THE WEEK OF OCTOBER 24, 2022

WELCOME TO THE PULSE!

We have developed The PULSE based on comments and suggestions from the membership and with your input in mind.

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

NJAASC OCTOBER QUARTERLY MEMBERSHIP MEETING

NJAASC held its October Membership Meeting on Wednesday, October 19th at the Galloping Hills Country Club in Kenilworth, NJ.

The meeting was well attended by the membership and featured a great program of speakers, as well dozens of vendor tables to peruse.

A good time was had by all!

Grand Prize Winner Gemma Fandialan, Bergenfield Surgical Center

COMMITTEE MEETING REMINDER

The NJAASC Annual Event Committee will be holding a scheduled meeting on 10/24 at 4:30 PM.

If anyone wants to help with this committee, please feel free to join Bonnie and the committee on the Zoom/call.

Contact Patrick: pstewart@njpsi.com

He will then send you zoom/call-information to join the meeting. 

From a center:

Make sure your back-up DON and Administrator have signed job descriptions in their file for their back-up positions, as well as their primary roles.

Make sure you have PPE strategically placed in your center- at the entrance of all sterile areas and covered hand sanitizer, as well.

Ch 3.E Orientation and training according to position description to all staff.

Why is this a frequent citation during a survey? The most common finding is that the orientation isn’t completed within 30 days of employment (3.E.1). How will a surveyor determine if the center is following this standard?

1. Surveyor will review the orientation checklist
2. Consider adding the first day of employment to the top of the form
3. Consider adding the orientation completion date at the bottom of the form
4. Develop a comprehensive facility orientation checklist
5. This list will include infection prevention, fire safety, and risk management. Basically, this list will include information and training that every employee should complete.
6. For a list of required elements, review the Personnel Records Worksheet in the Tools section of v41.
7. Develop a job-specific orientation that will include training and documentation of competencies based on the employee’s role in the center.
8. Don’t forget the business office, as they need job-specific training, also.
9. The surveyor will then review all the information regarding ongoing competencies and the employee’s evaluations to ensure that they are providing quality care to patients.
10. How long do we have to keep all the information in the files? I suggest keeping the initial information from the time of hire, if available, and the recent information, possibly from the last survey. I recommend that centers scan all the old information and store it in the Cloud. The paperwork is no longer needed, and the information is retrievable.

What happens when an employee has been in the center for several years and the information regarding initial orientation is no longer retrievable? That happens a lot.I asked a long-time surveyor. Here are her comments. These are just suggestions.

"That's a tough one for me. I often tell the organization to separate the initial orientation paperwork, including the application and credentialing documents [RN license]; put that in a sheet protector in the file. Keep the current 2 years. When they don't have the orientation documents and still work for the organization, I suggest an attestation to verify learning during the first 30 days of orientation [as everyone knows, you cannot recreate documentation that doesn't exist, but attestations will let a surveyor know that the standard is understood.] I always recommend a scanning depository, by name and year for all the other "stuff." I will suggest the organization always keep the present year's training/education by subject for ease of use.

       11.What happens if the orientation is/was not completed within 30                   days. The file will be marked NO for the standard. If this                                 occurs for most of the files, it could result in a standard deficiency.

      12. I always ask to review the newest employee’s file, and I’m                              specifically looking for the orientation information.

Don’t take this lightly. If an employee is assigned to care for patients, and orientation was never completed or is still in progress, should a bad outcome occur, the plaintiff’s attorney will have plenty of ammunition to support a lawsuit.

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

Ambulatory Healthcare Strategies

AGeier@AH-Strategies.com

From a Center:

DOH requested that an orientation policy be developed for agency staff.

For use of a jet vent, in addition to having the equipment on site, competency and in service training should be developed for use.

It is recommended that your facility perform a mock drill related to local anesthetic systemic toxicity.

