THE WEEK OF NOVEMBER 21, 2022

CONTRIBUTE CONTENT TO THE PULSE

Your response to THE PULSE has been overwhelmingly positive. To continue providing membership with a quality product, we need your help. Member centers and vendors are urged to contribute content. This is your newsletter- be a part of it!

For it to reach its full potential, your contributions to content are needed.

Please send your questions and comments to the Editor, specific to these recurring columns: 

• SURVEY SNIPPETS
• WHAT’S ON YOUR MIND
• WE HEAR YOU

Please send your questions and comments to

Jeff: jshanton@jssurgctr.com

IT’S TIME TO RENEW YOUR NJAASC MEMBERSHIP!

Please be aware that 2023 NJAASC dues renewal letters have gone out to the membership.

NJAASC would like to thank all of you for your support this past year. We have even bigger plans for 2023, and we need your continued help to make it happen.

If you have any questions about your membership renewal or have not received a letter, please contact Kelly Biddle: kbiddle@njpsi.com.

We also have a membership renewal giveaway!

One ASC and one Vendor member that renew prior to Thanksgiving will be randomly selected and treated to a lunch (up to $400) by NJAASC. In addition to lunch, a donation will be made in those member center and vendor names to the "30 Days of Giving" charity drive that is underway.

PRESENTATIONS AND POWERPOINTS

ARE UP ON THE WEBSITE

Speaker presentations from the 10/19 Quarterly Membership Meeting are up on the website.

The Way to Sway: Crafting Presentations That Entertain, Engage, & Educate

Ron Cappello and Lizzie Kupersmith

November 1, 2022

Presenters want to sway audiences, and audiences want to be carried away. However, there is an ongoing debate as to the best way to achieve that goal. 

Leaders at Amazon think PowerPoint is a big waste of time and insist on a six-page memo format. Apple thinks having one image or key word on a slide is the best way to ensure audience engagement.

Whatever your preference, the fact is the process of preparing a presentation is an excellent way to organize your thinking and curate your ideas to give them a clear and resonant voice. In each case, it takes time and attention to detail to achieve your communication goals, including employing the elements outlined below:

Story - It’s always a good idea to know where you want to take your audience and what is the best type of story to get them there. Stories make the best cognitive bridges to make data and information relatable and understandable. 

Substance - It’s the function of form that elevates content to a high level of importance. This means that for your message to stand out it has to stand for something in order for it to resonate with your audience. 

Style – It always gets a bad rap, implying something lacks substance. This isn’t true. The substance of style is the visual vehicle that helps carry stories and presentations forward by making sure all the senses of an audience are engaged. 

Simplicity - Leonardo DaVinci stated simplicity is “the ultimate sophistication.” Writer Ken Segall puts it in more basic terms, calling simplicity “the love child of the two most powerful forces in business: brains and common sense.” Both observations are spot-on because they

remind us of the importance of finding the right balance between the two. This ensures that audiences are afforded the respect they deserve, while avoiding coming across as a pedantic know-it-all.  

Short - Brevity is the soul of wit, which is hard and takes time to achieve. Yet, it remains the best forcing mechanism to decide what content to remove and what to include to maintain the integrity of the story and to respect your audience. 

It’s been said that there is nothing new in the world, only history you haven’t read. Well, the fact is that there is nothing new in the five elements noted above, but it’s important that we remind ourselves of these fundamentals to capture our audiences’ attention and mind share.

Ron Cappello  | CEO

Infinia Group LLC

rcapello@infiniagroup.com

BUILDING THE BEST LINKEDIN PROFILE

Why should you complete your Linkedin profile:

• Having a completed profile improves networking success.
• People are looking at your profile regardless of its current state so make it the best it can be.

Getting started:

• Take a critical look at your profile- it is the first thing people see when they search for you.
• Upload or update your profile photo. It should be current, professional and show that you are confident, successful, and trustworthy- SMILE!
• Add a background photo. This is the second visual element at the top of y our profile page. It can grab people’s attention, set the context and show a bit more about what matters to you. This may be a photo of a world cloud containing keywords to reinforce your message, of the areas of medicine your center is focused on, an abstract image, a quote that serves as your professional compass or your center’s logo, for example.
• Create a captivating headline. You have 220 characters to describe what you do using brief, compelling words. Your headline should be an updated snapshot of your current role at your ASC.
• There’s no rule that says the description at the top of your profile page has to be your job title. Use keywords that people might use to find someone like you.
• Use the headline field to say a bit more about how you see your role and how you serve your patients, manage your center and work with your physicians.

