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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

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.


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

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.


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

What’s Your ASC’s Leverage Point in Payer Negotiations?

What’s Your ASC’s Leverage Point in Payer Negotiations?

By Leadership, Payor Contracting No Comments

When it comes to payer negotiations, your ASC leverage point is the weight you bring to the game. What do you lean on to produce results? What card(s) do you play to change the game?

What we’re talking about here is simple physics – matter, motion, energy, and force. Or put more simply, influence. Influence equals change. And no influence equals no change. If what you’re leveraging weighs on you as much as it does your opponent, it’s not leverage. Think of a teeter-totter on a playground with two evenly weighted people on it. It doesn’t move much! You need force applied to one side to create influence and shift the situation.

Your ASC leverage point is achieving the most gain while exercising the least amount of loss. It is important to know what you can concede and what you must gain before your walk into any negotiation. Apply this to all parts of your ASC business operations, especially negotiation with payers.

Optimal leverage enables you to impact change that multiplies your efforts and preserves the utilization of your resources.

Let’s look at an ASC leverage point example.

Is achieving a slight increase in your ASC’s procedure reimbursement at the cost of surrendering payment for implants a leverage point? No, because it costs your ASC as much as it gains. Again, think of the teeter-totter example with two evenly weighted parties attempting to move it. You must work to concede less while still achieving positive results. If your ASC can gain a decent increase without giving up anything other than perhaps the time and energy necessary to make its case, then a true leverage point is exercised.

For a leverage point to work in your favor, it must be sensible, perceived as credible by the payer, and not merely a perceived threat. If perceived as a threat, it will not have the power to influence the other side to move closer to a negotiating position. In either case, an ASC leverage point has potential to bestow gains or impose losses on the other side. However, a genuine leverage point is not overstated or punitive; it’s consequential and practical. It’s the prime force you exert to get what you need and goes beyond strong negotiating skills. Negotiation skills cannot replace a genuine leverage point.

Consider another ASC leverage point example.

Say a payer bundles implant payment and is not offering adequate reimbursement to cover your ASC’s costs plus a reasonable profit. Does your ASC threaten to terminate its contract with the payer because the procedure pays poorly? (This is probably a threat some payers hear often but providers rarely follow-through on.) This tactic would likely amount to a lose-lose proposition for both parties.

An alternate option is to inform the payer your ASC can no longer accept these cases on their members and must divert the cases to a higher paid (facility perspective) and higher cost (payer perspective) center to make your case. The former is not a perceived leverage point unless your ASC truly intends to carry out the termination. But the latter is not only grounded, it will demonstrate to the payer how much they will lose by not administering a reasonable procedure reimbursement that covers your costs and nets a reasonable profit.

Let’s face it, your facility needs the payer to pay more, but the payer has little incentive to pay your facility more. Payers hold significant leverage. To make your case, your ASC must find and exercise its leverage point and change the equation.

A change in the equation can be a payer gaining more information and an increased understanding and willingness to adapt to your ASC’s thinking. Your ASC is offering a cost-containment solution to the payer. Rather than simply asking for greater reimbursement, your ASC must negotiate rates that allow you and your payers to stay in business in a competitive health care market.

Dan Connolly, VP of Payer Relations & Contracting

Improving Clinical Staff Efficiency with ASC Business Education

By ASC Management, Leadership No Comments

Gradually moving up the ASC job ladder provided me with opportunities to learn a great many things. One of the most significant lessons arose not long after I moved into a management position.

As a nurse, my focus was on delivering the best care possible to every patient that crossed my path. When we delivered great outcomes, I felt successful. Because there were always patients for me to care for, I assumed the ASCs I worked in were also successful businesses.

My outlook changed when I became a manager. My effectiveness as a manager requires focusing on the bigger picture. A significant part of that picture still includes the delivery of safe, compliant care. However, another sizable part involves the financial side of running an ASC. I felt very comfortable with the former and completely unprepared for the latter.

In a clinical position with no management duties, I didn’t stop to consider the ASC business. I didn’t know the reimbursement we receive for a case covers everything we do for patients, from the moment they walk in the door until they go home. It also covers the ASC’s expenses, including our surgical supplies, utilities, rent, and, of course, salaries. I did not receive any relevant ASC business education until I assumed a management position.

Receiving an ASC business education changed my perspective on the delivery of care. Now, every time I see an unused towel or suture in the trash, I equate it to money – money that could go toward better equipment, new technology, and pay raises. I quickly surmised conveying some ASC business education basics to my clinical staff would likely go a long way toward cutting our costs.