TOPIC: Sodium Bicarbonate Injection - USP, 8.4%, 50 mEq/50 mL Vial, 20-Count Carton by Exela Pharma Sciences: Recall - Due to Vial Breakage

AUDIENCE: Patient, Consumer, Health Professional, Pharmacy

ISSUE: Exela Pharma Sciences, is recalling 49 lots of Sodium Bicarbonate Injection - USP, 8.4%, 50 mEq/50 mL vial, 20 count carton, because the product poses a potential safety concern with vial breakage and flying glass when pressurized while preparing the product for administration.

Exela has received five (5) reports of flying glass injuring skin, eye and/or other parts. There have been no reports of sterility failures.

This recall is not expected to cause drug shortage.

Product was distributed nationwide to wholesalers, distributors, and other customers between December 16, 2021, and August 10, 2022.

For more information about this recall, click on the red button "Read Recall" below.

BACKGROUND: The product is used for treatment of metabolic acidosis.

RECOMMENDATIONS: 

• Exela is notifying its customers by e-mail and certified mail and is arranging for return and replacement of all recalled product directly to the company. 
• Customers that have the product, which is being recalled should discontinue use, segregate the recalled product, submit a recall stock response form to the company, and hold the product until shipment instructions are provided.
• Customers with questions regarding this recall can contact the company.
• Consumers should contact their physician or healthcare provider if they have experienced any problems related to the usage of this drug product.

Health professionals and patients are encouraged to report adverse events or side effects related to the use of these products to the FDA's MedWatch Safety Information and Adverse Event Reporting Program:



• Complete and submit the report online.
• Download form or call 1-800-332-1088 to request a reporting form. Then complete and return to the address on form, or submit by fax to 1-800-FDA-0178.

Amit Gupta RPh, Pharm. D. CCP

amit@amitguptaconsulting.com

Q: Can a graduate from the Assistant in Surgery Program from NIFA work as an assistant in the OR like a PA or RNFA?

A: Yes, they can, They must be an RN to train for RNFA., and you would credential them just like a RNFA. If the person is not an RN she is just a tech and cannot perform the same as an RNFA as it would be out of scope of practice and needs to be certified as an ST. NIFA is Colorado-based and is the nation’s largest RNFA program.

Q: We are an RSP, we were purchased and revoked our DOH license application. What do we do now? What regulations do we follow?

A: IVF centers are looked at on an individual basis by NJDOH. You are now simply a doctor’s office, not a facility, and are governed by DCA.

From Gene Brenycz at NJDOH: ‘If all you are doing is egg retrieval under anesthesia, neither licensure nor registration is required.’

Q: A patient is considered fully vaccinated if they have a booster too, correct? Do we need to test patients who do not have a booster?

A: Two different issues!

For patients - you go by ED 20-016-revised page 6, b. Patients are either fully vaccinated or not. Patients do not require a booster. If not fully vaccinated, they must test and quarantine.

You are confusing patients and staff. For your staff, up-to-date means fully vaccinated and one booster.  Staff must test if they are not up-to-date and means they have a medical/religious exemption.

Q: A question has arisen in my center: What is the minimum clinical staffing number needed by NJDOH for a two-OR facility?

A: Each OR must have a RN circulator and certified tech per OR. According to NJ reg 843A-12.16- PACU staff time and availability: There shall be at least one registered nurse whenever a patient is in the PACU and a second healthcare staff member immediately available.

FYI: There is currently a nurse staffing bill in the Legislature.  

Q: When a patient pays us by credit card, can you add merchant fees (2-3%) to the amount to cover the credit card cost?

A: Our Senior VP says:

Yes, you can charge the patient for those, I would suggest ensuring the patient is not charged above bank fees. To add to that I recommend having a journal code for merchant fees so that the amount can be posted to the patient account for full accounting and transparency.

I personally am not a fan of this practice.  You may want to consider not charging a patient that is paying in full vs. charging a patient that is partially paying their balance, and maybe a threshold, so patients paying less than a certain amount are not charged the fee.