Nina Dietrich, LLC

A Public Relations and marketing communications firm.

nina@ninadietrich.com



Nina is NJAASC’s PR and Communications expert

WHERE IS PROTECTED HEALTH INFORMATION WITHIN THE ORGANIZATION?

When it comes to the HIPAA Rule (Privacy and Security) all Covered Entities and Business Associates are required to protect the Confidentiality, Integrity and Availability (CIA) of all the patient data that is created, maintained and transmitted by the organization.

C’mon people – this is HIPAA 101!

Unless your organization is conducting a comprehensive Risk Analysis, you have already violated the HIPAA Security Rule:

Risk Analysis (Required) – 164.308(a)(1)(ii)(A): Conduct an accurate and thorough assessment of the potential risks and vulnerabilities to the confidentiality, integrity, and availability of electronic protected health information held by the covered entity or business associate.

More importantly, without conducting a Risk Analysis you have not identified where all PHI and ePHI is within the organization.

Document ALL applications and systems containing ePHI; secure all PHI in paper form, have Business Associate Agreements signed with all third parties accessing the organization’s PHI, and put security measures in place for all users accessing the PHI/ePHI. 

Dawn Meglino

HIPAA Compliance Specialist, CHPSE, CCSA, CCAP

DMeglino@ANATOMYIT.COM

From a Center:

The surveyor wanted to see complete reconciliation of pathology in the log:

• Patient information
• Doctor information
• Date specimen collected
• Date picked up from the lab courier

• Disposition of specimen if not picked up the same day (i.e., specimen refrigerator)
• Date report received
• Confirmation and date that the results were reviewed by the doctor.

Risk Assessments

Several of the regulations that affect the ambulatory surgery centers require the performance of risk assessments. Some are very specific, i.e., an all-hazard risk assessment that will be used to develop the Comprehensive Emergency Preparedness Plan (CEMP). There are lots of

templates available for use, including the ASCAssociation.org website.

Here is a list of risk assessments that you should conduct. Have them available for the surveyors to review, as many are required to be used to develop plans, i.e., Infection Control Plan. Refer to the Physical Environment Checklist (PEC) in v41 for specifics.

1. Advanced Wet Procedure Room Assessment (Include whether facility has line isolation monitors or GFCI outlets)
2. AORN Fire Risk Assessment (may be used during the time outs)
3. Chemical Risk Assessment
4. Construction Infection Control and Safety Assessment (v41 7.II.B) before commencing demolition, construction or renovation while the facility is occupied
5. Facility-based and community-based all-hazard risk assessment used to develop the CEMP (v41 8.II.A.2)
6. HIPAA/HITECH Privacy & Security Assessment (best if conducted by a qualified IT provider
7. DVT risk assessment (v41 10.I.M)
8. Fall Risk Assessment (Clinical)
9. TB Risk assessment (OSHA – state-specific)

You don’t have to reinvent the wheel to find examples of these tools. Make sure to use them to develop your plans and show that they were reviewed and incorporated into your plans. One suggestion is to create a spreadsheet with each plan that shows what you did to address the priority: staff training, developed a new policy, etc.

Ann Geier, MS, RN, CNOR(E), CASC

Ambulatory Healthcare Strategies

AGeier@AH-Strategies.com

Q: Who can sign executed DEA 222 Order Forms?

A: Registrants and individuals given power of attorney by registrants can sign DEA 222 order forms. Any registrant may authorize one or more individuals to obtain and execute DEA Forms 222 by granting a power of attorney to each such individual.

To grant a valid power of attorney, the power of attorney must be signed by:

• The registrant, if an individual; a partner of the registrant, if a partnership; or an officer of the registrant, if a corporation, corporate division, association, trust, or other entity.
• The person to whom the power of attorney is being granted, and
• Two witnesses.