Here are some of the ways I approach providing ASC business education to clinical staff.

Allocate time. During our monthly staff meetings, I commit time to discuss our business. I gauge what staff members do and do not understand. I provide clarification when they have specific questions. Once a quarter, I dedicate most of a meeting to ASC business education. This allows me to dive more deeply into specific topics. Since much of what I cover is new, I spread out education to avoid overwhelming staff. I want to teach, not scare them.

Keep it simple. Clinical staff don’t need to know every little detail about the ASC business. When I explain concepts like reimbursement, inventory management, just-in-time ordering, and case costing, I take a “101” rather than a “301” approach. I define concepts using basic terms and outline how they affect the ASC’s bottom line. I focus on how improvements in our ASC business performance benefit patients, staff, and facility.

Break down costs. Sometimes providing a little data can help drive a point home. Our ASC uses Project C.U.R.E. bins to gather medical supplies and equipment for donation. Staff discard unused items from surgical packs into these bins. After these bins fill up, I take pictures of the items inside and put a cost to them. I show these pictures and share the financial breakdown with staff. I also share data comparing the cost of “red” medical waste versus regular waste and disposable versus reusable supplies. Talk about eye-opening experiences!

Challenge staff. Once staff gain a better appreciation of waste costs, we attack our surgical packs. I ask staff to look at the packs to determine what is actually needed in them. At times, staff indicate rarely used items are included in the pack per physician request. In these instances, I speak with the physician. We typically remove the item from the pack but make sure it is available in the room during surgery. That’s a win-win!

New isn’t always necessary. On one occasion, an influx of non-ambulatory nurses joined our ASC. The facility they previously worked in purchased everything new. I educated them about refurbished equipment. I emphasized our use of this equipment did not jeopardize the delivery of high-quality care they were used to providing but did save us money.

Focus on safety. When speaking about cutting costs with your clinical staff, expect some looks of concern. Staff may translate “cutting costs” to mean “cutting resources” and, therefore, “cutting corners” on safety. Convey to staff the ASC will not authorize cuts that could jeopardize safety.

For example, we were using a lot of sterile towels during non-sterile cases. When I addressed how the use of non-sterile towels during these cases would benefit the ASC business, I also explained why doing so wouldn’t increase risk.

Engage Staff, Grow the ASC Business

As my clinical staff gained a better understanding of our ASC business model, they embraced the challenge of finding and implementing cost-cutting changes. With this mindset, we achieved significant savings in a short amount of time.

I know we can always do better. That’s why I try to ensure our clinical staff always have the business education of our ASC operations in the back of their minds. It’s easy, even for leadership, to become complacent when things seem to be going well. But in a health care environment where every dollar really does matter, there’s no room for complacency, and no reason not to empower all staff to make a difference in the bottom line.

Tara Demuth-Fenton, Director of Operations

ASC Disaster Response: A Case Study

ASC Disaster Response: A Case Study

By ASC Management, Leadership No Comments

This is the second part of a two-part blog series on ASC disaster response by Diane Lampron, Director of Operations. Click here for part one.

In the blink of an eye, a completely normal day in your ASC, can be upended by a natural or man-made disaster. And it can take days, weeks, or months to return to your pre-disaster routine.

Emergency preparation is not only critical for an effective ASC disaster response, but, as we previously discussed, it’s a Medicare requirement for ASCs. Part of proper preparation is revising your emergency plan based on your response to drills, tabletop exercises, and emergency events. Every revision should improve the helpfulness of your plan. Understanding what it’s like for another ASC to respond to a disaster can further your ASC disaster response preparation.

Below are some of the critical steps taken during a Colorado ASC’s response to a ruptured pipe. The subsequent flooding caused substantial damage throughout the ASC. Areas flooded with the equivalent of sewer water included the waiting room, front hallway, registration desk, pre-op, and recovery room. The sub-sterile area also suffered significant damage. Thanks to a strong, tested emergency plan, hard work by staff, and outside support, the ASC re-opened to full capacity in three months.

