THE WEEK OF NOVEMBER 14, 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.

MAY A PATIENT BE TRANSPORTED HOME BY UBER AFTER RECEIVING ANESTHESIA?

The New Jersey Administrative Code states that if a licensed facility administers anesthesia to a patient the facility policy should be that a patient should not drive themselves home and should be accompanied home by another person who accepts responsibility for the patient.

However, if the patient fails to comply with the above requirement, e.g., the patient orders an Uber to drive the patient home, such non-compliance will need to be documented in the patient's medical record.

Therefore, a patient may be transported home by Uber, but this action will be in opposition to the facility policy.



If anesthesia is administered in an office setting, the Board of Medical Examiners requires a practitioner to make sure the patient is discharged into the company of a responsible individual. A patient would not be permitted to take an Uber home because Uber and other ride sharing entities do not take responsibility for their passengers as required by the Board of Medical Examiners. Unlike the rules governing a licensed facility, the Board of Medical Examiners does not permit noncompliance by the patient as an exception for a patient to take an Uber home.

Sources: NJAC 13:35-4A.6 (d)(4)

NJAC 8:43A-12.14(b)(8)

TEXTING ELECTRONIC PROTECTED HEALTH INFORMATION

The HIPAA Security Rule “requires Covered Entities and Business Associates to maintain reasonable and appropriate Administrative, Technical and Physical Safeguards to protecting ePH.” specifically, to:

• Ensure the Confidentiality, Integrity and Availability (CIA) of all ePHI created, received, maintained or transmitted
• Identify and protect against reasonably and anticipated threats to the security and integrity of the information
• Protect against reasonably anticipated, impermissible uses or disclosures
• Ensure compliance by the organization’s workforce
• Stipulate what text messages are permissible.  Sending text messages that do not include personal identifiers would be considered okay. If a patient consents to text messaging (be sure this is documented) and understands the risk of communicating personal information over an unencrypted channel, and that the message complies with the “minimum necessary” standard.  Other than the two categories above, text messaging ePHI or any form of patient data is not secure unless a HIPAA Compliant application or solution is put in place, meaning a secure encrypted network with access controls and audit controls to satisfy the requirements of the HIPAA Security Rule.

Dawn Meglino

ANATOMY Compliance Specialist, CHPSE, CCSA, CCAP

DMeglino@ANATOMYIT.COM

From a Center:

The surveyor wanted the facility to have the list of ‘Never Events’ (list of events that should never happen, e.g. wrong side/site surgery, etc.) accessible.

Data Analytics/Outcomes and the QAPI Process

Claire Cerame, MSN, RN

Positive Outcomes Healthcare Quality Improvement, LLC

ccerame@PositiveOutcomesQI.com

From a Center:

Make sure you have discharge summaries for any patient transferred to a hospital.

Make sure if you are doing pediatrics that your policy states the age and that you have appropriate equipment, supplies and PALS for that age.

Today, organizations are managing a substantial number of disposable and reusable instruments. And, with cost, staffing, and time constraints, it is difficult to ensure appropriate inspection, cleaning and reprocessing of these instruments.

To ensure patient safety, it is imperative that facilities confirm whether an instrument can be reused and reprocessed. Checking the manufacturer IFU for consumable items can confirm the intended use for the device and avoid accreditation surveyors from noting the reprocessing of a single-use devices.

Katie Rudolphi

ONESOURCE

Katie.rudolphi@ridatix.com

Further discussions regarding Hazardous Drugs

and important classification of

Hazardous Waste

After working with your pharmacist to determine if you have hazardous drugs on your formulary please determine if you need a compliance package to meet USP800 regulations.

Remember these drugs can be harmful to your staff if they are in contact with them. Regulations for USP800 will soon become enforceable.

Complete the same process for Hazardous Waste in your facility.

Here are a few tricky questions and specific guidance for epinephrine and nitroglycerin:

1. Do Epi-pens that have been used constitute hazardous waste? NO, Epinephrine that has been prescribed for an individual's use, such as in an emergency kit to treat allergic reactions (commonly referred to as "Epi-Pens") are considered household hazardous waste and are exempt from the hazardous waste regulations. 
2. Do glass ampules or syringes from which epinephrine has been withdrawn constitute hazardous waste? NO, Epinephrine use in medical applications is usually in the form of epinephrine HCL which is a salt and is therefore not a listed hazardous waste when it is disposed of. USEPA has also stated that residual epinephrine that remains in a syringe or carpule after it has been injected has been used for its intended purpose and would not be classified as a P042-listed hazardous waste.
3. Do glass bottles containing nitroglycerin which has been administered to a patient constitute Hazardous waste? NO, medicinal nitroglycerin itself is not a U.S. Federal Hazardous Waste. Medicinal nitroglycerin may be disposed by incineration in an approved incinerator. Syringes containing residual medicinal nitroglycerin should be managed as regulated medical waste. Unopened medicinal nitroglycerin in the original packaging can be returned through a reverse distribution program.
4. 
   

For materials to be considered hazardous waste under the RCRA program (BLACK BOX), and therefore subject to RCRA regulations, they must first be classified as solid waste. Remember the RCRA Black Box accepts all waste, including true hazardous and suspected hazardous waste.

John Karwoski

JDJ Consulting

john@jdjconsulting.net

Q: When the outside consulting company hired by NJDOH does a CMS recertification survey, is it also counting as the NJDOH state survey for the ASC? Centers are getting letters that seem to intimate that.

A: When the consultants hired by NJDOH do a CMS recertification survey, a state report is also generated for the findings, hence the letter from the state.

