The Successful Ophthalmic ASC - Administration Operations and Procedures
The Successful Ophthalmic ASC - Administration Operations and Procedures
Administration, Operations
and Procedures
Administration, Operations
and Procedures
Written by:
Louis Sheffler, MPS, Maria Tietjen, BSN, and Carl Desch, MBA
Louis Sheffler, MPS, is the Chief Operating Officer of American Surgisite Centers. He started working
as a developer of ASCs in 1980 and has been involved in 135 ASC projects nationwide. He serves on the
Board of the Outpatient Ophthalmic Surgery Society (OOSS), and participated in the AAO subcommittee
to review EMR standards for CCHIT. Maria Tietjen, BSN, works as Executive VP Nursing and Clinical
Services at American Surgisite Centers. Her background as an Operating Room Nurse spans a 35 year career,
specializing in Ophthalmology for 26 years and Orthopedics for 10 years. Carl Desch, MBA is the Chief
Administrative Officer of American SurgiSite Centers. He spent over 30 years in the financial industry at
JPMorgan and then Goldman Sachs where he focused on operations, risk management and administrative
roles internationally. He currently coordinates various aspects of managing ambulatory surgery centers,
including billing and collection functions, insurance, purchasing and center governance
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Other titles in
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A dm i n i s t r ati on, Ope r ati ons and Proc edures The Suc c essful Ophtha lm ic A S C
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A dm i n i s t r ati on, Ope r ati ons and Proc edures The Suc c essful Ophtha lm ic A S C
tool: having the right tools for the job yields a more to communicate with physician office software (inter-
efficient and more profitable operation. operability) so that required patient information
Effective planning and management of an ASC’s will flow easily from office to ASC.
technology demands a high level of attention. With- Required forms and features of an EHR system
out a specific plan and ongoing oversight — activities should include the following:
that include all members of the ASC staff — technol-
ogy can end up frustrating daily operations, rather • Compliance with federal initiatives for
than facilitating them. ASC ownership/management “paperless” physicians
should expect to take time getting everybody to buy • Chart notes (physician/anesthesiologist/sur-
in to new systems so that staff welcomes the transi- gical nurse)
tion to a new system. • Automated billing, accounting and reporting
External Communication • Electronic consent forms
Good communication with the community (both • Preop health questionnaire
surgeons and patients) should include maintain- • Pre/Postop nursing records
ing a website. Effective communications programs
can enhance ASC profitability by getting the ASC’s • Pre/Postop surgeon’s records
name out into the marketplace, and drawing addi- • Fully automated general and monitored
tional doctors and their patients to the center. anesthesia care (MAC) anesthesia records
• Intraoperative records
EHR and Related
Information System Support • Discharge summary (“super” bill)
Medical practices and surgery centers have been • Automated generation of operative reports
utilizing electronic practice management (EPM) • Quality assurance of electronic charts
software systems for years. The function of these sys-
tems is to set appointment schedules and to provide • Full auditing features and reports
a platform for electronic insurance reimbursement • Automation and management of patient
submissions. records and documents
For most ASCs, the gap between scheduling and • HL7/DICOM connectivity to medical
billing has been filled with paper surgical charts. equipment
Recently, software companies have introduced
electronic health records (EHR) to interface with • Integration with third-party products
the scheduling and billing functions.
EHRs have many advantages over paper charts. Equipment and
A well-designed ASC EHR system should permit Supply Management
remote block-scheduling from each surgeon’s office,
transmission of forms to the ASC medical record There are many different avenues for staying current
over a secured Internet protocol and remote access on the latest ASC equipment in the marketplace
to charts for surgeons. These features greatly reduce and on the buying opportunities that exist. Trade
the workload of creating paper charts in the ASC, publications, industry conferences, manufacturers’
while making the scheduling job easier for surgeons’ representatives, independent research and the anec-
offices. dotal experiences of colleagues are all good sources
EHR software pricing varies greatly. ASC manag- of information. Once the ASC is operational, it is
ers and owners should therefore carefully check out advisable to maintain continuous vendor contact to
various systems and weigh the features and benefits review how equipment is operating and how it can be
of each. (See Resources section at the end of this better utilized and maintained.