Immediate ASC Disaster Response

Steps taken upon discovery of the flood and damage included the following:

  • Called the disaster code
  • Activated the emergency management plan (EMP)
  • Contacted fire department (which turned off water)
  • Ensured there were no patients, visitors, or personnel requiring evacuation.
  • Closed front entrance
  • Notified ASC leadership
  • Assessed affected areas
  • Took pictures of damage
  • Set aside damaged items/equipment (for insurance purposes, this included items that caused the damage, such as a broken sprinkler pipe)
  • Moved unaffected equipment away from damaged areas
  • Notified property insurance carrier
  • Rerouted deliveries

Activating the EMP

Activation of the ASC’s EMP triggered the following actions:

  • Established incident command team
  • Identified who would fill the roles identified in the EMP – Role assignments are critical. Each role guides the activities required to address all aspects of the disaster, from suspension of business operations to the response and through recovery.

Roles assigned included incident commander and staff (e.g., safety officer, infection preventionist, public information officer) as well as sections for operations, planning and logistics, and finance/administration. If you are not familiar with the responsibilities of these positions, the Federal Emergency Management Agency provides helpful resources here. Note: Some of the activities that took place under these sections are discussed below.

  • Developed incident action plan which established objectives throughout response to the incident and underwent regular updates as recovery progressed
  • Notified the facility’s governing board


The following steps were taken to disperse information regarding the incident and closure:

  • Changed telephone greeting
  • Posted notice on center’s website
  • Notified physicians’ offices
  • Notified the state’s Department of Public Health
  • Issued press release
  • Notified the state’s Department of Fire and Life Safety
  • Notified the facility’s accreditation organization

Disaster Recovery Work

The project was separated into five phases to be completed prior to a re-opening phase:

  1. Mitigation/ restoration
  2. Safety
  3. Demolition
  4. Rebuilding/construction
  5. Risk reduction


Steps taken included the following:

  • Restoration company commenced water cleanup and mitigation activities working 24/7 to mitigate further damage
  • Industrial hygienist conducted assessment and took samples
  • Infection control risk assessment (ICRA) performed


Steps taken included the following:

  • With fire sprinklers offline, fire watch implemented
  • Conducted and documented fire watch walkthrough every 30 minutes during recovery period
  • Created signage for emergency fire exits


Steps taken included the following:

  • Brought in contractor for demolition and construction phases of the work
  • Obtained permits needed for demolition and renovation/construction


Renovation plans previously scheduled for a future date were incorporated into the disaster recovery work to save on construction costs.

Risk Reduction

Planning included efforts to help reduce the risk of a reoccurrence. For example, additional insulation was installed and a new checklist was created for facility personnel to follow when investigating leaks.

Incident Command Officers and Sections

The incident command officers and sections oversaw the ASC disaster response work described above. Additional responsibilities are described below.

Safety Officer

The safety officer performed the following tasks:

  • Daily walkthroughs for interim Life Safety measures, ICRA, and hazard control risk assessment ensuring corrections were made as needed
  • Daily count of narcotics and medication storage security checks

Infection Prevention Officer

The infection prevention officer performed the following tasks:

  • Daily ICRA assessment walkthroughs
  • Ongoing communication with industrial hygienist regarding assessment and safety tests

Public Information Officer

The public information officer performed the following tasks:

  • Issued regular press releases providing updates on repairs
  • Kept website notices and telephone greeting current
  • Developed wayfinding signage and maps
  • Provided weekly briefings with facility employees

Planning and Logistics Section

The planning and logistics section performed the following tasks:

  • Determined staff availability and work assignments
  • Determined staff pay structure during recovery
  • Worked with local hospital to accommodate ASC patients and coordinate ASC staff support
  • Provided hospital with necessary supplies, equipment, and instrument sets to accommodate procedures rescheduled from the ASC
  • Identified replacement items to be ordered immediately due to lag time in ordering and delivery (e.g., cabinets, counters, doors, carpeting)
  • Maintained communication/phone system and information technology (IT)
  • Coordinated re-establishment of services (e.g., housekeeping, waste removal, linen)
  • Maintained “disaster book” of all response activities

Operations Section

The operations section performed the following tasks:

  • Obtained temporary storage for unaffected equipment that required relocation
  • Identified need for replacement equipment and IT
  • Ensured the hard drives of damaged computers were stripped/wiped before disposal
  • Developed risk reduction plans

Finance/Administration Section

The finance/administration section performed the following tasks:

  • Conducted walkthrough with insurance adjustor
  • Compiled all invoices to be paid
  • Tracked lost revenue
  • Provided cost analysis and cash flow data to governing board
  • Provided insurance carrier with all requested information (e.g., projection of business loss amount, list of damages, photos)


The following steps were taken to ensure a successful reopening:

  • Conducted mock patient walkthrough of new space
  • Posted required documentation previously removed (e.g., ASC license, patient rights and responsibilities, HIPAA, accreditation certificate)
  • Reinstated facility logs (e.g., refrigerator temperature, malignant hyperthermia cart check, defibrillator test and cart check)
  • Changed telephone greeting and website notice
  • Issued press release
  • Planned, publicized, and hosted open house
  • Celebrated re-opening and facility’s return to normal operations!

