‘Deemed status’ to affect you — Do you know how?

Under new federal regulations expected to become final later this month, the Accreditation Association for Ambulatory Health Care (AAAHC) in Skokie, IL, and the Joint Commission on Accreditation of Healthcare Organizations in Oakbrook Terrace, IL, may grant Medicare certification and accreditation to surgery centers.

Those regulations mean less duplication of effort for same-day surgery (SDS) managers and an end to delays for centers seeking initial Medicare certification. But the granting of "deemed status" by the Health Care Financing Administration (HCFA) in Baltimore will lead to other changes in accreditation standards and surveys.

"On the AAAHC application form, an organization is going to be able to check a box as to whether they want their survey to be a special Medicare survey or an ordinary survey," says executive director Christopher A. Damon, JD. "We would apply all the same standards, plus some additional ones."

In one significant change, surgery centers seeking both Medicare certification and accreditation will be subject to unannounced surveys, as required by HCFA. Accreditation surveys will continue to occur on a three-year timeline.

Both the Joint Commission and AAAHC have included new Medicare-related standards in their 1996 manuals. For example, HCFA requires surgery centers to have a separate recovery area and waiting area.

"That would be a problem for a very small surgeon’s office or someone else who is using space in a creative manner," says Damon. "Some doctors may use an OR as a recovery room. Medicare doesn’t permit that." Surgery centers seeking both accreditation and Medicare certification would need to create a distinct recovery room and waiting area to comply, he says.

HCFA also requires a Medicare-certified surgery center to "operate exclusively for the purpose of furnishing surgical services to patients not requiring hospitalization." The surgery center must be distinct from a doctor’s office or clinic, with separate record keeping and staff.

In many cases, the Medicare-related standards simply are more detailed than previous AAAHC or Joint Commission standards. For example, HCFA requires specific emergency equipment in ORs, including emergency call systems, oxygen, mechanical ventilatory assistance equipment, cardia defibrillator, cardiac monitoring equipment, tracheostomy set, and endotracheal tubes.

"For an organization that’s already accredited, this shouldn’t be that much different," says Tod Tappert, MPH, MA, associate director of ambulatory care accreditation services for the Joint Commission. Because the necessary adjustments were included in the 1996 Joint Commission manual, accredited surgery centers probably already comply, he says.

The HCFA rule requires surgery centers to notify their state health agencies of their accreditation status. The state officials will then inform HCFA.

Accreditation now worth more

Perhaps the greatest impact of the HCFA "deemed status" rule, which is expected to become final by Nov. 22, is to make accreditation more valuable. Already, many managed care organizations prefer — or insist — that ambulatory surgery centers receive accreditation.

"There are some payers across the country that are saying if you’re not accredited, you can’t even be part of the preferred provider organization," Tappert notes.

For new surgery centers that have faced delays in getting Medicare surveys due to federal budget constraints, deemed status may be a lifesaver. Both the AAAHC and the Joint Commission have made provisions for new centers to receive quick surveys.

The AAAHC previously required centers to be in business for six months before they received their initial accreditation survey. That requirement has been waived to allow for surveys within a few days of opening, Damon says. Surveyors would return in about six months to complete the survey process, he says.

The Joint Commission’s "early survey option" allows for an initial survey even before a center opens its doors. "We can actually survey them before they open as long as they’ve got a facility in existence, staff, policies, and procedures in place," says Tappert. "We come back six months later and look for the track record."

Neither organization expects an increased demand for accreditation to create delays in the AAAHC or Joint Commission surveys. Damon notes that the AAAHC added staff and surveyor training programs last year when accreditation demand increased due to a California law that required accreditation, Medicare certification, or licensure for all surgical facilities. (For more information, see Same-Day Surgery, June 1996, p. 70.)

"We are gearing up, so there will be minimal delays if any," says Damon. "All of the people already accredited by us will continue on their three-year schedule."