module.) Systems that are easy to use and that reduce A regularly scheduled program of preventive
workload should be benchmarked against paper chart maintenance is necessary for all highly utilized
costs and work flow. An ideal EHR system should be equipment to ensure optimum performance and
easier, faster and less expensive than paper records. longer life span. Equipment upgrades should be
The Centers for Medicare and Medicaid Services considered and are usually included in maintenance
(CMS) provides incentives and subsequent penalties agreements offered by the various OR equipment
for the use of EHRs. Make sure that the software companies. A log should be maintained to record
platform you choose for the ASC has the ability utilization of equipment so that outdated items
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can be removed from the ASC in a timely manner. purchasing and management, despite the incre-
The market for used equipment and instruments is mental cost, often yields significant savings because
large; if equipment has been properly maintained, of the discounts these companies are able to extract
much of it can be resold. By the same token, not from suppliers and the warehousing capabilities they
everything that is purchased for the ASC needs to be offer. Before rejecting the idea of going outside
new. Nonelectric equipment, such as stainless steel to get the services of a purchasing agent who can
ware, can be purchased in the secondhand market. represent its interests, an ASC should perform a
Mechanical equipment should be purchased used thorough cost analysis.
only if it is backed by the original manufacturer. ASC managers should establish internal proce-
The cost of medical supplies has become increas- dures and centralize ordering to contain costs. For
ingly difficult to control in the wake of the federal example, surgical glove costs can vary widely. Proce-
government’s publication of Medicare Conditions for dures should dictate how products are ordered and
Coverage (www.cms.gov; then search “Conditions what products are approved for purchase.
for Coverage”). Items labeled “single use” cannot
be reprocessed; this has driven supply costs up. Billing and Collection Services
Purchasing personnel need to be on top of these
requirements and should examine competitive OR Revenue is the fuel that runs the ASC engine. How
products and utilize multiple supply vendors to efficiently an ASC collects the insurance claims that
extract the best prices. are due to it determines the fate of the business.
Competition for sales always exists in the mar- Failure to expend adequate effort to collect revenue
ketplace: the largest supplier does not always offer can greatly harm the ASC. Good ASC management
the best terms. To start the process of selecting a starts by having the right people in place in the col-
supplier, purchasing staff should obtain several lections role — or a qualified firm under contract to
quotes for the items that are used most frequently. perform collection tasks.
Payment terms should be negotiated to maximize Make certain that the billing and collections staff
cash availability. In certain instances, there may understand the role they are performing and are
be flexible promotional consignment terms for properly trained to identify the procedural codes
IOLs. The purchasing staff should leverage available they will be using, as well as what different insur-
information sources to learn about alternative sup- ers require on claim submissions. Billing is not a
pliers and products. New products should be priced mechanical process: the more the billing specialists
before being evaluated in the OR. ASC staff should understand about the procedures that are being
be open to trying new products: such flexibility can performed at the facility and the subtleties of a
contribute to efficiency and help the bottom line. discharge summary and use of modifiers, the greater
It is also important to manage inventory levels the revenue stream will be and the faster it will flow.
properly so as not to tie up valuable capital. High It is important to have contracts in place and to
inventory levels of slow-moving items eat up stor- review them annually for the group of insurance
age space, and unused stored drugs can expire. In providers who are in-network. The credentialing
high-volume ASCs, warehouse management software process can be cumbersome and time-consuming; it
systems can precisely manage inventory levels and set requires a knowledgeable person who stays on top of
automatically triggered reorder points. Such systems the insurance company to complete the contracting
are also integrated with the ASC’s accounting system process. Initial rate schedules often entail multiple
to allow for the posting and updating of invoices and rounds of negotiation and, once in place, are also
payables. Even a single- or a double-OR ASC is not subject to review and adjustment at different times.
