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Ambulatory Surgery Center Archives - Page 4 of 7 - Pinnacle III

Mar 15
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Hiring an ASC Clinical Director

Hiring an ASC Clinical Director

By ASC Development, ASC Management, Leadership No Comments

Recently I took some time to reflect on what I’m grateful for. The long list I came up with included my ASC clinical director.

Our clinical director does a lot for our center. She certainly makes my job as administrator easier. Concerns have never been raised about her work ethic and performance. I wouldn’t think twice about leaving the ASC under her command for an extended period of time. I know that, if an issue arises, she can effectively address it or find the resources to do so. You can’t put a price tag on that peace of mind.

An ASC clinical director is a highly important function within the facility. Finding the right person for this role can be difficult. The clinical director must possess a variety of qualifications related to both clinical and business operations. To find the optimal clinical director for your ASC, I have listed characteristics to hone in on during your search.

Clinical Director Characteristics

Several characteristics clinical directors should possess to help them succeed in their role are outlined below.

Relevant clinical background. The clinical director should have a solid understanding of their center’s specialty(ies). For example, at an endoscopy center such as ours, our clinical director’s gastroenterology background is valuable. If you work in a multi-specialty center, the clinical director should possess a broad surgical and PACU background.

The appropriate clinical background allows the clinical director to:

  • Understand the roles and responsibilities of their staff;
  • Fill in for clinical staff members if someone calls in sick or needs to take a break;
  • Understand how to meet the needs and requirements of physicians in their respective specialties;
  • Earn respect from staff and physicians because of a demonstrated knowledge and experience with the specialty(ies);
  • Support the delivery of high-quality care; and
  • Help the center meet accreditation and regulatory requirements.

Eagerness to learn. ASC clinical directors typically work their way into the position by ascending the ranks of the clinical staff. Clinical directors often do not possess a strong business background as they move into this leadership position. To perform successfully as a clinical director, though, one must understand the business side of running an ASC. This includes budgeting, expense monitoring, and third-party payer contracting and reimbursement.

A clinical director must embrace learning. Your ASC will benefit as your clinical director learns the ASC business and incorporates new knowledge into his or her approach to clinical responsibilities. A clinical director who is motivated to go outside of his or her comfort zone in the learning process contributes to the ASC’s success and is worth his or her weight in gold.

Responsiveness. ASC clinical directors should be responsive to their physicians and staff. They must know how to recognize when issues are developing, such as a dissatisfied physician or poorly performing staff member. They must also know how to deal with these issues in a timely fashion to avoid them becoming more significant problems.

For example, a clinical director should recognize when a physician is becoming busier and adding cases. Such a development touches on many aspects of an ASC’s operations. It may require hiring more staff, allocating more block time, and/or purchasing more supplies. The clinical director is not expected to address these potential developments independently. Rather, they may research the development and speak with other members of the ASC team about actions to effectively accommodate the growth.

Proactiveness. Strong clinical directors can foresee future challenges and know how to act in advance. When a clinical director is new to the position, these challenges may primarily be clinical in nature. The longer the clinical director is in the position, the more he or she should consider business and operational issues as well.

Effective communicator. Clinical directors should be strong communicators, an important ability for effective leaders. They must know how to engage in clear communication with everyone in the center, including physicians, staff, vendors, patients and their families.

Remember, effective communication is a two-way street. A clinical director should feel comfortable approaching others and promote an environment where others feel comfortable approaching the clinical director.

Giving Thanks for My Clinical Director

Our center recently went through an unannounced CMS survey. We were understandably stressed when it occurred, but no one panicked. The staff performed their job duties and provided the high-quality care that they do every day of the year. The physicians expressed complete confidence in the performance of the staff and the leadership of the clinical director. We passed the survey with no deficiencies.

This experience demonstrates how well our clinical director performs. ASCs typically have a small group of physician owners. The physician owners are likely to be critical of the clinical director because it is a clinical role. A successful ASC needs its physician owners to be confident in the clinical director’s leadership and ability to help run the center. If staff members feel the same way, employee turnover rates tend to be low. When staff members like their leaders and work environment, they’re not going to leave.

Patients notice this dynamic. They often comment, “You all seem to like your jobs and have fun here.” That speaks to how the center is managed and how ASC staff members feel about their culture and work environment. Much of this hinges on the presence of a strong clinical director.

