining calm. Evaluate the response to each simulation and determine opportunities for improvement.

When brainstorming scenarios to simulate, consider possible situations specific to your ASC. For example, if you have a convalescent center, patients staying with you for an extended period can present unique risks. An extended care patient on bed watch may determine it’s safe to ambulate independently without first alerting a nurse. This non-compliance could lead to a devastating fall.

2. Secure the situation.

Regardless of whether patient or staff safety is threatened, make sure to “secure” the situation. Securing the situation can range from calling in security to deal with a threat of violence to informing people around the non-compliance incident what is occurring. If staff members do not feel comfortable responding to a situation on their own, bring in a manager or physician to assist with the situation.

3. Empower staff.

ASC staff, particularly nurses, often have a patient-first mentality. As employees of the ASC, their work focuses on providing the best possible experience for patients. But sometimes the customer isn’t always right. Leadership should emphasize it is not only acceptable but encouraged for staff to speak up when faced with a non-compliant patient.

Empower staff to make decisions they feel are in the best interest of patient and staff safety. This may include transferring a patient to the hospital – a decision not to be made lightly, but one that staff should know is an option if the situation warrants it.

4. Engage family and friends.

Once you encounter a non-compliant patient, you’re no longer just dealing with the patient. The situation also indirectly involves those individuals accompanying the patient. It is important to be upfront about what is occurring with family and/or friends. When you are honest and respectful, conversations about the issue are typically easier. These individuals may have recommendations for how to help diffuse a situation and obtain compliance.

5. Determine level of seriousness.

After you address the non-compliant patient incident, asses its severity. If the incident was minor, including a note in the patient’s chart may suffice as documentation of the experience. However, if the incident led to a more significant patient and/or staff safety issue, consider involving your medical advisory committee and governing board. Also consider whether to involve your risk management and legal team.

If the incident resulted in serious patient harm, patient unconsciousness, or patient transfer, it may require reporting to your state. Understand your state specific reportable event policy and process.

6. Analyze the non-compliant patient incident.

Regardless of the incident’s severity, set aside time to analyze what occurred. Perform a root cause analysis if the incident is significant. Even a minor non-compliant patient incident is worth formally discussing with staff. The key is obtaining feedback on the response and determining if there are opportunities for future improvement.

7. Don’t overlook possible effect on staff.

Dealing with a non-compliant patient is typically not easy. The experience, particularly one which jeopardized safety, may cause distress for your staff and physicians. It is important to evaluate how these “second victims” respond to the incident. If anyone appears traumatized, offer professional support. One-on-one conversations with team members may bring trauma to light.

The More You Know

A non-compliant patient situation can escalate very quickly, going from a seemingly minor incident to one that risks patient and staff safety. By allocating time for education on non-compliance, you will put staff members in a better position to act responsibly when an incident occurs. Following an incident, take advantage of the negative development and turn it into a positive by evaluating the situation. Hopefully what staff members learn will improve their response during the next experience.

Jebby Mathew, Regional Director, Operations

Nov 28
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Introduction to ASC Data Analytics

Introduction to ASC Data Analytics

By ASC Management, Uncategorized No Comments

Part 1: Introduction to ASC Data Analytics

In this three-part series, I will explore the topic of ASC data analytics. Part 1 introduces the topic of data analytics as it applies to ASCs. Part 2 provides examples of how analytics can benefit ASCs. Part 3 walks through the evaluation process to determine if data analytics is a good fit for your surgery center. Let’s dive in!

To succeed in today’s competitive business environment, every organization requires knowledge and understanding of its performance. This fact is especially true in the rapidly evolving world of healthcare, perhaps even more so for ambulatory surgery centers (ASCs). For some, a simple informal review of monthly financial statements may present a sufficient picture of the overall health of the organization. A review of standard accounting reports can provide the information necessary to guide general decision making. However, basic reporting and analysis may not provide sufficient insight to maintain pace with the constantly changing, fast-paced ASC market.

To gain a competitive market advantage, a deeper understanding of an ASC’s performance may be required. The emerging field of ASC data analytics focuses on providing nuanced introspections that surgery center leaders can rely upon as critical tools for decision making.

If you’re not familiar with ASC data analytics, don’t worry. You are not alone. While utilized extensively in financial and retail sectors, ASC data analytics has only recently gained traction. While many factors play into this rapid growth, they all essentially boil down to rising costs, tightening reimbursement, and the influx of integrated health networks. ASC data analytics is increasingly utilized to identify actionable areas of improvement and model the impact of potential changes before they are implemented. As the ASC arena continues to become more competitive internally, along with growing outside pressure – an aging population, payment model shifts, and fluctuating legislation, for example – the ability to identify core problems and predict the success of proposed solutions is an essential tool for organizations looking to gain a competitive edge.