In addition to the signature requirement, a valid power of attorney is subject to the following provisions: A power of attorney executed may be signed electronically by any or all the persons required to sign. The power of attorney may be revoked at any time by the person who signed the most recent application for DEA registration or re-registration and two witnesses. The power of attorney should be filed with executed DEA Forms 222 if applicable and must be available for inspection. The power of attorney is not submitted to DEA, but it must be readily retrievable for inspection. In sum, individuals granted a valid power of attorney may sign DEA 222 order forms.  

Amit Gupta RPh, Pharm. D, CCP

Consultant Pharmacist

amit@amitguptaconsulting.com

Q: We are a one-room center licensed last year. We got a bill from NJDOH for our 2022 license stating in arrears. I thought we did not have to pay for this?

A: You do not. NJDOH apparently switched to a system called Dominion that is causing problems. You need to reply back to them that you are a one-room center and per the One Room Law you are not

responsible for initial and subsequent license renewal costs. And, of course, you are not subject to the ambulatory assessment.

Q: If a person finishes an accredited SPD program with certification can they do the 400 required hours under a preceptor at the center who is a certified SPD employee with 15 years’ experience.

A: Yes. Only HSPA requires 400 hours work and does not limit where the 400 hours are given, just verification of the hours and what experience the person received.

Q: We started doing New York PIP cases and got a denial for the 45-day rule. Is this true? Can you explain?

A: The 45-day rule is based on Regulation 68. It reduced the time to submit a medical bill from 180 days to 45 days.

Q: We want to move file cabinets that contain patient charts, and another contains employee files. Do they have to be behind a locked door or is the locking portion of the file cabinet sufficient?

A: Yes, you can do that. The records need to be secure, but locked cabinets suffice as long as they are always locked when unattended. 

Q: We have an ongoing issue with getting MDs to submit MMR, Hep B titers & 2 step ppd on hire. Is it still required?



A: DOH no longer requires annual TB testing if the facility annual TB risk assessment is LOW ( this from the 2020 regulation). However, NJDOH still requires that all new hires need pre-placement testing (tspot or Quantiferon TB gold), unless the new hire has a result from testing done within the past year.

Strategic HR examples include tasks that are future- and value- focused such as:

1. Building a pipeline of high-quality job candidates
2. Managing training and certification pathways for employees
3. Improving employee engagement and productivity
4. Developing employee retention programs
5. Planning strategically for employee and leadership succession

Interviews, onboarding, performance reviews and other HR services can benefit from strategic input to create better experiences for candidates and employees. A strategic approach to HR can also help your company avoid common HR mistakes that involve tactical HR processes.

HR planning is an ongoing process. Your HR strategy should be reviewed regularly and updated as your organization changes. The key is to choose strategic initiatives that align with your company’s goals. The role of HR is to be a business partner to a growing organization.

Jeanne Roman

INSPERITY

Jeanne.roman@insperity.com

While it may be difficult to collect every dollar owed by patients, your point-of-service collections goal should be set at 100%. With the right processes in place, striving to collect in full will become the norm. If your current collections success rate is considerably below 100%, hitting this figure right away may prove difficult. Build toward it over time, perhaps supporting your efforts with a quality assurance and performance improvement (QAPI) study.

Kathryn Boylan

SISFIRST

kboylan@sisfirst.com

Time is money!

Collectability is a real word, even though when I try to type it, it gets auto corrected to copycat or colostomy!

Collectability basically means what are the chances of a bill actually being paid. Even though collectability of a medical bill is fairly high early on- about 90% in the first 60 days, those numbers quickly drop off once you go past 90 days. At 180 days collectability is down to 20%; at 1 year it is less than 10%, and at 2 years the chances of getting paid are less than 1%. If you wait too long to send your accounts to a collection agency, not only are you hurting the chances of getting paid, but also increasing the chances of complaints from angry patients, and possibly even lawsuits.

