for embezzlement, says John Fan- burg, chair of the health law prac- tice at Brach Eichler in Roseland, New Jersey. “We have found that ASC physician owners


delegate a lot of independence to their administrators because they are busy practicing medicine and do not want to be involved in the oversight required of a multi-mil- lion-dollar business. But without proper oversight, embezzlement can go undetected.”

Further complicating matters, Acker Protect Your ASC From Embezzlement

Establish internal controls, use an external accountant and conduct regular audits BY ROBERT KURTZ


crubs. Gloves. Scalpels. Drapes. A rowboat. Which of these is not

like the others? Margaret

Acker, RN, CASC,

wishes she did not need to answer this question. She was the chief executive officer (CEO) of an ASC when she saw an unauthorized pur- chase of a rowboat on her ASC’s credit card statement.

“When I became CEO, I assumed

everyone at the ASC would do their job the right way,” says Acker, a project specialist with Compliance One Group in Kalamazoo, Michigan. “Like most people, I put a lot of trust in others. As this experience taught me, I was naïve to think that every- one would act the way they should and the way I expected them to.”

Acker says she was fortunate to detect the embezzlement not long after it occurred. Other ASCs, says Denise McClure, president of Averti Solutions in Boise, Idaho, are not so lucky. As examples, she cites cases from the Department of Justice’s website of a Pennsylvania ASC busi- ness manager embezzling more than $4 million over 14 years and a prac- tice manager for an ophthalmologist with a laser center embezzling more than $500,000 over four years. “As these and many other cases illustrate, surgery centers are at risk for theft and embezzlement,” McClure says.

Understanding Vulnerabilities The manner in which many ASCs operate can increase the likelihood


says, is that staff members in ASCs often wear multiple hats. “Your busi- ness manager might handle bank depos- its, oversee billing and place orders on a company credit card,” she says. “In a lot of ASCs, the person ordering sup- plies is also the person receiving those supplies. Both scenarios can increase an ASC’s vulnerability.”

McClure says that operating on a “trust model” for internal control is risky. Even if internal controls exist, the business manager can usually override or ignore them. “In a small organization, the best and some- times only internal control is over- sight, but physicians often do not have time to review bank records and drill down into the details to catch possible embezzlement.” While bigger surgery centers

might have more individuals in man- agement and oversight positions, McClure says, this does not necessar- ily serve as an embezzlement deter- rent. “Fairly large surgery centers may only have a few people involved in accounting processes. This makes it difficult to segregate duties.” Another factor that Fanburg says increases embezzlement risk: cash payments. “ASCs often accept co- pays and even deductibles in cash. Cash is difficult to track and easy to conceal.”

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