too small for such a system. Many firms offer ware- At least one person should be charged with staying
house management and related accounting packages; current on developments related to various contracts
the costs of these systems have been coming down and also on industry trends and proposed changes in
in recent years. The systems can be customized, but legislation or regulations.
customization is usually not necessary for effective The billing function should be organized such
operation. that claims are submitted as quickly as possible
When examining the supply management after the procedure has been finished and patient
function, ASC management/ownership must also records completed. The staff must monitor submit-
consider another dimension: the staff hours that ted claims and quickly turn around those that are
are being expended maintaining data records and rejected. The staff should also look for any patterns
supply flow. Using a purchasing agent for supply in the rejections to see if something is consistently
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wrong or if something has changed. The submission Good reporting is frequent reporting — namely,
of secondary claims is more difficult to track and a monthly closing and reconciliation, followed up
control (compared with Medicare primary claims), with quarterly reporting of financial results and
but it is vital for profitability. Monies received must variance analysis. The reporting packages generally
be quickly posted and cleared, and daily proofs consist of several income statements with compari-
need to be conducted to minimize reconciliation sons to other time frames, balance sheet compari-
headaches at month’s end. Duplicate payments or sons and also several forms of activity comparison,
overpayments should be refunded when discovered. best sorted by either CPT code or physician name. If
The insurance companies will either request return they are being distributed to the ASC shareholders,
of the funds or ask for them to be applied against a these reports are generally accompanied by a com-
subsequent claim. mentary on the results.
As receivables start to age, the staff should not Sharing the results with the center’s shareholders
hesitate to escalate the issue and begin the collec- and other key individuals who assist in running the
tion process if needed. Waiting too long to get a center is a good practice. It allows all involved to
payment from a patient, even if staff is in contact better understand the dynamics of the operation and
with the patient, only decreases the probability of to see how their actions and those of others translate
eventually getting paid. Working out payment plans into the financial reality of the ASC.
for select patients may be an acceptable alternative to Additional functions such as the handling of
demanding full payment of an open balance. ASC payables, cash management, bank account reconcili-
management/ownership must set metrics for the ations and banking relationships, interactions with
billing and collection functions with respect to the the outside accounting firm and preparation of tax
timely completion of tasks and for the receivables returns are also part of the financial life of an ASC.
aging profile. Billing/collections staff should meet Seeing that these activities are taken care of expedi-
regularly to review the metrics and identify ways to tiously is an essential element of a good operation.
improve performance further. The investment of (For more information on these subjects, see the
time will yield significant returns. If collections Financial Reporting and Management module in this series.)
fall behind, paying overtime hours to the billing
department is worth the investment; additionally, Benchmarking
hiring an outside consultant to review fees and bill-
ing practices is wise. (See the Complete Guide to Coding Benchmarking the ASC’s results against the per-
module in this series for more information on formance of other eye surgery centers will assist
reimbursement.) the managers of the ASC in determining how well
the surgery center is performing. Joining the state
surgery center association, as well as a national
Financial Reporting and Budgeting organization such as the Outpatient Ophthalmic
An ASC needs to have a good budgeting process in Surgery Society (OOSS), will provide valuable tools
place — and produce regular reports of financial for business, administrative and clinical benchmark-
results for review. Timely financial reports enable ing. (See Resources for more information.)
the managers of the center to see how they are doing
against their annual plan, to spot where assump- Other Services to Consider
tions or market conditions require changes and to
track revenues and expenses throughout the year. There are a myriad of other business-related func-
Whether budgeting and reporting responsibilities tions and services that are part of running an ASC
are assigned to full-time ASC staff or are outsourced efficiently. These include having good legal support
does not change the fact that they need to be com- to review contracts, analyze regulations, prepare
pleted and that the information needs to be updated legal documents and give counsel when needed on
frequently. Management also needs to be aware of compliance matters and related questions. The
seasonal variations. In the Northeast, for example, lawyer or firm providing such services should have
the busiest time is from the start of autumn until the experience in the industry and should be prepared
end of the year. Scheduling and staffing may need to offer support on short notice. Carefully consider
to be adjusted for time of year, and financial results and outline the specifics before agreeing to any fee
should be benchmarked by month or season against arrangements.