Jonasz Knapik

SAVIT

jonaszknapik@gmail.com

The TICA imposed a $10,000 limitation on the amount of state and local tax (SALT) that individuals (or pass-through business owners) may deduct from Federal Income Tax. In response, a multitude of states have countered with enacting PTET (Pass Through Entity Tax) elections as a workaround. As such, effective for tax year 2020, New Jersey implemented the BAIT program (Business Alternative Income Tax), which is an elective entity-level tax on pass-through businesses. The BAIT provides a workaround to the federal limitation for state tax deductions. Pass-through entities such as partnerships, LLCs and S corporations can elect to pay New Jersey income tax at the entity level, and the owners would receive a credit on their personal returns for the entity-level paid tax paid. This can effectively eliminate the federal limitation on the SALT deductions of $10,000 imposed by the 2017 Tax Cuts and Jobs Act (TICA).

A number of different factors should be considered in determining if a business should make a BAIT election. The BAIT can be a vital tool as part of any business tax planning strategy. However, each business (based on their facts) needs to weigh the potential benefits along with the risks in determining the right course of action.

Jason Rosenberg

WITHUM

jrosenberg@withum.com

To identify revenue cycle shortcomings, monitor key performance indicators (KPI) and compare your performance against benchmarks. One KPI worth tracking is days to bill/charge lag. Monitoring the average days to bill helps ensure cases are billed promptly and payments are received in a timely manner. The standard benchmark for this is less than two days. 

Karena McKenzie

SURGICAL NOTES

Karena.mckenzie@surgicalnotes.com

Training, Education and Consulting for Sterile Processing and GI/Endo

TIDBIT FOR NOVEMBER

The JC and other surveying groups always focus on immediate use steam

sterilization (IUSS). Here are some steps to ensure compliance with AORN and

AAMI standards.

• Obtain, review and ensure compliance with manufacturer’s instructions for use (IFU) to determine if the device or instrument may be reprocessed via IUSS. If not, IUSS of the specific device/instrument should not be performed.
• The IFUs should be read when the device is purchased so you know, in advance, if IUSS is permitted. This may impact your process.
• If IUSS is permitted, follow the IFUs exactly for the cycle type, temperature setting, exposure time, and drying times (if applicable).
• Understand that IUSS requires compliance with ALL the steps, including the cleaning and transport of devices. 
• Do you have the specific cleaning equipment (e.g., sonic cleaner, mechanical washer) to comply with the entire IFU? 
• Items are to be reprocessed in approved/validated rigid containers or trays that have been validated for IUSS. Determine if your containers are validated for both pre-vacuum and gravity displacement cycles as some devices still require gravity cycles. Not all IUSS containers are validated for this cycle.
• IUSS should not be used for mere convenience, or due to limited instruments or equipment for the number of cases/procedures performed.
• Adopt evidence-based guidelines to minimize IUSS. Develop key performance indicators for the percentage of IUSS that is permitted (e.g., 2% of items processed).
• Make sure you have a QA process to review all IUSS cycles which should include the reason the IUSS cycle was performed.
• Make sure your IUSS documentation includes:
• Date, time, sterilizer number or identifier
• The results of any Bowie-Dick or DART testing performed (first cycle of the day)
• Results of BI test (performed first cycle of the day)
• Specific description of item (S) being processed in IUSS
• The cycle selected (pre-vacuum or gravity)
• The exposure time and temperature set on the sterilizer
• Documentation that the IUSS container was cleaned prior to use.
• Documentation of any preventive maintenance that was performed on your IUSS container(s) (e.g., venting of the valve)
• If you have multiple IUSS containers, label each with a specific number or letter (top and bottom) to track maintenance performed and any quality issues. 
• Traceability to the patient for the IUSS item(s) (for example, a copy of the patient ID label)
• Documentation of the chemical integrator result (AAMI recommends a Type 5 CI be used in all IUSS cycles.
• Documentation of the BI result (if used in the cycle).
• Initials of the person who performed the IUSS and removed the items from sterilizer (if different)
• Reason for IUSS (should have specific reasons listed)

Nancy Chobin, RN, AAS, ACSP, CSPM, CFER

Sterile Processing University, LLC

Nancy@SPDCEUS.com

414 River View Plaza Trenton, N.J. 08611 •  (609) 503-7696  • info@njaasc.org

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