You Can Never Be Too Prepared

As I write this, Hurricane Harvey has wreaked havoc on Texas. Fires are consuming hundreds of thousands of acres across multiple western states. Hurricane Irma has Florida in its crosshairs. There is no shortage of news about the extensive damage that occurs in the wake of these disasters.

On a positive note, there are reports highlighting the improved preparation and response effort thanks to lessons learned from disasters like Hurricane Katrina and Rita. There will undoubtedly be lessons learned from Harvey and Irma that will help with future disaster planning.

Hopefully the Colorado ASC disaster response outlined above helps your surgery center identify opportunities for its own preparation improvement. If your ASC experiences a disaster, I encourage you to share your own response efforts. Relaying your story to an industry publication or presenting on it at a state or national meeting could ensure other ASCs benefit by learning from your experience.

I will leave you with this key takeaway. You cannot plan for everything. However, the more you prepare, the better off you should be when faced with the unexpected.

Diane Lampron, Director of Operations

ASC Emergency Preparedness: Checklist for Compliance

ASC Emergency Preparedness: Checklist for Compliance

By ASC Governance, ASC Management, Leadership No Comments

Disasters come in many forms. They can be natural – a hurricane, tornado, flood, earthquake – or man-made – a chemical spill or cyberattack. While the impact of disasters varies greatly, what ultimately matters is how your ASC responds. An effective response, outlined in an ASC emergency preparedness plan, can protect and save lives, reduce facility damage, and make recovery easier.

Critical to such a response is the development of an ASC emergency preparedness program. I witnessed its value firsthand at a Colorado ASC that suffered a significant disaster in 2015. The ASC’s plan was instrumental in containing the damage, ensuring patients received the care they needed, and expediting repairs.

If your ASC is certified by Medicare, meeting emergency preparedness regulations is a requirement. Centers for Medicare & Medicaid Services (CMS) outlined these regulations in their final rule posted in September 2016. While the regulations went into effect in November 2016, providers and suppliers have until November 15, 2017 to comply with and implement them.

Earlier this year, Pinnacle III published a blog on “What the CMS Emergency Preparedness Rule Means for ASCs.” With the implementation deadline fast approaching, I thought it would be helpful to publish the ASC emergency preparedness program requirements below. They are organized for your convenience with the intent of helping you achieve and maintain compliance.

Your program must include, but is not limited to, the following four elements:

1. ASC Emergency Preparedness Plan

Develop and maintain an ASC emergency preparedness plan. The plan must:

  • Include a risk assessment. The plan should be based on a facility- and community-based risk assessment that employs an all-hazards approach. This approach focuses on capacities and capabilities critical to preparedness for a full spectrum of emergencies or disasters specific to the location of your ASC.
  • Factor in the types of hazards most likely to occur in your area. Take into consideration facility damage, care-related emergencies; equipment and power failures, and communication interruptions, including cyberattacks.
  • Include strategies for addressing emergency events identified in your risk assessment.
  • Address the needs of the patient population, including services your ASC can provide in an emergency.
  • Address continuity of operations, including delegation of authority and succession plans.
  • Include a process for cooperation and collaboration with emergency preparedness officials (e.g., local, regional, state, federal) in their efforts to maintain an integrated emergency response.
  • Include documentation of your ASC’s efforts to contact emergency preparedness officials and participate in collaborative, cooperative planning efforts.
  • Undergo a review and update at least annually.

2. Policies and Procedures

Develop and implement ASC emergency preparedness policies and procedures. Base them on the emergency plan and risk assessment discussed above and communication plan discussed below. Review and update policies and procedures at least annually. At a minimum, policies and procedures must address the following:

  • A system to track the location of on-duty staff and sheltered patients in your care during an emergency. Note: If you relocate on-duty staff or sheltered patients during an emergency, document the name and location of the receiving facility/location.
  • Safe evacuation from your ASC, including consideration of care and treatment needs of evacuees, staff responsibilities, transportation, identification of evacuation location(s), and primary and alternate means of communication with external sources of assistance.
  • Means to shelter in place patients, staff, and volunteers who remain in your ASC.
  • A system of medical documentation that preserves patient information, protects information confidentiality, and secures and maintains records availability.
  • Use of volunteers in an emergency and other staffing strategies, including the process and role for integration of state and federally designated health care professionals, to address surge needs.
  • Your ASC’s role in the provision of care and treatment as an alternate care site identified by emergency management officials, in the event of a waiver declared by the U.S. Health and Human Services Secretary.

