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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.

 

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

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

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

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

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

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

 

The Ripple Effect of Reducing Data Entry Errors

The Ripple Effect of Reducing Data Entry Errors

By ASC Management, Leadership, Revenue Cycle Management No Comments

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

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

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

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

Review and Analyze Data Entry Error Log

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

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

Data Entry Double Check

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

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

Front Desk Staff Input

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

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

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

Ongoing Front Desk Staff Meetings

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

Eye on the Prize

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

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

The Ripple Effect

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

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

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

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

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


Michaela Halcomb, Director of Operations

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

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

By ASC Management, Leadership No Comments

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

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

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

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

  • Is the ASC maximizing time of service collections?

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

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

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

    • Patients will be much more pleased with their overall experience if they fully understand their financial obligation and do not face unexpected or minimal post-surgery expenses when their EOBs arrive.
  • Does the ASC have the case volume to support a full-time or part-time position or can this responsibility be added to an existing employee’s job description?

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

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


Lori Tamburo, Director of Operations

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