Catherine Sayers, Director of Operations

Feb 28
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Teamwork Can Become Your ASC’s Organizational Norm

Teamwork Can Become Your ASC’s Organizational Norm

By ASC Management, Leadership No Comments

Is teamwork the norm in your ambulatory surgery center? If the answer is yes, you are ahead of the curve.

Most organizations struggle to develop and foster an environment in which true teamwork can flourish. However, organizations successful in fostering a team-oriented environment see many benefits in the lives, and output, of their workforce. An organizational norm of teamwork fosters creativity & learning, builds trust, develops conflict resolution skills, blends complementary strengths, promotes a wider sense of ownership, and encourages healthy risk-taking.[1]

In the book, High Five! The Magic of Working Together, the authors assert, “Fostering teamwork is creating a work culture that values collaboration. In a teamwork environment, people understand and believe that thinking, planning, decisions, and actions are better when done cooperatively. People recognize, and even assimilate, the belief that ‘none of us is as good as all of us.'”[2]

Why is developing a culture of teamwork such a struggle?

Our schools, family structures, and many of our pastimes emphasize winning and individual achievement over collaborative accomplishments. Some of us are raised in environments that do not teach or value collaboration. Instead, we learn early to be the first and the best.

As we mature and begin our careers, this pattern continues. It is not uncommon for workplace rewards and promotions to be directly tied to individual performance. The system of rewards at work often reinforces self-reliance. Instead of working collaboratively with colleagues who are specialists in their respective fields, we strive to grow our own breadth of knowledge to increase our ability to do all things by ourselves.

How can you create an environment in which teamwork and collaboration are your norm?

Clearly communicate teamwork and collaboration are expected. Model teamwork in your interactions with each member of your ASC. Talk about and identify the value of a teamwork culture in meetings. Make teamwork a core value of your surgery center. Advertise it in places easily seen and identifiable by all. Emphasize that being a team player is a strength. Hire individuals who are team-oriented.

Maintain a culture of teamwork even when things are going wrong. Resist the temptation to blame individuals. Instead, focus on how the team can resolve issues that arise. This allows your team the freedom to make decisions without fear of making a mistake and being reprimanded.

As you transform your staff into a collaborative team, recognize and reward teamwork actions along the way. Consider how to focus compensation, bonuses, and recognition on collaborative practices as well as individual contribution and achievements. One avenue for teamwork recognition is sharing important stories that emphasize teamwork during regular team meetings. For example, “Remember when our Pre-Op/PACU nursing staff worked together to conduct a pre-survey prior to our most recent state accreditation survey? They found 5 areas where we needed to improve processes to maintain compliance with regulations. But they didn’t stop there. They executed the necessary process improvements. Let’s all applaud our Pre-Op/PACU nursing staff members. They diligently worked together to get ready for that survey and contributed favorably to our success.”

How do you maintain teamwork and collaboration?

As you focus on and implement teamwork, you will recognize the need for team building activities. Traditionally, organizations approached team building as a trip to a resort, playing games, or some other type of break from the workplace. Then they wondered why the sense of teamwork at their one-day outing failed to make its way back to the workplace. To gain the most from your efforts to build teamwork, consider more regular, fun, shared occasions for team building. Potlucks, local sporting events, or even local dinners are all good options.

Consider challenging your staff with a project that requires working together collaboratively to achieve a desired objective. Before doing so, however, provide training and tools to team members on communication and setting team standards. This will allow them to focus most of their energy on the assigned project and less effort on figuring out how to work together as a team.

Use ice breakers and teamwork exercises at meetings. While these activities are short in duration and cost little to implement, they help teams get to know one another and often result in a healthy dose of laughter.

Celebrating Team Culture

Ask ASC leaders to publicly recognize teams for their successes and offer team members opportunities to recognize their peers for major contributions to the team. Receiving recognition makes the feeling of team success even sweeter, and worth repeating.

Effective teamwork not only promotes creativity, learning, and innovation, but also encourages team members to perform at their highest potential. When team members are working together at their highest potential, their efforts are multiplied. Your organization benefits exponentially. Once teamwork is established as an organizational norm, trust amongst colleagues and workplace satisfaction are fostered, contributing to a general sense of good will in your ASC.

Jovanna Grissom, VP of Operations

[1] https://www.sandler.com/blog/6-benefits-of-teamwork-in-the-workplace

[2] High Five! The Magic of Working Together, by Kenneth V. Blanchard, Sheldon Bowles, Others, 2000, New York: HarperCollins Publishers Inc. Copyright (2001) by Blanchard Family Partnership and Ode to Joy limited.

 

Feb 21
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Matchmaker, Matchmaker: Finding the "Perfect" Surgery Center Team

Matchmaker, Matchmaker: Finding the “Perfect” Surgery Center Team

By ASC Development, ASC Management, Leadership No Comments

In the classic “Fiddler on the Roof” song “Matchmaker, Matchmaker,” Tevye and Golde’s daughters sing about a matchmaker finding husbands for them. The lyrics include the following line: “Matchmaker, matchmaker, look through your book, and make me a perfect match.” When tasked with building a new surgery center team, I play the matchmaker role.

My “book” is comprised of information on job seekers – a collection of resumes/CVs, interview notes, and insight from the candidates’ references. With this information, the pressure is on me to accomplish what those daughters ask for – perfect matches. I cannot simply choose who I think is the best clinical director, administrator, materials coordinator, operating room nurse, recovery nurse, and business office person on paper. These selections cannot happen in a bubble. Instead, I must do my best to ensure this initial set of team members will work well together. They will jointly create the desired culture for the ASC. And they will instill this culture in the staff members hired and trained after them, helping attract more likeminded individuals.

There’s a lot of pressure to get these initial hires right. I hope they will remain with the ASC for years, forming the foundation for the facility. When building a surgery center team, I focus on the following to increase the likelihood that I make the correct selections.

Ownership Expectations

During meetings with the ASC’s owners, I seek first to understand their expectations of the new facility. What does their optimal surgery center team look like? How do they envision the facility’s culture? What type of employees are they looking for to support that culture?

When PINNACLE III is the manager of the facility, I factor in our culture expectations as well. Defining an ASC’s culture isn’t easy. In my experience, if I take the time to understand expectations, I’ll gain the insight required to create the anticipated culture. In an ASC, it will likely include expectations of delivering the highest quality care via a skilled, efficient team who perform their respective roles with integrity.

Surgery Center Team Interviews

A resume or CV tells me about a prospective employee’s background. That background information is important – I want to hire competent, qualified staff. However, resume review is not the most important step in the hiring process. Candidates can appear quite impressive on paper but fall short of expectations in person. The interview process is the best opportunity to assess whether candidates fit the mold for the new surgery center team.

My interview questions aim to accomplish several objectives. I dig deep to truly understand how an interviewee will work for the ASC. My focus isn’t just be on short-term performance but the candidate’s potential longevity and adaptability as the center grows. What are their values? Do they place importance on honesty and integrity? Are they lifelong learners? How do they envision positively impacting the business? I’m looking for positive signs as well as potential warning signs.

I inquire about their previous employer’s culture. Coming from an organization with a different culture than the new ASC isn’t necessarily problematic. Depending upon the situation, it’s important to recognize that I may need to do a little work to address the effects of that culture, particularly if the candidate was not valued in their previous work setting.

I like to ask interviewees how they would act when faced with difficult situations I’ve witnessed firsthand in ASCs. For example, what would they do if they encountered a disruptive physician? What if the narcotic count was off at day’s end? What if a daily deposit didn’t match the books? I want to obtain an understanding of how they are going to respond during stressful events.

These types of questions serve two purposes, First, I hope their responses give me confidence that they will act responsibly. Second, I learn if they will respond differently than I would in a similar situation. If they turn out to be the right fit for the surgery center team, I have identified an area where this person may require some guidance.

My Presentation

When interviewing job candidates, I am typically the first, personal representation of the ASC. I am the face of its culture or, in the case of a new or developing ASC, its desired culture. I am likely all the candidates know of the surgery center team. If I want the ability to hire the candidates I determine are right for the ASC, I need to ensure these candidates view the ASC as a good fit as well.

With the low unemployment rate, health care professionals typically have at least a few, if not many, job options. Hiring is a two-way street. I need to ensure the way I present during the interview process reflects the way I want the ASC to be perceived. I believe it’s best to be clear and concise when interviewing. If I adopt an overly laid-back approach, I risk alienating individuals looking for structure. More laid-back candidates will still appreciate the professional manner through which I conducted their interview.

Achieving Surgery Center Team “Perfection”

While finding “perfect” matches may prove difficult, I want to come as close as possible with my initial hires. I would rather hold off on filling a position than make a “bad” hire. With bad hires, I often spend extra time and effort bringing them on, only to lose them after a short period. In a worst-case scenario, a bad hire can create untoward results in the ASC’s culture – gossiping, not focusing on personalized service, or not treating physicians as customers, for example.

That’s why the key for me is never to hire out of desperation. There’s no better way to find an imperfect match. Remember: When playing matchmaker for an ASC, the task is finding matches for the owners, other staff, and patients. And like that of a matchmaker, this is a responsibility not to be taken lightly.

Lisa Austin, VP of Facility Development

Feb 15
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Addressing Patient Requests for Charity Care or Financial Hardship at Your ASC

Addressing Patient Requests for Charity Care or Financial Hardship at Your ASC

By ASC Management, Payor Contracting, Revenue Cycle Management No Comments

As insurance plans continue to shift more of the financial burden of health care to patient, providers receive more requests for charity care or financial assistance. Health care services have become unaffordable for many, forcing some patients to avoid necessary treatment if they do not receive substantial financial discounts.

Does your ASC have a process in place to address the rise in patient co-pays and deductibles, and the growing need for charity care?

One option for dealing with patient payments is to waive co-pays or deductibles to avoid the process altogether. Such a tactic, however, could lead you straight into legal issues related to the False Claims Act, Anti-Kickback Statutes, and non-compliance with managed care agreements. Additionally, there are state specific laws addressing waiver of co-payments and deductibles. The best response is to develop sound financial hardship and charity care policies to help you legally and consistently navigate these waters.

What is the difference between charity care and financial hardship?

There are no formal definitions for charity care or financial hardship. Health care entities use a variety of terms including, but not limited to, uncompensated care, charity assistance, and bad debt. In Pinnacle III’s managed facilities, we have established distinct definitions to minimize confusion and enhance communication.

Charity care is free care. The patient simply has little to no means to pay for needed medical services. The benchmark for receiving charity care is typically set using family income between 100% and 400% of the Federal Poverty Level (FPL). A chart with percentages of the poverty guidelines listing yearly and monthly levels can be found online.[1] The U.S. Department of Health and Human Services releases U.S. Federal Poverty Guidelines which are updated every year using Census Bureau data. The current data can be found online.[2] If you choose to use this method, make sure you update your policy annually when the new guidelines are released.

Work with your Board of Directors to determine what poverty level you will use to grant a charity care service. You may want to consider a sliding scale as listed below; however, charity care is typically “free.”

An example of a sliding scale is:

Below 250% of FPL: 100% charity care
Between 251%-300% FPL: 75% discounted care
Between 301%-400% FPL: 60% discounted care

If you choose to implement a sliding scale, keep your procedure costs in mind. Set your lowest discounted rate at or slightly above Medicare reimbursement which should allow you to break even on the services being provided.

Some ASC’s establish a “Charity Care Day” for a set number of patients who have cleared the Center’s approval process. On this day the providers, staff, and even some vendors donate their time and/or resources for the charity care surgical cases. This practice demonstrates significant commitment to the Center’s community. Share with the local newspapers or launch a public relations effort to alert your community to your initiative to help those in need.

While charity care is “free,” financial hardship is a request for discounted care. Some of the other terms used to describe financial hardship are economic burden, economic hardship, financial burden, financial distress, and financial stress. Being under-insured, having no insurance, and increasing medical costs are situations that contribute to financial hardship. When reviewing a financial hardship request, it is essential to have patients substantiate their financial need. In some cases, patients with insurance who choose not to file their claim with the insurance company, may not be eligible for your financial hardship program. Ensure your board clearly defines your facility’s financial hardship parameters.

Creating a Policy

Both charity care and financial hardship requests should go through an application process. Assign a financial counselor, or someone in your facility who handles financial discussions with patients, to guide them through your process and move completed applications along for consideration and approval.

Consider the following when setting up your financial hardship and charity care policies:

  1. Create an application form for the current episode of care.
    1. Require a new application and proof of hardship for future care.
  2. Be precise about the documentation needed to support the request.
    1. Tax returns
    2. W-2s
    3. Bank statements
    4. Proof of unemployment
    5. Alimony, child support, etc.
    6. All sources of income
  3. Reject incomplete applications.
  4. Consider all financial resources available to the patient.
  5. Provide available options to patients upfront.
    1. Payment plans
    2. Low cost health care loans
  6. Establish timeline for review and approval.
  7. Determine notification process of approval or denial – letter or phone call?
  8. Maintain the confidentiality of the data received with the application. Ensure bank account details, social security numbers, etc. are redacted (or partially redacted) to prevent this information from falling into the wrong hands.
  9. Make the process known to your patients who apply and ensure staff consistently follow it.
    1. Educate your staff on policy guidelines, timeliness of the process, etc.
    2. Consistently apply the process to each individual patient to avoid claims of discrimination.

Once your policies are created, consult your attorney to ensure you have appropriately addressed any risks and you are following state laws.

Unforeseen circumstances arise at the worst times. Having sound policies to review financial hardship and charity care requests will help you compassionately work with your patients while protecting your ASC’s bottom line.

[1] US Department of Health & Human Services; Office of the Assistant Secretary for Planning and Evaluation, Resources, A chart with percentages (e.g. 125 percent) of the guidelines

[2] US Department of Health & Human Services; Office of the Assistant Secretary for Planning and Evaluation, Poverty Guidelines

Carol Ciluffo, VP of Revenue Cycle Management

Feb 08
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Running an Effective ASC Board Meeting: Lessons I've Learned

Running an Effective ASC Board Meeting: Lessons I’ve Learned

By ASC Governance, ASC Management, Leadership No Comments

Board meetings are critical to an ASC’s ongoing and long-term success. They designate time to address regulatory issues required to maintain compliance. They serve as an opportunity for leaders to make important financial and strategic planning decisions. An ASC board meeting also allows leadership to address problems or areas in need of improvement.

In my 10-plus years serving as a surgery center administrator, I’ve run my fair share of board meetings. Regardless of how each board meeting turns out, I strive to learn something to help the next meeting go smoother.

Guidance for Conducting a Better ASC Board Meeting

Here are some of the key lessons I’ve learned over the years.

  1. No established rules. There are no firm guidelines for running an ASC board meeting. In fact, board meetings do not need to be formal. What matters is finding a format and approach that allows you to accomplish what’s necessary in the time available.
  2. Get to know your board. Learn about your board members; specifically, what they want to get out of board meetings. Using this information, adapt your approach to cater to these needs.
  3. Be consistent. Once you develop a format that works well for your board meeting, stick with it. This serves several purposes. A template will make developing agendas easier and help ensure you do not omit important topics from one meeting to the next. It will also help focus the meeting – board members will know when certain agenda items are up for discussion. If time is consistently allocated to specific topics, board members are less likely to push for earlier discussion on an issue.
  4. Take command. As the individual running the board meeting, you play a major role in determining the meeting’s effectiveness. Talkative or strongly opinionated board members have the potential to hijack a meeting. Maintain control and keep the meeting on task.
  5. Allow for discussion. Build in time for some discussion of key issues in every board meeting. The key word here is “some.” Most meetings last 60 to 90 minutes. A mere 15-minute discussion will eat up a large percentage of that time. Keep discussions short and focused so you can move through the agenda. If an issue requires lengthy discussion, designate a time following the meeting for interested individuals to continue their conversation.
  6. Focus on key items. Going into an ASC board meeting, know which issues are the most important and make sure to cover them. Good preparation and organization of information will help ensure efficient use of the available time. If you plan to provide details, make sure they are critical to the discussion and any decisions. Do not dive so far into details that you take time away from other key issues.
  7. Keep it high level. When weighing what details to provide, such as financial or quality data, keep in mind that most boards look for a high-level perspective. This would include what’s going right or wrong within the ASC and your recommendation on next steps (more on this below). A high-level perspective typically works well for most topics unless one requires deeper discussion because of its urgency or seriousness.
  8. Come up with solutions. If your agenda includes the sharing of shortfalls or areas of concern, be prepared to outline plans for correction. You want board members to leave the meeting feeling confident that you are already working to address any problems.
  9. Make decisions easier. Agenda items that require board members to vote on an issue or make a decision can quickly derail a meeting. If one board member shares an opinion, others are likely to share their thoughts as well. This can quickly turn into a lengthy, possibly heated, discussion. Avoid this scenario by steering members away from unnecessary confrontations. Rather than asking board members what they think the ASC should do, provide options to choose from. Share your recommendation, with a short explanation of your reasoning. The board may still want to engage in a discussion, but providing a few options rather than presenting an open-ended question should help bring about a faster decision.
  10. Be upfront with bad news. If you have bad news to share or anticipate needing to discuss a difficult subject, don’t shock board members by using the meeting as the first time you present this information. Provide board members with a heads-up that the meeting agenda will include the concerning topic. Make sure the board president is aware of the matter and, when possible, to discuss the issue prior to the meeting. If the matter affects specific board members, hold conversations with them in advance.

Bonus Tips for a Successful ASC Board Meeting

Here are a few additional pieces of advice to help you lead constructive meetings:

  • Efficiency is important, but poor preparation can quickly overshadow its significance. If you don’t present ideas in an organized manner, the board may perceive you as less efficient and knowledgeable.
  • When you don’t know the answer to a question, admit it. You’re better off being transparent than trying to appear knowledgeable about an issue when you simply are not. If the information provided turns out to be incorrect, the board is likely to lose confidence in you. Rather, take the time to research the information and provide a correct response. By taking this approach, when you say you know the answer to a question, board members will trust you.

Considering the infrequency of board meetings – with many ASCs only holding them quarterly – every minute of every meeting is of the utmost importance. To run your next ASC board meeting more effectively and productively, prepare fully and take total advantage of the time allotted.

Diane Lampron, Director of Operations

Feb 01
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Why a Strategic Plan is a Good Idea for Your ASC

Why a Strategic Plan is a Good Idea for Your ASC

By ASC Development, ASC Management, Leadership No Comments

A strategic plan is a valuable resource for every business. Ambulatory surgery centers are no exception. A business strategic plan is a tool that outlines the organization’s progress to date, the current market landscape including information on competitors, the strategic priorities for the future, and plans for addressing challenges and opportunities. In each of these assessment areas, the business is viewed from a multi-faceted perspective, focusing on elements such as sales, consumer behavior, finances, quality, and business development. In an ASC, these elements may translate as physician alignment/recruitment, patient satisfaction, finances, quality, and new service lines.

Developing a strategic plan requires an investment of resources. Most notably, the time and commitment of some of the most highly skilled people in your organization. It is important for team members working on the plan to invest the time required to examine the organization and make informed decisions about its focus and direction.

Here are some of the benefits that come with creating a strategic plan for your ASC.

Charting the Course

A strategic plan sets a direction or course for the ASC’s leaders. It allows for the prioritization of growth initiatives and defines how success will be measured. In a sense, it helps people throughout the organization understand what they should be working on and in what order. Without a clearly defined plan, you may find your priority initiatives, the ones that drive the highest success, are being given secondary treatment. For example, if cost containment is a high priority for your ASC, your strategic plan might state you will create awareness of and movement toward achievement of that goal through employee education. Specifying how often employee education will focus on and reinforce cost containment initiatives allows your team to track their progress on the goal throughout the year. The focus shifts from “educating employees” to “cost containment through employee education.”

Maintaining Alignment

A strategic plan can place every member of your ASC on the same page. It is common to find departments within an organization headed in different directions. While they each may be accomplishing their departmental goals, the organization itself may struggle to achieve its primary strategic objectives. With the creation of a strategic plan, it’s possible for operations, finance, clinical, human resources, marketing, business development, and all the other departments in your business to align their efforts towards the same desired goals.

Sustaining Focus

A strategic plan offers an opportunity for ASC leaders to formally incorporate input from key members of the organization into business operations. Business leaders often receive insightful suggestions for improving business processes from internal team members. However, they may find it difficult to incorporate these suggestions in meaningful ways. A strategic plan offers the opportunity to integrate “good ideas” into the organization’s key initiatives and communicate them throughout the organization.

It also assists leaders curb unnecessary projects that consume the valuable time and energy of team members. Sometimes, it can be hard to say no to innovative ideas or initiatives. If there is no clear direction, these suggestions can create a lot of distraction. By prioritizing the activities necessary for success, each member of your leadership team can sustain focus on the agreed-upon objectives. Priorities make it easier to say no to distracting initiatives.

Creating Buy-In

As you create your ASC strategic plan, seek input from all leaders within your organization. Synthesize their input and communicate your message back to every member of your organization. Employees should know where their organization needs to be and the ways it will get there. Ensure your strategy is written down, finalized, and communicated to everyone acting on it.

Create a strategy for your business that incorporates your vision, mission, and outside the box thinking. Treat your strategic plan as a map that charts the course of your ASC, defining where you want your business to go. And, don’t be surprised when your guide helps you end up exactly where you wanted your business to be!

Extra Resources:

https://cnmsocal.org/

https://smallbusiness.chron.com/strategic-planning-important-business-2671.html

Jovanna Grissom, VP of Operations

Jan 25
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OIG Exclusion – Why Completing Routine Screenings Makes Sense

OIG Exclusion – Why Completing Routine Screenings Makes Sense

By ASC Management, Leadership No Comments

The Department of Health and Human Services (HHS) Office of Inspector General (OIG) released a Special Advisory Bulletin on the Effect of Exclusion from Participation in Federal Health Care Programs on May 8, 2013. This updated guidance is available at https://oig.hhs.gov/exclusions/effects_of_exclusions.asp.

This regulation states that no federal health care program payment may be made for any item or service provided by an excluded person or at the medical direction of an excluded person. Health care entities violating this mandate risk civil monetary penalties of up to $10,000 for each item or service provided by the excluded person. They may also risk an assessment of up to three times the amount claimed, and in serious cases, the health care entity employing or contracting for services with the provider may also face exclusion.

Health care entities, including ASCs, are advised to screen all employees, physicians, allied health professionals, and contractors for exclusion from any federal health care program. The OIG recommends, at a minimum, checking all personnel who provide patient care. Those services are at the greatest risk for civil monetary penalties because they are more likely to be paid for by a federal health care program. The most thorough screening includes services provided to your facility by contract – a pharmacist consultant, sales representatives, administrative and management services, etc.

The OIG does not require monthly screening; however, they strongly encourage completing this task monthly to limit the facility’s liability. Completing monthly screening places your facility in a better position to minimize the potential damages assessed in situations where excluded persons are discovered. Screening should take place when hiring, credentialing, and signing new contracts for services provided to the facility and should continue monthly until termination of employment or contractual arrangement. It also is wise to check state requirements. Many states require or recommend monthly checks of their databases of excluded persons.

You may choose to perform the OIG exclusion review internally via facility personnel or use a third-party vendor. If you use a third-party vendor, keep in mind that it is still the facility’s responsibility to review documentation provided by the vendor. Using a third-party vendor for exclusion verifications does not absolve the facility from liability. Maintain documentation of all searches to verify the process is routinely taking place and serve as a record of the results.

If you discover a prospective or current employee, provider, or contracted person or entity on the exclusion list, you will need to terminate that individual’s employment or contract. You may wish to involve legal representation to assist with the termination and any reporting that needs to be made. If the excluded person provided services to federal health care program patients, payments the facility received from those programs will need to be returned to the federal entities.

Protect your facility from the possibility of civil monetary penalties and fines. Implement a process to complete OIG exclusion checks monthly and maintain records of these reviews on file.

Kelli McMahan, VP of Operations

Jan 16
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Developing a Quantitative Skill Set to Become a Better Leader

Developing a Quantitative Skill Set to Become a Better Leader

By Leadership No Comments

The ASC industry is challenged by the same issues as other industries – the need to find, employ, and empower good managers and leaders.

Throughout my career, I have engaged in the search for potential leaders who possess the powerful mix of interpersonal communication skills, a background in clinical medicine and/or its operations, and financial acumen. With heavy competition to hire strong leaders in health care, we are fortunate when we secure candidates who possess two out of these three skills.

For example, many ASC administrators possess the interpersonal skill set and background in clinical medicine, but they lack a solid foundation in finance and mathematics. Oftentimes, we hire or promote these individuals and work closely with them to develop the financial and quantitative skills necessary to successfully manage and lead a surgery center.

A great starting point for health care managers seeking to improve their financial acumen is “Finance and Accounting for Non-Financial Managers.” This resource is offered through many different authors and training organizations. While one-on-one mentoring is preferred, studying the book or attending the course allows those with minimal prior exposure to these principles to achieve a reasonable to high level of competency in financial and quantitative analysis.

Recently, I read an article by Alexandra Samuel in the Wall Street Journal titled “How I Beat Math Phobia – and Became a Better Entrepreneur.”[1] In this article, Ms. Samuel discusses her “math phobia.” It opened my eyes to why many people say they are not “numbers” people. While they may be fully capable of handling numbers-related tasks (calculating a tip, balancing their checkbook), they may have an ingrained fear of complex math or be intimidated by accounting principles.

Ms. Samuels outlines four approaches anyone can take to defeat their “math phobia” and improve their quantitative skill set and financial understanding.