Utilizing data analytics may sound like a panacea for struggling ASCs looking to get back on track or for successful ASCs seeking to further strengthen their position. However, before jumping on the ASC data analytics bandwagon, it’s important to fully understand what analytics entails in the ASC world. Once a basic comprehension is achieved, only then can one ascertain whether implementing an ASC data analytics program is likely to produce a suitable return on investment.

Stay tuned to gain additional understanding of ASC data analytics! My next post in this series will provide examples of how data analytics can be leveraged by ASCs. I will wrap-up the series in my third post by delving into how to determine if an ASC data analytics program is a good fit for your organization.

Cody Carlin, Director, Data Analytics

Nov 21
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Patient Billing – Enhancing Patient Satisfaction & Your ASC’s Revenue Cycle Process

Patient Billing – Enhancing Patient Satisfaction & Your ASC’s Revenue Cycle Process

By ASC Management, Revenue Cycle Management No Comments

You may think service to your ASC patients ends upon completion of their surgical visit. The reality is, patient satisfaction extends far beyond their date of service. An effective patient billing and collections process can impact patient satisfaction both prior to and after their visit.

How can your surgery center create a positive revenue cycle experience and improve your patient billing process?

1. Proactively address financial concerns prior to each patient’s surgery by obtaining and providing thorough information on their behalf.

  • Contact patients prior to their date of service to verify registration information.
  • Perform insurance eligibility and verification to obtain prior authorization, if required.
  • Create a patient financial responsibility estimate for services to be performed.

2. Avoid potential billing misunderstandings by clearly relaying payment expectations upfront.

  • Discuss patients’ financial estimates with them prior to their scheduled appointment.
  • Secure payment from patients or explore payment plan options.
  • Clarify any remaining billing questions patients might have concerning the billing and collections process.
  • Record details regarding any prior arrangements made with patients in your ASC’s patient accounting system. This will assist with future collections efforts, if needed.

3. Improve upfront collections and/or adherence to agreed-upon terms for financing by reviewing patient estimates with them on the date of service.

  • Review financial responsibility estimates and payment options with patients again, answering any remaining questions they may have.
  • Secure signed financial agreements outlining payment plan details.
  • Collect payments that are due at time of service. Your patients are more likely to pay their bill when you review financial expectations and proactively involve them in the estimation and payment process.

4. Make it easy for your patients to remit payments.

  • Offer an online payment portal accepting ACH debits from bank accounts, a variety of credit cards, and payment plan options.
  • Provide patient friendly statements.

An efficient insurance verification process allows claims to move through the third-party payer system. The result? Timely reimbursement. Conversations with your patients regarding their anticipated financial responsibility ensure they are informed ahead of time. If you’re communicating well, they are able to understand and follow the ASC revenue cycle process.

The goal is a positive patient billing experience from referral all the way through to a zero balance on their account. Patient satisfaction, timely revenue collection, and recommendations of your facility to other patients seeking quality care and a smooth process is a win-win for all!

Carol Ciluffo, VP of Revenue Cycle Management

Nov 16
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Overcoming ASC Management Nightmares: Keeping Up with Regulatory Changes

Overcoming ASC Management Nightmares: Keeping Up with Regulatory Changes

By ASC Management, Leadership No Comments

Second installment in the “Overcoming ASC Management Nightmares” blog series. Click here for Part 1 and Part 3.

ASC Management Nightmare #2: Keeping Up with Regulatory Changes

Rarely a week goes by where there are no new regulatory changes approved or existing regulations revised. This should come as no surprise when you think about how many regulations ASC’s must meet to remain in compliance. There’s Medicare’s interpretative guidelines. There’s HIPAA and the HITECH Act. There are coding rules, billing rules, human resources rules. The list goes on. On top of federal regulations, ASC management must understand their state-specific rules, some of which can trump federal rules.

Staying abreast of all the ongoing regulatory changes is a daunting, but crucial, task. If I fail to do so, I risk our ASCs falling out of compliance. Just the thought of that happening puts a knot in my stomach.

Solution

Fortunately, I’ve found comfort by using resources that help me stay abreast of regulatory changes and their effects on ASCs.

The national Ambulatory Surgery Center Association (ASCA) is a tremendous source of information. ASCA offers valuable education and networking opportunities through its annual meeting, monthly webinars, and periodic multi-day seminars. Members receive regular emails highlighting changes to federal regulations as well as those under consideration. ASCA has assigned staff members to monitor and research rules and regulations. You can be confident that if there are regulatory changes, they will know about it.

In addition, ASCA members can take advantage of ASCA Connect, an online discussion group. Active ASC professionals post a wide variety of questions and requests every day. Most of them receive helpful responses. Members of the ASC community are eager to help one another and willing to share their knowledge and tools. ASCA Connect provides a great opportunity to network with other members of ASC management outside of in-person meetings.

