By Stephen W. Earnhart, MS
Earnhart & Associates
Austin, TX

The outpatient surgery market is ever-changing, and staying up to date is not always easy. As consultants, my team always looks for new ways to stay ahead of the game and find opportunity before someone else. Some of our current projects might work for you.

As a caveat, every state provides its own rules and regulations for healthcare facilities, so not all these ideas will work in every state.

Two Separate CMS Numbers in One ASC

The concept of two separate licensed and Medicare provider numbers in the same space is not novel, but most in the industry don’t always see the advantage to it.

Some facilities want the opportunity to “go out of network” billing for some procedures rather than be hampered by “in-network” contracts. A facility that has payer contracts cannot go out of network, so this is an opportunity for performing those procedures in the same location of the existing in-network ASC. This is especially helpful for facilities burdened with lousy payer contracts and want to shift their cases into the “new ASC” that has no contracts. Hence, they can bill those cases as out of network.

Also, this is great for single-specialty ASCs that only operate a couple days per week and want to expand with new investors and specialties but not get into the existing surgeons investment.

The option of providing two Medicare Provider numbers in the same space isn’t without its restrictions. For example, you cannot function with both at the same time, and there are a lot of paperwork and hoops to jump through. For most, it is well worth the effort.

Expansion into Total Joints (TJs)

We talked about this before, but it is now becoming the industry norm for both hospitals and ASCs. Many are jumping into this opportunity before it is too late, in the sense that other groups in your town will lock up all the “bundled fees” contracts in an exclusive relationship with the hospital HOPD or an ASC.

It is difficult to perform these procedures due to the size of the sterilizers required for the unusually large instrument trays that the instrumentation for TJs require. Plus, most instrument prep rooms are just too small to accommodate these oversized sterilizers. A good architect could fix that for you. Word of caution: Do not move forward on these changes based on a passing interest by your orthopedist. Get a firm commitment before you take on this expense.

Overnight Beds in Recovery

The ability to keep patients up to 24 hours in an ASC is not of interest to most ASCs, but it is huge if you are trying to attract new specialties and users.

Walling in existing secondary recovery cubes or space isn’t that expensive and doesn’t necessarily lead to a reduction in the number of recovery beds. Providing this space is a great attraction to some surgeons who would probably perform more procedures at your facility if he or she had this overnight recovery “safety net” available. Not everyone understands this concept. You can actually keep patients longer than 24 hours in your ASC if medically necessary, but you cannot plan on keeping them longer than 23 hours and 59 minutes. There is a big difference in the eyes of the states and CMS on that distinction.

Offsite Recovery Centers

With the advent of more spine, shoulder surgery, and total joint procedures performed in ASCs and HOPDs, the concept of an expansion of recovery time, up to and beyond 72 hours, is growing. Almost all our facilities now include a separate recovery center for those procedures currently performed in the facility or anticipated procedures in the coming year(s).

They require very little space (less than 2,000 square feet for four private rooms), are economical to operate, and, in most states, do not require extensive licensure. Like with everything else, do your homework as there are many moving parts to setting these up. But if you do, they are a great adjunct service to busy and productive ASCs and HOPDs.

Study some of these options and others available to you. Outpatient surgery is just a few years away from being called just “surgery.”

Earnhart & Associates is a consulting firm specializing in all aspects of outpatient surgery development and management. Earnhart & Associates can be reached at 5114 Balcones Woods Drive, Suite 307-203, Austin, TX 78759. Phone: (512) 297-7575. Fax: (512) 233-2979. Email: Web: