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REGULATORY REVIEW


Certification Resources To enter into any agreement with CMS—even agreeing to get paid under Medicare—an ASC must be Medi- care-certified.


The certification pro-


cess involves multiple steps, including obtaining a National Provider Identi- fier (NPI), enrolling in Medicare, com- plying with Medicare’s Conditions for Coverage (CfCs) and completing a compliance survey performed by an accrediting organization. In some states, there is an additional state licensure sur- vey. ASCA provides a rundown of the specific processes involved in each of these steps as well as official documents and forms. All certified or prospectively certified ASCs should be familiar with the CfCs published in the Code of Fed- eral Regulations (CFR). A review of the State Operations Manual (SOM) that guides surveyors and provides further information on how an ASC can best comply with federal standards can also be valuable. ASCA provides links to both these resources on its website.


Quality Reporting Resources In 2012, CMS officially implemented the Ambulatory Surgical Center Quality Reporting (ASCQR) Program, a mecha- nism that ASCs can use to publicly dem- onstrate their consistently high perfor- mance. As of the 2017 calendar year, the program lists 12 quality measures, but the list is designed to change over time. ASCs that successfully report the required quality data will be eligible to receive their full annual payment update, while those that do not may be dealt pay cuts. Of the 12 measures, 11 are reported by the facility while one, ASC-12, is claims based. The cataracts quality mea- sure, ASC-11, is currently voluntary. Meeting the


ASCQR reporting


requirements involves a nexus of forms, websites and agencies. Five quality mea- sures are reported using G-codes on the CMS-1500 form, and five others are reported through CMS’ QualityNet site. ASC-8 Influenza Vaccination Coverage among Healthcare Personnel is reported


through the National Healthcare Safety Network (NHSN) managed by the Cen- ters for Disease Control and Prevention (CDC). To file complete data reports, an ASC representative must register for both the QualityNet site as well as the NHSN. ASCA members can find many resources on ASCA’s website that help centers successfully meet the ASCQR reporting requirements. Each quality measure is broken down and explained and links are provided to the Quali- tyNet site, the ASCQR Specifications Manual, a Reference Checklist, NHSN registration and more.


Emergency Preparedness Resources In September 2016, CMS published a final rule establishing national emer- gency preparedness (EP) requirements for all 17 Medicare and Medicaid pro- vider and supplier types, including ASCs. The rule creates mandatory elements and planning procedures that facilities must institute to account for facility occupant safety in the event of natural and man- made emergencies. To help ASCs com- ply with this rule, ASCA has published breakdowns of the required EP provi- sions: risk assessment and planning, pol- icies and procedures, communication plan, and training and testing. Further- more, ASCA provides an ASCA spread- sheet that identifies pertinent sections of the rule and CMS’ interpretive guide- lines. The guidelines, along with CMS’


Track the Latest Regulatory and Legislative News for ASCs


Visit ASCA’s website every week to stay up to date on the latest government affairs news affecting the ASC industry. Every week, ASCA’s Government Affairs Update newsletter is posted online for ASCA members to read. The weekly newsletter tracks and analyzes the latest legislative and regulatory developments concerning ASCs.


www.ascassociation.org/ GovtAffairsUpdate


22 ASC FOCUS NOVEMBER/DECEMBER 2017|www.ascfocus.org


resources and links to a multitude of fed- eral agency resources can be found on ASCA’s website.


HIPAA Resources ASCA provides several resources to help ASCs remain compliant with the Health Insurance Portability and Accountability Act of 1996 (HIPAA). You can find background on the act, as well as its four key provisions— privacy, security, breach notification and enforcement—on ASCA’s web- site. ASCA facility and corporate mem- bers also have free access to the asso- ciation’s HIPAA Workbook for ASCs, a comprehensive resource for designing, updating and evaluating your ASC’s HIPAA compliance program. All of this information can be


found on ASCA’s website by selecting “HIPAA Resources” under the “Fed- eral Regulations” tab.


Webinars, Publications and Other Resources ASCA supplies regulatory informa- tion through avenues other than its website. Regulatory issues are often covered in ASCA’s bi-monthly webi- nar series, which is available to ASCA members at a discounted price. Some regulatory webinars from the past year covered topics such as HIPAA essentials, updates on the Consumer Assessment of Healthcare Providers and Systems Outpatient and Ambu- latory Surgery (OAS CAHPS) Sur- vey and the 2018 Medicare payment rule. ASCA’s Government Affairs team also distributes a weekly email newsletter, the Government Affairs Update, which includes regulatory news and information. For specific regulatory questions, please feel free to reach out to Alex Taira at ataira@ascassociation.org or Kara New - bury at knewbury@ascassociation.org.


Alex Taira is ASCA’s policy analyst. Write him at ataira@ascassociation.org.


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