Lisa Kiernan

NJDOH



Q: We are leasing adjacent space for expansion. There will be a non-structural breakthrough, and an additional sterile room will break through to the perioperative clinical areas. We have read construction codes from DOH and that permits do not need to be applied for if no structural changes are made to the building. We are double checking for any additional advice.

A: You need to speak with your local/municipal building department. It is never a good idea to start taking down walls and reconfiguring things without inquiring, at a minimum. You need to make sure the correct firewall assembly is installed in the sterile supply room.

Anthony Riehl

Healthcare Life Safety Consultants

FYI- When you do construction, you also need to call in and include your IC Professional to do an ICRA assessment.

As per NJAC Title 8, Chapter 43A, Subchapter 19, Physical Plant and Functional Requirements 

8:43A-19.1 Physical Plant General Compliance for new construction or alterations requires that all alterations must: 

Conform with the New Jersey Uniform Construction Code N.J.A,C, 5:22 

Conform to the Facility Guidelines Institute, Guidelines for Design and Construction of Outpatient Facilities.

8:43-A 19.2 Plan Submission; payment of Review Fees 

Schematic Plans must be submitted to the New Jersey Department of Health (DOH) for functional review and approval. 

Upon approval of the functional plan, construction plans prepared by a New Jersey licensed architect shall be submitted to the New Jersey Department of Consumer Affairs (DCA) for Code Review and approval. 

Upon approval of construction documents by DCA, the approved construction plans shall be submitted to the municipal building department to receive Construction Permits.

DOH inspectors verify that that facilities have not been altered by comparing the DCA Approved Plans, that must be on site for review, to the facility to ensure no unapproved changes to the facility have been made. Changes include renaming and/or utilizing a room/area for a function/purpose other than approved by DOH and DCA. All DOH and DCA approved plans for physical alterations and approvals for functional/use changes of existing rooms/areas must be on premises for review. 

Q: We are a registered surgical practice with our license application submitted to DOH and are awaiting licensure inspection. Do we have to be accredited now, or is this something we need to do after licensure?

A: You must be accredited within one year of licensing.

Q: What is the regulation regarding what the patient must wear in the OR? Gown, hair bonnet, shoe covers-are all three mandatory?

A: There is no regulation.  This is policy- and procedure-driven. You should also consult with your IC professional and check the AORN manual for further enlightenment.

Q: Can an optometrist own an ASC in NJ..? He would have several ophthalmologists working for him to do surgeries.

A: No, he cannot. This has nothing to do with N.J.;  this is a Federal ruling that is part of the Anti-Kickback statute from OIG regarding self-referral.

Tactical HR and strategic HR are both necessary for a company to reach its full potential. However, tactical HR must come first because it includes things that make it possible to hire, train, pay and manage employees.

Tactical HR also addresses compliance with employment and benefit rules.

Examples include:

• Processing forms for new hires
• Handling payroll
• Posting compliance notices
• Recruiting and hiring
• Writing job descriptions

Jeanne Roman

INSPERITY

A great way to gain a better understanding of how patients view your collections process is to include the billing experience in patient satisfaction surveys. For any patients who express dissatisfaction with their experience, reach out to find out why and determine if there is anything you can do to rectify the situation. This interaction can help you learn ways to improve your patient collections processes and possibly keep a patient from leaving a negative online review of your ASC.

SIS FIRST

kboylan@sisfirst.com

Try to avoid using unspecified HCPCS codes when billing for implants. Before the claim is submitted to a carrier or when working an appeal, review your implant HCPCS code. If a generic code was used (e.g. L8699), check to see if a more specific code can be used or ensure you are following the payer’s specific requirements.

Karena McKenzie

SURGICAL NOTES

Karena.mckenzie@surgicalnotes.com

Sometimes the accounts payable department does not receive the same priority from a company’s CEO as other departments do. It isn’t often the first area of business to receive cash for improvement. Despite this, AP teams play an essential role in a company’s operations and maximize available working capital.

Here are seven metrics to help get your CEO’s attention:

1. Invoice processing time
2. The price of handline a single invoice
3. Rate of invoice exceptions
4. Recorded vs. offered discounts
5. Number of supplier inquiries, disputes and dispute resolutions
6. Working capital
7. Incorrect payment rate expressed as a percentage of the entire cost

Jillian Dickerson

HYBRENT

hello@hybrent.com

Here are five alarming facts about denials!

1. Denials represent 90% of missed revenue opportunities.
2. 30% of claims are either denied, lost or ignored.
3. Denials push back your reimbursement by an additional 21-45 days.
4. 30% of physicians still rely on a manual claim denial management system.
5. Out of all the denied claims, 65% of them are never reworked.

Conclusion: If you do not have the correct technology or team available to track and work denials effectively, invest in some, or partner with the right billing service.

Nick Rodriguez

CONSENTUS

nrodriguez@consentus.com

3 Questions to Determine If Your Infection Prevention Plan Includes Your Linen



Because of the challenge of healthcare-associated infections (HAIs), medical facilities should have a comprehensive infection prevention plan in place. One area often overlooked in a complete infection protection plan is the linen and laundry service.

Here are three questions you should ask yourself when determining whether your linen is considered in your infection prevention plan:

• Are you receiving “sanitized” or “hygienically clean” laundry service?
• Do you have effective inventory management practices in place?
• Are your linens, gowns and garments stored in a safe place?

If your medical facility doesn’t identify and enforce a strict code of best practices regarding medical linens, involve proper inventory management techniques, and provide protection from airborne pathogens, your infection plan may not be comprehensive enough.

Read more to learn if you are meeting your infection prevention plans when it comes to your linen management.

BRENDAN DOYLE

IMAGEFIRST

bdoyle@imagefirst.com

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

njaasc.org