3. Communication

Develop and maintain an ASC emergency preparedness communication plan. Review and update the communication plan at least annually. The plan must include the following seven components:

  • Names and contact information for staff, organizations providing services under arrangement, physicians, and volunteers.
  • Contact information for emergency preparedness staff (e.g., federal, state, regional, local) and other sources of assistance.
  • Primary and alternate means for communicating with your staff and emergency management agencies.
  • A method for sharing information and medical documentation for your patients with other providers to maintain continuity of care.
  • An appropriate means to release patient information in the event of an evacuation.
  • An appropriate means of providing information about the general condition and location of patients under your care.
  • A means of providing information about your ASC’s needs and its ability to provide assistance to the appropriate authority.

4. Training and Testing

Develop and maintain an ASC emergency preparedness training and testing program based on the emergency plan, risk assessment, policies and procedures, and the communication plan discussed above. Review and update the training and testing program at least annually.

With regard to training, your ASC must:

  • Provide initial training in emergency preparedness policies and procedures to all staff, individuals providing on-site services, and volunteers (consistent with their expected roles).
  • Provide emergency preparedness training at least annually.
  • Maintain documentation of all training.
  • Demonstrate staff knowledge of emergency procedures.

To meet the testing requirements, your ASC must conduct at least two exercises annually to test its emergency plan. You must:

  • Participate in a full-scale community-based exercise. If a community-based exercise is not accessible, participate in an individual, facility-based exercise. Note: If your ASC experiences a natural or man-made emergency requiring activation of your emergency plan, you are exempt from engaging in an exercise for one year following the onset of the event.
  • Conduct an additional facility-based exercise. This can be another individual, full-scale exercise or a tabletop exercise that includes a group discussion.
  • Analyze your response to and maintain documentation of all drills, tabletop exercises, and emergency events.
  • Identify and implement improvement opportunities, revising the emergency plan as needed.

Note: If your ASC is part of an integrated health care system with a unified and integrated emergency preparedness program, you may choose to participate in the system’s coordinated program. If you do so, there are additional requirements your ASC must meet. Review the CMS final rule to identify those requirements.

Quick Tips

To achieve compliance, follow the steps provided above. Some tips that will further assist you in your emergency preparation efforts are:

  • Designate an incident commander. This individual is responsible for the overall management of the emergency response.
  • Pre-assign other incident command roles. This could include a deputy incident commander whose responsibilities include filling the incident commander role in the event the incident commander is not on-site during the emergency. It could also include command staff (e.g., public information officer, safety officer, liaison officer) and general staff (e.g., operations, planning, logistics, finance/administration).
  • Make sure your ASC has the appropriate insurance and coverage for the emergencies and disasters you are likely to face.
  • If financial, patient, and other data is stored on-site, plan for how you will protect servers and other critical information technology.
  • Consider any “what ifs.” If there is something you think could happen during an emergency, plan for it.

Improving Your Emergency Preparedness Program

Development of an ASC emergency preparedness program can help a center achieve a more successful response to a disaster. But disasters are unpredictable. An ASC emergency preparedness program can only account for so much. That’s why it is critical to take advantage of every exercise to identify areas of your plan to revise and improve.

It’s also valuable to study how other health care providers responded to actual disasters. Doing so provides an opportunity to incorporate tried-and-tested processes and practices into your plan. In an upcoming blog, I will share many of the steps the Colorado ASC I mentioned took in response to its disaster. By doing so, I hope to help your ASC prepare for what you may face one day.

Diane Lampron, Director of Operations

We all Wear Many Hats – An ASC Staffing Guide

We all Wear Many Hats – An ASC Staffing Guide

By ASC Management, Leadership No Comments

Ambulatory surgery centers (ASCs) are cost effective because they employ a highly efficient staffing model. In addition to traditional roles various employees and departments perform, ASC administrators and facility staff assume other non-traditional responsibilities. Every staff member wears many hats on any given day. When hiring ASC personnel, it is imperative to outline for candidates all the duties expected of them, many of which often go beyond solely providing direct patient care. ASC leaders know staffing a surgery center requires flexibility and careful consideration.