Karena McKenzie

SURGICAL NOTES 

Karena.mckenzie@surgicalnotes.com

The HIPAA Security Rule requires healthcare organizations to maintain reasonable and appropriate Administrative, Technical and Physical Safeguards for protecting ePHI. The HIPAA Privacy Rule sets standards for all PHI: any individually identifiable health information related to past, present, or future provision of healthcare.

There are specific policies and procedures that must be in place in order to be compliant with the HIPAA Rules.

A policy is defined as a set of ideas or plans that is used as the basis for making decisions.

A procedure would be the series of actions conducted in a certain order or manner.

In other words, policies may tend to remain stagnant, whereas procedures would be the exact steps and actions an organization would take to fulfill HIPAA requirements.

Include the following policies and procedures in your organization’s HIPAA Manual:

• Facility Security Plan
• Physical Asset Inventory / Asset Management
• Acceptable Use of Information / Assets
• Hiring / Onboarding Policy and Procedure
• Termination / Offboarding
• Identity and Access Management
• Security Incident Processes and Procedures
• Disaster Recovery Plan / Business Continuity Plan

Dawn Meglino

HIPAA Compliance Specialist, CHPSE, CCSA, CCAP

DMeglino@ANATOMYIT.COM

Surgery centers are busy and always on the go! Staff members often wear multiple hats to get things done, so there is always a need for improving workflow, efficiency and cost optimization.

Consider an easy-to-use and intuitive chart management solution, that would reduce the manual work associated with chart preparation and offering storage (with online search) that does not require high upfront cost and training. It should also interface with the center’s scheduling software.

Sanjay Kaul

MedOfficePro

skaul@medofficepro.com

SHOULD I ATTEMPT TO COLLECT FROM A PATIENT DURING THE HOLIDAY SEASON?

It is a question that I am sometimes asked by administrators and managers.  

The answer is a resounding YES!!

There is never a good time of year to pay a medical bill.  In January and February, you're recovering from Christmas spending. Then it's tax season. June and July is vacation time. August and September are back to school and finally, it's the holiday season again.  

Remember that the collectability of an account drops significantly every month from the date it is initially due. If you wait until Thanksgiving, Hanukkah, Christmas and New Year's are over, your chances of collecting that balance have decreased by 50%.

Set a solid 90-day patient billing protocol and follow it, including sending patients to collections, all year long.

Jonasz Knapik

SAVIT

jonaszknapik@gmail.com

To improve implant billing, develop a payer reference tool. Create a contract matrix your staff can utilize during charge entry, posting, and AR follow-up. The contract matrix should contain the following:

1. If implants are payable
2. If there are threshold requirements
3. If implants are reimbursed at a percentage of charge or invoice cost
4. If the payer allows the reimbursement of shipping, handling and taxes
5. If the payer requires an implant invoice
6. The billing requirements

Karena McKenzie

Marketing Manager

SURGICAL NOTES

Karena.mckenzie@surgicalnotes.com

Attracting and retaining a high-quality staff is important to every ASC, but perhaps most importantly, to a new facility.

Hire the right administrator. One of the most important hires any new surgery center will make is the ASC Administrator or Executive Director.

Among the qualities this person needs to be successful are:

1. A commitment to always putting the patient first.
2. At least three to five years of management experience, either in a hospital or physician’s office. Ideal candidates have managed and been accountable for a P&L statement. They have negotiated vendor contracts and perhaps even insurance contracts. They have been involved with billing and collections. They possess a reasonable understanding of employment law. They have had to get physicians to buy into new policies and procedures.
3. Excellent written and verbal communications skills.
4. Excellent negotiation skills.
5. ‘People’ skills.

Nancy Goldstein MA, RNC

Horizon Healthcare Staffing

nancy@hhstaff.com

The Joint Commission reports that the area of Infection Control is commonly cited for ‘failure to implement IC activities or required evidence-based guidance such as Standard Precautions (IC.02.01.01).

This includes failure to follow state or federal regulations, manufacturer’s instructions for use (IFUs) and/or processes and organizational policies and

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