  1. Find a mentor to assist you with increasing your comfort with numbers. (Managers and leaders who are comfortable with math and finances, make yourselves available as a mentor or resource to team members who self-identify as “non-numbers” people.)
  2. Immerse yourself in a “passionate project” requiring numbers, math, or quantitative analysis. In the ASC industry, the project could be related to productivity, reducing waste, improving quality, increasing profitability, or monitoring business development efforts.
  3. Look for a quantitative question you are desperate to answer. Many questions related to an ASC’s performance have a quantitative basis. Ms. Samuels suggests, “All of those questions are answerable with data, and they can drive your recovery from math phobia.”
  4. Determine if your math anxiety is related to the gender factor. As a brother of two sisters, both of whom have science and health care degrees, as well as the father of two daughters who are quite competent in math, I hadn’t considered how gender may impact someone’s view of math and quantitative analysis. After reading Ms. Samuels’ article, I now recognize as a business owner, manager, and leader, I need to be cognizant a gender impact exists for quantitative and math comfort. I also realized that to effectively identify and develop talent, we need to address this issue by encouraging the use of the three tactics outlined above and other available techniques.

Math is important to every role in every organization. When “math phobia” is removed, one may find comfort in the reliability of numbers and equations. Developing a quantitative skill set and financial acumen takes effort, but it begins with support and a nudge in the right direction. No one should shy away from math and finance out of fear. Wise managers and leaders will provide team members with tools to deal with math phobia or they will miss out on the opportunity to secure the services of many talented people.

Robert Carrera, President/CEO

[1] https://www.wsj.com/articles/how-i-beat-math-phobiaand-became-a-better-entrepreneur-1511751960

Jan 11
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9 Strategies for Upfront ASC Patient Collections

9 Strategies for Upfront ASC Patient Collections

By ASC Management, Revenue Cycle Management No Comments

With the continued rise of co-payments, deductions, and co-insurance percentages, patient balances are quickly becoming the largest payer class for ambulatory surgery centers. This increased financial burden for patients places upfront ASC patient collections front and center for every facility. ASCs who adopt a proactive stance toward patient financial responsibility can significantly shorten their payment resolution cycle and increase profitability.

In an ideal situation – submission of a clean claim and prompt processing of same by the third-party payor – payment from the patient’s insurance company is received approximately 15-30 days following the date of service. Upon completion of a properly processed claim, the facility can then generate a statement notifying the patient of any residual financial responsibility.

In many cases, however, the actual “payment in full” status of an account extends well beyond a 45- to 90-day timeframe, particularly when the balance attributed to patient responsibility is significant.

To avoid becoming a long-term creditor, ASCs can positively impact patient balances by employing the following ASC patient collections strategies in the upcoming year.

  1. Consider hiring a Patient Financial Counselor to serve as your ASC’s primary source of patient estimates. With their solid understanding of how insurance works and ability to relay patient responsibility expectations in understandable terms, your ASC’s upfront patient collections and patient satisfaction will trend in a positive direction.
  2. Pre-verify patient insurance benefits specifically noting deductibles, co-pays, and co-insurance parameters, as well as the portions patients have already met in each of these areas.
  3. Collect co-pays and deductibles on the date of service, prior to patients undergoing scheduled procedures.
  4. Ask for payment in full.
  5. Don’t fall into the trap of extending payment plan terms that will not pay off patient balances owed in a reasonable amount of time (e.g., $10/month on a $500 bill); otherwise, your ASC can easily become your patients’ loan officer of choice.
  6. Establish hard and fast payment plan guidelines. Ensure staff consistently adhere to them when payment plans are required.
  7. Accept credit card payments and offer alternative payment services (i.e., low interest health care loan programs).
  8. Employ the use of a secure online payment portal.
  9. Accelerate your statement process. Gone are the days of monthly statements – it is simply too expensive to carry an interest free loan for your patients. Shorten your statement cycle to daily, weekly, or every 15 days. Ask for payment in full via the initial statement with one final notice generated 30 days later.

Failure to proactively manage patient balances can result in a higher percentage of accounts receivable attributable to individuals than third-party payors and more patient accounts than you can afford to contact. Ensure your patients are informed about their financial responsibility prior to their procedure and actively work with them to secure payment at the time of service. Upfront ASC patient collections can significantly impact your ASC’s cash flow, especially as you move into the new year.

Carol Ciluffo, VP of Revenue Cycle Management

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