FEATURE
pain tables are traditionally at least $20,000, and there are other costs as- sociated with performing these proce- dures,” Ramirez says. Next, says Mowles, you can discuss licensure requirements. “Have they thought about the fact that most states are not going to allow these procedures to be performed in an unlicensed facil- ity? The cost and complexity of going through an accreditation survey to meet the state regulations is just as onerous as what an ASC goes through. The only difference is you don’t have to meet the Medicare Conditions for Coverage, or the physical environment regulations that apply under the state regulations for licensing and Medicare’s Life Safety Code requirements through the National Fire Protection Association (see article on page 10). There are still challenging, regulatory minimums considered stan-
dard for an accredited, office-based sur- gical program.” Physicians will also need to con-
sider what staff they need to hire, says Mowles. “You can’t use your reception- ist to run the c-arm. You really do have to think about accepted standards of care. What would be considered safe and ap- propriate to your peers?” Physicians who want to bring these patients to their offices will also need to determine if they have the space to accommodate patients undergoing pro- cedures, says Mowles. “If you’re going to invite someone in to see your office- based procedure room, you can’t have the patient hanging out in the hallway. You will certainly want to design a flow that is bigger than you think it would be because you don’t want patients or their family members using a bathroom that’s across from your step-down recovery
area. What would provide privacy by design for patients? The Health Insur- ance Portability and Accountability Act (HIPAA) doesn’t make you build sound- proof walls, but it is implied that you will do your best for privacy.” Ramirez adds, “You at least have to
have a small preop and recovery area, so oftentimes an office will need tenant im- provements to get the space ready.” You can ask physicians if they have considered how they will handle and secure drugs, suggests Mowles. “Pain management practices have narcotics. If you don’t have an ASC with the system of the two professionals doing the drug count together, who is going to do it? Are you going to delegate that responsibility, and to whom will you feel comfortable delegating it?”
If none of these issues concern the physicians, Mowles adds, you can note
ASC FOCUS MARCH 2013
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