How do you devise a staffing plan that incorporates the multiple roles staff will be expected to perform while ensuring your facility remains cost effective and efficient? In this post, we highlight some of the diverse functions your surgery center staff perform to help you visualize a plan for effectively allocating your ASC’s operational responsibilities among them.


A registered nurse is typically solely responsible for patient care. However, in an ASC, one or more nurses may also be tasked with facility infection prevention and/or monitoring the center’s adherence to the infection control program. Ensuring nurses complete infection control duties requires building sufficient time into the schedule. Infection control may occur during non-clinical hours, on slower days when the schedule permits, or by scheduling an extra nurse on certain days to allow infection control tasks to be routinely completed.

Surgical Technician.

A surgical technician takes charge of preparing operating rooms, ensuring all the necessary equipment is prepped and assembled. Due to the nature of their role, your ASC’s surgical technician may also function as your materials coordinator. Organization and prioritization are paramount for this dual role. As materials coordinator, the surgical technician will need to order supplies, check on special orders, receive products, document purchases, account for shipments received, and remain on hand to cover procedures. Specific ordering days can be established to ensure supplies are effectively managed. Consider adding an additional staff member on ordering days, or scheduling ordering on slower procedure days. Other team members may also assist with putting away received supplies and restocking supply areas.

Nurse Manager.

A nurse manager is expected to contribute to direct patient care while also attending to their administrative duties. A facility’s nurse manager typically maintains managerial authority over the entire clinical staff. As the title suggests, the nurse manager needs to possess expertise in both clinical and administrative duties, including direct patient care and staff management, respectively. An effective nurse manager is organized and competently harnesses the assistance of facility personnel to accomplish daily, monthly, quarterly, bi-annual, and annual tasks.

A clinical nurse manager can help alleviate some of the administrator’s burden by handling the administrative and hiring responsibilities of clinical staff, as well as monitoring the use of implants and corresponding reimbursement. This delegation works particularly well because nurse managers are often in close conversation with physicians where they can adeptly advocate for the use of more cost-effective implants. Train these leaders to manage their staff members and implants, and to operate with autonomy.

Clinical Staff.

There are many other roles your clinical staff will be expected to perform in addition to their direct patient care duties. Quality assessment and control, managing safety protocols, pharmacy ordering, and data input are a few examples. The person responsible for quality assessment and control will need allocated time to run reports, conduct research, compile items for meetings, assist with staff education, etc. The safety officer will need to conduct audits, assist with staff education, and compile items for meetings, among other tasks. Clinical staff must fulfill many important roles. They can accomplish smaller tasks between patients or as the schedule starts to slow down.

Front Office Personnel.

These employees wear multiple hats every day and many times in a day. They can be responsible for reception, registration, medical records, scheduling, verification and authorization of benefits, and patient collections. They may perform some HR functions assisting the administrator with onboarding, benefits administration, personnel file maintenance, and payroll. The unique skills they possess should not be overlooked when special projects or mini-task force committees arise.

The size of your facility and the processes you put into place will determine how many hats you need and who will wear them. Try to allocate tasks based on employee strengths.

Make a list of the crucial roles, then designate each role to a specific title (e.g., RN). Doing so will help you identify what type of person you may need to hire or move into each role.

Hire personnel who are willing to function in multiple roles. Understand this multiple role mindset may be a departure from an employee’s previous environment. Set expectations accordingly.

Incorporate time to achieve these multiple roles into your staffing schedule. Take advantage of low volume times. Set aside staffing time for special tasks/projects. Use flexible hours to effectively staff for projects and clinical time on the floor.

To employ the use of an efficient flexible staffing ASC model, ASC administrators and leadership teams must ensure staff have comprehensive job descriptions with clearly defined responsibilities that collectively cover the entirety of an ASC’s operational responsibilities.

These steps will help unleash the power of your ASC team.

Kelli McMahan, Vice President of Operations

Leadership Defined – Best Qualities of an ASC Leader

Leadership Defined – Best Qualities of an ASC Leader

By ASC Management, Leadership No Comments

Jennifer Post’s article, 11 Ways to Define Leadership, published in the leadership section of Business News Daily on March 29, 2017, listed qualities of highly effective leaders alongside relevant quotes from current leaders and business founders. I found many of the viewpoints on the definition of leadership useful for the ambulatory surgery center (ASC) industry. The author’s main point also struck a chord. She maintains leadership is subjective, but its foundation is formed from one thing – the ability to build consensus and establish a following among individuals and teams.

