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THE WEEK OF DECEMBER 12, 2022 | |
CLARIFICATION FOR SCRUB NURSE/TECH ARTICLE
FROM 12/5
Regarding the Scrub Technician article, which stated the scrub technician must be certified, it should read:
If a surgical technician was employed prior to December 21, 2011, they are grandfathered in and do not need to be certified.
It is important that they be able to verify that they have been practicing prior to December 21, 2011.
If not practicing as a surgical technician prior to December 21, 2022, they must be certified, per the NJ Surgical Technology Law, effective 12/21/11.
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. Your 2022 membership runs out January 2023, so make sure you renew in order to attend the events we have scheduled for 2023.
January 25, 2023 - Quarterly Membership Meeting - Galloping Hills Country Club in Kenilworth, NJ: ONLY FOR NJAASC CENTER AND VENDOR MEMBERS.
February 15, 2023 - Infection Control Conference, in cooperation with NJDOH - Galloping Hills Country Club in Kenilworth, NJ: ONLY FOR NJAASC CENTER AND VENDOR MEMBERS
NJAASC would like to thank all of you for your support this past year. As you can see, we have even bigger plans for 2023, including the 13th Annual ASC Conference, April 18 & 19, 2023.
VENDORS
Your renewal invoice includes an option to ‘lock in’ your discounted table for the 13th Annual ASC Conference.
It is your choice, but this offer is only extended in conjunction with your 2023 dues renewal.
If you have any questions about your membership renewal or have not received an invoice, please contact Kelly Biddle: kbiddle@njpsi.com.
NJAASC WOULD LIKE TO WELCOME
ITS NEWEST MEMBER CENTER
University Reproductive Associates, Hasbrouck Heights, NJ
Welcome Aboard!
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RECORD REPRODUCTION
The law applies to hospitals and to health care professionals with respect to their professional treatment and billing records. It does not directly apply to licensed ambulatory care facilities; however, health care professionals are required to apply the law to the records of all health care providers that are part of the health care professional’s
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record. So, if the patient asks a health care professional and he/she has the facility’s records in his/her patient record then it is clearly covered. If the request is made of the ambulatory care facility and the owner is a licensed professional, an argument can be made that it applies to this record request because the owner is a licensee. For example, in the typical radiology model where the professional and facility records are both held by the facility, which is owned by the professional licensees, I would think it applies. But, if the facility doesn’t have any “professional treatment” records there is some ambiguity. Moreover, if a facility is not physician-owned it is not as clear to me that this law otherwise applies to licensed ambulatory care facilities.
John D. Fanburg, Esq.
Brach Eichler
Jfanburg@bracheichler.com
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BUSINESS ASSOCIATES
The Health and Human Services Office for Civil Rights (HHS OCR) describes a Business Associate as a person or entity that performs certain functions or activities that involve the use or disclosure of Protected Health Information (PHI) on behalf of, or provides services to, a Covered Entity.
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The Health and Human Services Office for Civil Rights (HHS OCR) describes a Business Associate as a person or entity that performs certain functions or activities that involve the use or disclosure of Protected Health Information (PHI) on behalf of, or provides services to, a Covered Entity.
Business Associate functions and activities include claims processing or administration; data analysis, processing or administration; utilization review; quality assurance; billing; benefit management; practice management; and repricing. Business Associate services are legal, actuarial, accounting, consulting, data aggregation, management, administrative, accreditation, and financial. See the definition of “Business Associate” at 45 CFR 160.103.
Covered Entities must have a contract or written agreement with ALL Business Associates describing the permitted and required uses of PHI by the Business Associate; that the Business Associate will not use or further disclose PHI other than as permitted or required by the contract or as required by law, and to use appropriate safeguards to prevent use or disclosure of the PHI other than provided for by the contract.
If you do not have Business Associate Agreements in place with all your organization’s Business Associates, this would be a HIPAA violation and may be subject to fines and penalties under the HIPAA Rule.
Frequently asked questions about Business Associates
Dawn Meglino
HIPAA Compliance Specialist, CHPSE, CCSA, CCAP
dawn.meglino@anatomyit.com
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SURVEY SNIPPETS
Shared information from our member centers about their surveys
(Please share with us your experiences, questions and comments. No names or centers will be printed; everything is anonymous.) E-mail to: jshanton@jssurgctr.com.
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The concrete pad that our generator rests on has settled and needs to be replaced. It will take 3 days to complete this repair and we will be renting a generator to keep us operational. Does this need to be called into the state and reported?
As long as the project does not cause the closing of the center, or if there is a period of time when emergency power is unavailable.
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Make sure the concrete pad is installed in accordance with NFPA 110-2010 or later, and the NEC. Make sure all applicable permits have been taken out; sometime municipal building departments can be tough to deal with after the fact. Lastly, make sure the existing generator is PM’d before placing it back in service and keep all documentation to support same.
