Ambulatory Surgery Center Transfer Agreement
1. CSA must not have a written transfer contract or hospital planning privileges for all physicians. Centres must provide hospitals with a document containing information about their surgery and patient population. The Centers for Medicare – Medicaid Services (« CMS ») has issued a final rule that significantly reduces many supplier obligations, in response to an executive order from President Trump, who urged the Department of Health and Human Services (« HHS ») to limit regulatory constraints. In particular, the final rule ends the requirement to enter into written transfer agreements with local hospitals through ambulatory centres (ASCs), to remove rules that require CSAs to perform certain patient assessments prior to surgery, and to reduce emergency prevention requirements for CSAs and other providers. The final rule is expected to come into effect on November 29, 2019. « This rule allows outpatient surgical centres to remain effective and affordable outpatient surgery providers without compromising their commitment to patient safety, » said William Prentice, CEO of ASCA. Proposed rule: CMS proposed to « remove the current requirements from paragraph 416.52 A) and replace them with requirements that, to some extent, defer CSA policy and the clinical judgment of the occupational physician, to ensure that patients receive appropriate preoperative assessments, tailored to the patient and type of surgery. » The surgical physician must still document in the medical record all pre-existing diseases and test results that must be taken into account before, during and after the operation. In addition, all pre-surgeon assessments should continue to contain documents relating to drug and biological allergies. If completed, the H-P would be included in the patient`s medical record prior to surgery. While 43 states require CET accreditation, only 30 require the ability to obtain emergency outpatient care. Fifteen of them are asking for a hospital transfer contract. The others require either an agreement or a hospital that grants privileges to CSA surgeons.
(See the « State Situations » sidebar.) ASCA members can access resources that break down the load reduction rule. These include a table that directly shows changes to the CSA`s (CFC) coverage conditions and a pager that shares medical history and physical assessment (H-Ps) conditions and transfer agreements.