I have been fortunate to learn from highly effective ASC leaders. Those I admire possess a variety of styles, but at the core, they all build momentum around common clinical and business-related goals.

In evaluating the day-to-day behaviors of these effective surgery center leaders, I identified the things they did that were most inspiring to me. I paired each tenet of a good leader with relevant quotes on leadership from Ms. Post’s article. I created the following as a guide for myself in hopes I can integrate these leadership traits into my daily interactions with my surgery center teams.

Step 1: Care

Leadership is about people serving people, inspiring people, and caring about people. You must show you care through your daily actions.

Our surgery centers often lean on staff to be excellent in a fast-paced environment, which is what we are known for. However, this can leave staff feeling the pressure to keep up. It is important to provide our presence, support, education, and creative tools so staff feel equipped to deal with the day-to-day operations of their departments.

“Leadership is serving the people that work for you by giving them the tools they need to succeed . . . [Team members] should be looking forward to the customer and not backwards, over their shoulders, at you . . . [Give] genuine praise for what goes well and lead by sharing in the responsibility early and immediately if things go bad.” –Jordan French, founding CMO, BeeHex, Inc. 3D Food Printing

Step 2: Communicate

When a leader does not communicate well, team members don’t feel valued. Good communication involves listening, truly understanding, and respecting others’ opinions. ASC staff members must be critical thinkers and doers. Impromptu conversations with staff member about problems in the center can result in some of the best ideas to resolve them. This requires leaders to have conversations, ask for input, listen, and think before throwing out an idea.

“Any time you work with a group you should expect disagreement. You should embrace dissent. Teamwork isn’t about going along. It’s about hearing all views, admitting mistakes, and sharing risks and rewards jointly.” – Gary Kelly, CEO, Southwest Airlines

“In my experience, leadership is about three things: to listen, to inspire and to empower. Over the years, I’ve tried to learn to do a much better job of listening actively making sure I really understand the other person’s point of view, learning from them, and using that basis of trust and collaboration to inspire and empower.” –Larry Garfield, president, Garfield Group

Step 3: Have Character

Over-prepare, admit weaknesses, and allow others to assist you. This builds a culture where team members feel valued and fulfilled.

“Adversity does not build character, it reveals it.” –James Lane Allen, novelist

“Leadership is the ability to see a problem and be the solution. So many people are willing to talk about problems or can even empathize, but not many can see the problem or challenge and rise to it. It takes a leader to truly see a problem as a challenge and want to drive toward it.” –Andrea Walker-Leidy, owner, Walker Publicity Consulting

Step 4: Be Competent

Effective leaders know their business and their team. A competent leader is reflected in a competent team. Encourage and help your team gain certifications or specialized training that will make your facility better by providing staff members with gratification and betterment of themselves. Promote from within your organization to your leadership roles. Create your own OR nurses using peri-op 101. Hire clinical directors with the intent of nurturing them in ways that will allows them to assume administrator roles.

“To me, leadership is about playing to strengths and addressing weaknesses in the most productive and efficient way possible. It’s about knowing your team and yourself, and doing your best job to set both up for success.” –Samantha Cohen, co-founder, Neon Bandits

Step 5: Have Courage

As many times as things go right, they go wrong. Leaders need to be the ones sitting in front of a board owning up to mistakes made. However, if a leader can take the situation, apply corrections, and discuss that process, blame is removed so the problem can be fully dissected. If we look at every issue as a potential opportunity to prevent its recurrence, people stop avoiding the issues.

“A leader is someone who has the clarity to know the right things to do, the confidence to know when she’s wrong, and the courage to do the right things even when they’re hard.” –Darcy Eikenberg, founder,

Every leader has his or her own style and strategy, and every company its unique challenges. Recruiting and retaining talent in healthcare is a financial and intellectual investment. Effective leadership helps ensure we get the most out of the time and money we spend finding and training team members, because effective leaders build and retain top talent.

“There is no one-size-fits-all approach, answer key or formula to leadership. Leadership should be the humble, authentic expression of your unique personality in pursuit of bettering whatever environment you are in.” –Katie Christy, founder, Activate Your Talent

Jovanna Grissom, Vice President of Operations

1Business News Daily article March 29, 2017 11 Ways to Define Leadership

Managing difficult employee behavior

Help! My Employees are Keeping Me Awake at Night!