the previous year’s performance. Also necessary are reliable and experienced
contractors who provide building maintenance and
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cleaning services. No facility wants to receive a poor work for them, too. Surgical complications that may
result following a surprise inspection or encounter occur with the anterior segment doctors Monday
environmental infection control problems that show through Thursday can be managed on Friday by the
lack of regard for patient care or safety. The services posterior segment surgeons.
of a reliable, experienced company are well worth For pediatric surgeons, Friday is an excellent day
paying a premium for. An ASC should also maintain to perform surgery. Children should be scheduled at
a strong relationship with transportation companies, a separate time from adult patients. Usually the par-
archiving services, waste disposal companies, electri- ents are allowed to be in the preop and postop areas
cians and plumbers who know the ASC complex and to comfort their children and spend time speaking
are on call for unforeseen emergencies. with the doctors and nurses. Friday is usually a
convenient time slot for working parents, too.
In dealing with the anterior segment practices,
Scheduling it is best to survey the practice to find out what days
the surgeon has office hours and what days he or she
is in the OR. If a doctor is moving surgery out of
Efficient coordination of the OR schedule is of the hospital setting and into the ASC, the surgical
the utmost importance to efficient ASC operation time block will likely be reduced because ASCs have
because personnel expenses are a major overhead shorter downtimes between cases than do hospitals.
category in the ASC. Gaps in the schedule are costly. It is a good idea for the ASC Nursing Director to
The best way to manage the daily schedule is by observe the surgeon in the hospital OR, if possible,
block-booking time for each surgeon. to evaluate case time. Doctors performing cataract
surgery in less than 15 minutes would be best served
Block-Booking Considerations by supplying two tandem ORs, so the nursing and
anesthesia staff have adequate time to prepare the
If you make your ASC available to outside surgeons,
patient for the surgeon. Ideally, there should be
here are some suggestions. It is important to get
only a few minutes’ downtime for the surgeon
accurate data from a surgeon who wishes to join the
between cases. For rapid procedures this can only be
medical staff of the ASC to determine how much
accomplished consistently and safely by having the
time that surgeon will require. It is wise to obtain
surgeon migrate from one OR to another.
the surgery volume history from the surgeon’s prac-
Long procedures, like retina and plastic cases,
tice by requesting a report of all surgical procedures
generally need an individual dictation for every case,
performed during the previous year. The surgeon’s
so procedures of these types should be scheduled as
electronic billing program in his or her practice
single-OR cases.
should be able to produce this information easily.
Because changing the OR to accommodate a new
If both eyes require surgery, most doctors want
surgeon later in the surgical-day schedule produces
to perform both surgeries within a month’s time
downtime, it is advisable for one surgeon to fill the
because Medicare requires a general history and
entire day. As an example, if a surgeon is used to
physical examination within 30 days of a planned
working four Wednesday mornings a month and
surgery. Performing surgery on both eyes in one
completing surgery at noon in the hospital setting,
month means that the patient will not need to
it is more efficient for the doctor to operate two full
return to the primary care provider for a second
Wednesdays per month at the ASC.
exam for the second eye surgery. Most doctors
Most surgeons prefer morning OR time. Having
should be block-booked into the surgery schedule
surgeons work a full day opens up more mornings
twice a month.
for other doctors on staff. Surgical centers that serve
Cataract patients need to be seen by the surgeon
multiple, lower-volume practices will need to deal
postoperatively one day after surgery. Fridays usually
with afternoon time slots. A fair way to allot after-
are not popular surgery days with anterior seg-
noon time is to assign each surgeon a morning slot
ment surgeons because most doctors do not have
and then an afternoon slot on another day.
Saturday office hours. Fridays are ideal for oculo-
One issue that can improve afternoon scheduling
plastic surgeons, however. Their patients are seen
is to meet with the anesthesia staff to discuss NPO
postoperatively 72 hours after surgery, which would
protocol. Many anesthesia groups, knowing that the
place a Friday surgical patient in the doctor’s office
anesthesia technique employed on cataract patients
the following Monday. Retina practices commonly
is either topical or a peribulbar block, allow patients
operate seven days a week, so Friday surgeries can
to take their normal medications and also permit
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them to eat a light meal in the morning before If you allow other surgeons to use your ASC,
arriving for afternoon surgery. This makes for here are some suggestions for minimizing cancel-
happier, less-stressed patients, especially those with lations. When the same practice is the source of
diabetes. Under these circumstances, many surgeons repeated cancellations, an investigation should take
will accept afternoon-block time. place to determine why this is happening. A review
It is important for the Nursing Director to of the office charts is helpful to see if a pattern can
prioritize the cases to be handled. This can be done be identified. Repeat cancellations can often be
by marking each surgical preop chart with the level attributed to unsatisfactory communication between
of difficulty anticipated in the surgical plan: office and ASC. It is good practice for the ASC
Office Manager to visit the problem practice with
• Marking the chart with a 1 indicates a the ASC Surgical Coordinator to study all cancelled
routine case. cases and reach a mutually agreeable solution.
• Marking the chart with a 2 indicates a more Unresolved problems should be referred to the ASC
difficult surgical case, such as a glaucoma Medical Director for further investigation.
patient requiring iris hooks.
• Marking the chart with a 3 indicates an
unusually difficult and long case. Required Documents
The surgeon should start the day with all the cat-
egory 1 cases. This should ensure that the beginning
for Surgery
of the schedule will move along on time and with
Patients need to supply, complete or review a
minimal difficulty. Once those cases are completed,
number of consent forms and other materials before
the category 2 cases should be performed. Assign
surgery. The surgeon’s office provides the patient
a longer time block for these procedures. This will
or a member of the patient’s family with a folder
allow the surgeon to take the time required to attend
containing the ASC forms that require attention
to the anticipated extra steps for the more compli-
and notifies the patient of the deadline for mailing
cated cases.
any required documents to the ASC. The surgeon’s
Category 3 cases should be performed on a
office should also give the patient the phone number
separate day. Cases of this sort are unpredictable and
of an ASC staff person to contact with any questions.
should be carried out without the pressure of also
The ASC calls the patient preoperatively to review
having to perform numerous routine surgery cases.
the forms and answer any questions that the patient
A time gap should be established before the
or family member may have. (Any surgery-specific
day of surgery to give the ASC the ability to add
questions the patient might have should be referred
slots for non-blocked cases of other doctors and to
to the surgeon performing the procedure, not to the
open time for emergency cases, such as retina cases.
nursing staff at the ASC.) Perioperative-type ques-
Generally this would be a two-hour time slot in the
tions may be directed to a nurse to handle.
afternoon for an emergency case. In multiple-OR
Medicare Conditions for Coverage regulations
facilities, the extra time needs to be reserved in only
(www.cms.gov; search for “Conditions for Cover-
one of the ORs. Without a time gap, OR time will go
age”) require that patients be fully informed before
unused, reducing profitability and efficiency.
having surgery at an ASC. The following are some
of the forms patients must review, supply and/or
Cancellations complete. Templates for most of these forms appear
Cancellations are an inevitable part of ASC opera- in Appendix A. The checklist in Figure 1 summarizes
tions. Random patients cancel because of comorbid common ASC forms and their functions.
conditions that require treatment before eye surgery
can safely be performed. Surgeons cancel because Patient Rights and Responsibilities
of personal emergencies. It is difficult to manage
As of May 18, 2009, CMS requires that each patient
around last-minute cancellations. Publishing the
be given a copy of his or her rights verbally and in
schedule one year in advance so that each practice
writing prior to the procedure date in a language
can double-check for conflicts such as vacations or
or manner the patient or his or her representative
religious holidays can help reduce cancellations.
understands. (See the Managing ASC Quality and Perfor-
mance module in this series for more information.)