Anthony Riehl, CFI, CESI
Healthcare Life Safety Consultants
anthony@hlsconsultantsllc.com
AAAHC and TJC allow 3 years for recredentialing of doctors, and surveyors. Look at what your policy says.
CMS [416.45(b] states: The ASC governing body must have a process reappraising the medical staff privileges granted to each practitioner. CMS recommends a reappraisal at least every 24 months. It ‘recommends’ but does not require, according to the interpretive guidelines.
Ann Geier
AH-Strategies
ageier@ah-strategies.com
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THE PHARMACY CABINET
Stay current with the latest Pharmacy news
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Medication Reversal Agents
Patient safety is always at the top of our minds. When reviewing different medications in
Ambulatory Surgical Centers, one question we always like to ask is if the reversal agent is on
formulary. Furthermore, is the drug stocked and can staff locate
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the medication in the event of an emergency? Has anyone recently checked to make sure the drug has not expired? These are all questions to think about in order to be best prepared in the event a medication reversal agent must be used. | |
Per the Institute for Safe Medication Practice (ISMP), it is recommended that all Ambulatory Surgical Centers ensure antidotes, reversal agents, and rescue agents are available to be administered if needed. Ensure coupled order sets and protocols are in place for reference. JDJ Consulting would love to hear from you and how your facility prepares in the event a medication reversal agent must be used.
John Karwoski
JDJ Consulting
john@jdjconsulting.net
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WHAT'S ON YOUR MIND?
Questions from our members
(Please forward any questions you may have, about anything!) E-mail to: jshanton@jssurgctr.com
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Q: We are starting to scan medical records into our scheduling program. Are there rules about keeping a physical copy after scanning, or can I shred it?
A: If you have tested the retrieval capabilities of your scanning system, you do not have to keep the paper charts. If the records are scanned and saved in the Cloud, they are supposedly saved indefinitely.
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Q: Is there a guide for how many Defibs/AEDs an ASC needs?
A: Refer to 8:43A- 12.18
Q: We received a Medicare denial that refers to something called an LCD. What is that?
A: LCD is a Local Coverage Determination and refers to the local Medicare carrier, which, in your case, would be Novitas.
It is a determination by a fiscal intermediary or carrier under Part A/B in respect to whether or not a particular item or service is covered.
Q: Who must be part of my Infection Control Committee? What are the criteria?
A: Your medical director, IC professional, administrator, and your in-house IC person. Refer to 8:43A-14.2
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DOLLARS AND SENSE
Advice to help your center’s bottom line
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Analyzing key performance indicators (KPI), especially those related to collections as a percent of net revenue, can help you monitor revenue cycle health in a direct way.
By clearly defining net revenue and recalculating it consistently every month, you should be able to determine whether your ASC is meeting collections expectations. If it turns out you are not
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collecting as much as you can, find and go after the missing money. Analyzing your data should not only help you identify problems, but also provide information on how to take actions and start solving those problems.
Kathryn Boylan
SISFIRST
kboylan@sisfirst.com
Are you a leader that motivates, inspires and positively influences the team? With the help of these tips, you’ll reflect on your leadership and management style – and find areas where you can grow into a truly exceptional leader.
1.Top leadership mistakes that strong leaders avoid
Great leaders know how to build trust, empathy and enthusiasm into their everyday interactions. The Insperity guide to leadership and management provides insights on cultivating this type of environment and avoiding common leadership mistakes, such as:
- Micro-management
- Unclear and inconsistent expectations
- Failure to notice sagging team morale
2.Tips for managing employees with different temperaments
Every team member is unique. Each employee has his or her own personality, working style, emotional intelligence and strengths. Strong, successful leaders know how to adapt their communications to appeal to individuals. This approach helps minimize staff conflicts and confusion.
When disagreements do arise, savvy leaders are also adept at conflict management.
Encourage leaders to:
- Foster open communication
- Avoid the temptation to generalize
- Focus on performance, not personalities
3. A primer on developing future leaders
Developing future leaders means investing in your team’s personal development and building skills. When developing your next company leaders, consider including:
- The employee’s internal motivation
- How they’re mentored and trained
- Their overall readiness to lead
Jeanne Roman, CBPA
INSPERITY
Jeanne.roman@insperity.com
Procurement automation can save money, which is one of the compelling reasons for the decision-making committee to think about it. Aside from that, the company obtains the following key benefits:
- On a single platform, you will be able to manage all of your procurement and order management activities.
- Project-based requisitions can be accessed directly at the activity level.
- Reduce the amount of paper used and the amount of human processing required.
- Avoiding maverick spending.
- Improve cross-departmental collaboration and communication.