By ASC Management, Leadership No Comments

Lately, when faced with a work situation that taxes my emotional reserve and keeps me awake at night, I turn it on its head. I view the issue from a different perspective; change the tape that’s repeatedly playing in my brain by altering the order of the words.

For example, when I hear, “I’ve got a difficult employee and I don’t have a clue what to do,” I reframe the problem and respond with, “Let’s talk about the difficult behavior this person is exhibiting that is creating frustration for you in the workplace.” Shifting our dialogue to focus on the behavior rather than the person, creates a much-needed level of objectivity that allows for more effective problem solving.

Let’s face it, as leaders, we are bound to encounter employees who exhibit behaviors that are difficult to manage. An employee who simply fails to show up to work on time can create havoc in a facility. Being met with resistance when asked to perform a task in a specific way can derail a surgery center team’s attempts to ensure patient safety.

If you’re like most people, you don’t enjoy confrontation. So, you chalk the behavior up to “a bad day” or, when the behavior rears its ugly head consistently, excuse it with, “That’s just how Marianne operates. She’s not interested in hearing feedback.” But, it’s your job to deal with these behaviors effectively to minimize the ripple effects. The harsh reality is, if you don’t deal with difficult behaviors, the problems will only get worse. And, if you don’t document your actions, it is as if you never responded.

When you find yourself wondering why an employee is being so difficult, avoid succumbing to “stinkin’ thinkin’.” In other words, avoid personalizing the behavior.

Here’s an example. Tom, your receptionist/registrar, reports to the surgery center 10 to 15 minutes late every morning. He is responsible for checking patients in promptly. If he’s not there, patients either end up waiting for him to arrive or his co-workers must stop what they’re doing to perform his job. This is annoying enough on its own. But he has the nerve to saunter in with a Starbucks coffee in hand, jovially greeting everyone on the way to his workstation. The patients love him. They have no idea he’s the one who created the tension they sensed upon their arrival. As he settles into work, capably completing the tasks his co-workers have started for him, you overhear a steady stream of employees filing past your office muttering, “Really? He does this every day. Why does he insist on making everyone miserable? I’m tired of doing his job. Doesn’t he recognize we’ve got our own tasks to perform to ensure surgeries start on time?”

Tom, contrary to what is now popular belief, likely does not wake up every morning planning to upset everyone. He’s laid back – a strong suit when it comes to interacting with patients nervously anticipating their planned procedure – and approaches everything in stride, including sleeping through his alarm, a long line at Starbucks, and having to circle the parking lot three times to find an empty spot.

To deal effectively with Tom’s tardiness, it’s important to accurately identify the problem behavior. On the surface, it might appear the problem is slacking – showing up late because Tom wants others to perform his job. After all, that’s what his co-workers have surmised. However, after talking with Tom, you realize he is on a completely different wavelength. He truly is unaware his behavior negatively impacts the start of everyone else’s day.

Now that you’ve identified the true difficulty, you can effectively manage Tom’s future behavior by having a conversation with him. People who are on a different wavelength, need clearly defined communication that outlines expected results.

Your conversation may proceed along these lines. “Tom, I need you to be at your workstation ready to check in our first patient on time each morning. I expect you to clock in at 5:45, then immediately report to your desk to ensure you are prepared for 6:00 a.m. arrivals. Adhering to this regimen will serve our patients well. The value you bring to our organization will be enhanced when your co-workers realize they can rely on you to greet patients and get them checked in promptly. Our physicians will recognize a change in how quickly they are able to get started each morning. I’m going to document our conversation today as a coaching session. Now that you recognize how important it is for you to be on time to perform an essential requirement of your job, I’m confident you will figure out how to report to work promptly every day.”

I recognize this is only one example of dealing with a difficult behavior. And, more importantly, I’ve assumed the conversation went well. You talked to Tom, he saw the light, he altered his behavior, and being late to work is not something that occurs anymore. I’m aware, however, that’s not always the case.

My point is this: when you separate the person from the behavior, accurately identify the problem, and promptly address with the employee how their behavior impacts the organization, you have a much greater chance of achieving a successful outcome. Those successful outcomes will not only lead to a happier, more united facility, they will allow you to sleep much better at night!

Kim Woodruff, VP of Corporate Finance & Compliance