Is your surgery center ready for a surprise Medicare survey?

July 15, 2008

Surgery center owners shouldn't worry about a survey, but welcome one. It's important that the center has a strong clinical director that understands the compliance requirements. The intent of this article is to give ideas on what to expect from a survey and to help prepare. This is a general overview of the process.

Most ambulatory surgery center (ASC) owners dread the thought of an unannounced survey. They always worry that they will fail the survey and the surgery center will be closed.

First of all, let me say that very few centers are closed because of a survey. The surveyors would have to identify a high-risk situation before they would close the doors. The intent of this article is to give ideas on what to expect from a survey and to help prepare. This is a general overview of the process, but in months to come the focus will be on each item specifically, in order to fine-tune a center's preparedness.

Surgery center owners shouldn't worry about a survey, but welcome one. It's important that the center has a strong clinical director that understands the compliance requirements.

When to expect a surveyor

When a center initially applies for Medicare certification it is asked to identify days and hours of operation of the proposed center. The state uses this information to schedule the initial and subsequent surveys. While most states don't have regular schedules for surveys, they always use this information to schedule their unannounced survey. Many ophthalmic surgery centers have changed their schedule since the initial survey and should notify the state of their current schedule. Nobody wants a surveyor to show up if the clinical director is not present. Each center should identify what the state has written for their center.

There are always two aspects to any survey, the walk through and review of all the documentation. To follow is what to expect from each.

Walk through

When surveyors arrive at a center, the first thing they will do is go to the front desk and identify themselves. They will ask for the clinical director. In an effort to organize, the clinical director should take the surveyors to an area with a table or desk. The clinical director should advise the surveyors that he/she will bring all the necessary documentation to the surveyors as needed. The surveyors will be OK for about 5 minutes while the clinical director plans the process. The staff should be advised that a surveyor is there and directed to go through the entire center and remove all open medications that haven't been dated for expiration after opening. The staff should make sure the space is clean and orderly. All staff should have nametags on. As soon as the clinical director has put this process into action, he/she should return to the surveyors.

The clinical director should take the surveyors through the patient process, starting by describing how the patient is admitted. The surveyors will want to know how the patient is processed through each area of the center. They will want to know what happens and what staffing is available in each area. The center is required to have a copy of the patient rights, responsibilities, and grievance policies posted in the waiting room. Each center should describe how they disclose ownership if the surgeon has ownership in the center. There should be a poster that describes a process for patients that don't speak English. The center should have a contract with a translator service to provide translation to patients when needed.

The next stop for the surveyors is the pre-op area. The clinical director will describe how patients are managed. The surveyors will want to know if the patients change clothes or just put a paper gown over their clothes. Policies of the center should reflect the actual practice. The clinical director should describe the nursing care delivered in this area, such as an RN admits and assesses the patient, a nurse's aid takes the vital signs, and the anesthesia provider starts a heparin lock, etc. Is your site marking done in pre-op? It should be, according to the standards of care. Stickers should never be used around the proposed surgical eye. Eyes should always be marked with an indelible marker to indicate the correct side.