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Patient Information Sheet Education and answers to Given to patient at least 24 Patient must acknowledge
commonly asked questions hours in advance of sched- receipt with signature.
for the patient. uled surgery (preferably,
when surgery is scheduled)
Patient History and Primary care physician’s ap- Within 30 days of surgery Primary care physician must
Physical
proval for surgery. Lab work sign.
is not required.
EKG Verification Form All patients over age 60 must EKG performed within 6 Primary care physician or
provide. months of date of surgery cardiologist signs, dates, and
interprets.
Patient’s Informed Consent Describes the risks and Completed by physician and Physician and patient must
benefits of the proposed patient at least 24 hours in both sign.
surgery. Should be specific advance of surgery
to the physician and the
procedure. Should identify
the eye as right or left, not
OD or OS.
Financial Interest Notes that surgeon has a Given to patient at least 24 Patient must acknowledge
Statement
financial interest in the ASC. hours in advance of sched- receipt with signature.
uled surgery (preferably,
when surgery is scheduled)
Advance Directive Legal documents that ensure Provided by patient at least Patient must provide to ASC.
patient’s wishes are followed 24 hours in advance of
if patient cannot make deci- scheduled surgery (prefer-
sions for him- or herself. ably, when surgery
is scheduled)
Patient Bill of Rights Document outlining patient’s Given to patient at least 24 Patient must acknowledge
rights. The ASC’s policies, hours in advance of sched- receipt with signature.
procedures and actions uled surgery (preferably,
must be consistent with when surgery is scheduled)
protection of the patient’s
rights.
Ocular History Substitute for a dictated Provided to ASC at least 24 Referring physician provides
preoperative note. hours in advance of surgery to ASC.
IOL Diopter Form Provided to ASC 1 week Referring physician provides
before surgery, to allow to ASC.
time to order IOL if out of
stock and avoid costly rush
delivery charges.
IOL Order Sheets Order form for the intra- Provided to ASC at least 3 Surgeon provides to ASC.
ocular implant for cataract days in advance of sched-
surgery. uled surgery
Driving Directions to ASC Clear, written instructions Given to patient at least 24 ASC provides to patient.
including a telephone hours in advance of sched-
number. If ASC is at same uled surgery (preferably,
location as practice, patients when surgery is scheduled)
should be given instructions
for entering the ASC.
Consultation Letter Confirms patient’s upcom- When surgery is scheduled ASC provides to medical
ing surgery and requests clearing physician.
general history and physical
information from patient’s
physician.
Patient Insurance Form Serves as the assignment of Day of surgery Patient completes.
benefits.
Preoperative Health Permits evaluation of health A couple of days before Patient completes.
Questionnaire
and risk factors. surgery for ASC staff to
review
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Appendix Guide
Visit www.aao.org/ascadmin for the following
appendixes, which contain customizable templates
for common ASC forms and documents.
Appendix A: ASC Paperwork Templates
• Patient Rights and Responsibilities
• Informational Document on Advance
Directives
• Disclosure of Financial Interest
• Patient Acknowledgment Form
• Patient Instruction Sheet
• Consultation Letter — Medical Clearance for
Surgery
• Patient Billing and Payment Notice
• Surgeon Reminder
• Patient Record Documentation
Appendix B: ASC Policies and
Procedures Manual
• Recommended Table of Contents for an ASC
Policies and Procedures Manual
• Sample Content for an ASC Policies and
Procedures Manual
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