Many states also have their own ASC associations. If you’re not currently involved with your state’s association, consider joining. The active state associations monitor important regulatory developments and share this information with their members. They also typically host networking meetings and/or educational conferences.

Finally, there are other ASC trade conferences you may want to consider attending. Professional societies, law firms, and industry publications, for example, host their own meetings.

Information is your biggest tool in keeping up with regulatory changes. Organizations that provide timely, accurate information on regulatory changes are your most important allies. In this ever-changing regulatory environment, there’s no such thing as too much education.

Lisa Austin, VP, Facility Development

Nov 06
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Overcoming ASC Management Nightmares: Finding OR Nurses

Overcoming ASC Management Nightmares: Finding OR Nurses

By ASC Development, ASC Management No Comments

First installment in the “Overcoming ASC Management Nightmares” blog series. Click here for Part 2 and Part 3.

One thing I’ve learned over the years is that if you hold an ASC management position, there’s always something that will keep you up at night. Whether your ASC has been open one day or 10 years, dealing with challenges is the norm. How you address those issues is what really matters.

This is the first installment in my “Overcoming ASC Management Nightmares” blog series which will explore the challenges robbing me of precious sleep. Fortunately, I’ve been successful in taking steps to keep these nightmares at bay. I suspect other ASC managers are experiencing these nightmares too. Hopefully my solutions can help put your mind at ease.

ASC Management Nightmare #1: Finding OR Nurses

The motto “If you build it, they will come” may have served Kevin Costner’s character in Field of Dreams well, but it typically doesn’t help ASCs when it comes to attracting staff. I recently helped build a new ASC. The first question each of the prospective administrators asked was, “How are you going to find staff?”

Nearly everyone I encounter is trying to figure out the answer to this question, particularly when it comes to hiring OR nurses. You can be in an area oversaturated or under-saturated with ASCs. In either case, you likely won’t find a large pool of good quality OR nurses to choose from.

How did we get here? Formalized educational forums for non-OR nurses to receive OR training is lacking. New nurses coming out of nursing school often feel they have received enough clinical education to justify a management position. The OR setting is heavy on mature nurses who are likely to retire in the coming years.

If you want to recruit high-quality OR nurses away from existing employment, prepare to pay them more than you pay your current pre-op and PACU nurses. You may need to offer OR nurses a different tier of benefits to entice them to join your ASC. Successful recruitment may even require you provide a substantial hiring bonus and cover relocation costs.

Adding OR nurses can affect many different layers of your business and operations, including physician/owner satisfaction, financials, and morale. Unfortunately, there is a lack of resources to help address this nightmare without breaking the bank.

Solution

Rather than look outside of our ASCs for OR nurses, we are looking within. We are implementing training programs that afford non-OR nurses the opportunity to become OR nurses. The Association of Registered Nurses (AORN) develops and sells the program’s infrastructure. It is comprised of a syllabus and criteria for staff to meet.

If a staff member expresses an interest in becoming an OR nurse, ASC management assesses the individual’s qualifications. When the nurse is in good standing and possesses the appropriate skill level, we purchase the AORN program on their behalf.

Once in the program, nurses in training work and are paid for their regular shifts. However, they do not perform their normal pre-op or post-op functions. Instead, they shadow a current OR nurse who serves as their mentor and helps provide on-the-job training. The trainees must complete homework and take tests on their own time. When they successfully complete the program, they transition into the OR.

We make a substantial investment in these nurses. Not only do we cover the cost of the program, we also pay another nurse to cover their responsibilities during their training. To enter the program, nurses sign an agreement with the ASC. They must remain with the ASC for an agreed-upon length of time that allows the facility to recoup its investment. If the nurses fail to complete the program, a payback mechanism in place.

Our use of the program is in its infancy, but the results are encouraging. Knowing we have a mechanism to help us groom our own OR nurses provides great comfort.

Putting Your ASC Management Nightmares to Bed

As long as you are in an ASC management position, don’t expect many anxiety-free evenings. That’s not unusual when you directly impact the success of a business and safety of people.

But try not to feel like you need to come up with all the answers to the challenges your ASC faces on your own. Brainstorm with people inside and outside of your organization. If you’re experiencing a challenging situation, chances are that others in ASC management are as well. When you connect with likeminded people working in the same industry, you can problem solve together.

And try not to be afraid to talk about the issues that are keeping you up at night for fear that it makes you appear vulnerable. I believe it does just the opposite: When you identify an issue and attack it head-on, you appear stronger. After all, no one has all the answers. Simply acknowledging there is a problem oftentimes makes it easier to develop a solution.

Lisa Austin, VP, Facility Development