- Assign employees to non-redundant, value-added jobs that are more strategic.
Jillian Dickerson
HYBRENT
hello@hybrent.com
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KEEP IT CLEAN
Infection Control Tips
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Did you Know This?
According to ANSI/AAMI ST-79, “Reusable cleaning brushes should be cleaned after each use and disinfected or sterilized daily, preferably after each shift.”
Single-use brushes should be used for one set/item, then discarded. Staff should be able to differentiate reusable from single-
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use brushes and ensure that single-use brushes are not being reused.
Reusable brushes should be inspected daily for damaged bristles and any other defects. If noted, they should be discarded and replaced.
If a manufacturer specifies a specific brush, it must be used unless an equivalent, validated to meet the standards of the original manufacturer’s specifications, is used.
Brushes are critical to clean lumened devices. The correct length and diameter of the brush based on the lumen size is needed to create friction with all internal surfaces of the lumen. Some specialty devices may require 3 or more different sized brushes to effectively clean the lumens.
Make sure staff is following IFUs to the letter and that they are using the correct size brush as recommended.
Nancy Chobin, RN, AAS, CSPM, CFER
President
nancy@spdceus.com
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SURGICAL SITE MARKING- WHO CAN PERFORM?
Can the surgeon delegate his PA to mark the surgical site? Our policies and procedures list this.We also have a definition of a “surgical team” listing a PA. We also have a PA delegation agreement signed by each surgeon for their PAs.
PA & SURGICAL SITE MARKING
8:43a-12.6, 4 iii
From NJDOH:
A: I have included pertinent regulations from Chapter 43A. Manual of Standards for Licensing of Ambulatory Care Facilities below. The State regulations that our office surveys for include delineation of medical staff privileges, medical staff assignment of duties, and requirements for verification of surgical site and side. I am not aware that the regulations in Chapter 43A. Manual of Standards for Licensing of Ambulatory Care Facilities would prohibit a PA to mark the surgical site. That being said, questions regarding physician and physician extender scope of practice would fall under the New Jersey Division of Consumer Affairs.
References:
8:43A-7.3 Medical director's responsibilities
(a) The medical director shall be responsible for the direction, provision, and quality of medical services provided to patients. He or she shall be responsible for, but not limited to, the following:
6. Assisting in developing and maintaining written job descriptions for the medical staff, participating in the review of credentials and delineation of privileges of medical staff members, and assigning duties based upon education, training, competencies, and job descriptions;
8:43A-12.6 Surgical policies and procedures
(a) The facility shall develop and implement written by-laws, rules, regulations, policies, and procedures for surgical and anesthesia services, in accordance with the governing authority and medical staff bylaws. The policies and procedures shall be reviewed at least every three years and revised as needed, and shall include at least the following: …
4. Policies and procedures regarding pre-anesthesia evaluation, patient preparation, and intraoperative management;
ii. There shall be a policy and procedure to verify the site and side of any and all surgical procedures. The procedure site and side shall be documented on the operative consent form.
iii. There shall be oral verification of the correct site and side of the surgical procedure in the operating room by a surgical team member in accordance with the facility's policy;
5. Policies and procedures to ensure that every patient is examined by a practitioner immediately prior to surgery; …
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30 DAYS OF GIVING
Thank you to our Member Centers that participated in our “30 Days of Giving” campaign. Here is a look at what one of our centers accomplished with their food drives:
Mercer County Surgery Center in Lawrenceville, NJ, donated food to HomeFront in Lawrence Township NJ.
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MEDICARE PAYMENT RESOURCES
ASCA Posts Expanded 2023 Medicare Payment Resources: ASCA has posted multiple new 2023 payment resources to assist members with understanding Medicare reimbursement. Beginning in 2023, Medicare will provide a “complexity adjustment” for certain code combinations, creating 55 new C codes that better reflect the true cost of performing select add-on procedures in conjunction with certain primary procedures. ASCA has posted a 2023 Complex Codes spreadsheet that lists each new C-code, the primary code and secondary add-on code that make up that C-code combination and the difference between the primary code rate and the boosted C-code rate. A new 2023 Device Intensive Codes spreadsheet lists all codes designated as device intensive for 2023, as well as the difference between the proposed and finalized rates. Finally, an ASC vs. HOPD Rate Comparison spreadsheet shows the difference between national Medicare reimbursement rates for all separately payable procedures in ASCs and hospital outpatient departments (HOPDs). These resources, as well as the Medicare Rate Calculator and Medicare Payment Resources (both updated quarterly), can always be found on ASCA’s Medicare Payment Resources webpage. Please contact Alex Taira with any questions.
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The information contained within is proprietary developed by NJAASC for its membership only. Any dissemination or use of this information by anyone to nonmembers is strictly prohibited without the written approval of NJAASC. | | | | |
