Medicare Announces Major Changes to Pre-operative H&P and Transfer Agreement Requirements for ASCs

The Centers for Medicare & Medicaid Services (CMS) announced in a Press Release on September 26, 2019, some major changes in the requirements that CMS-approved Ambulatory Surgery Centers (ASC) must comply with.  As part of the “Patients Over Paperwork” initiative, CMS noted it is making efforts to reduce regulatory burdens while still ensuring safety.

The first important change is that CMS removed the mandate that a patient undergo a comprehensive history and physical prior to ASC admission.  CMS now leaves the responsibility to determine the need for this preoperative H&P to the joint responsibility of the facility and surgeon.  In the Press Release on the Omnibus Burden Reduction (Conditions of Participation) Final Rule (CMS-3346-F), CMS noted that they are:

“Removing the current requirements that a physician or other qualified practitioner conduct a complete comprehensive medical history and physical assessment on each patient not more than 30 days before the date of the scheduled surgery. Additionally, CMS is finalizing the requirement that each ASC establish and implement a policy that identifies patients who require an H&P prior to surgery.”

The Final Rule is published in the Federal Register on September 30, 2019.  It is effective November 29, 2019.

ASCs will now have to have a policy that identifies which patients need an H&P.  Even if the ASC’s policy does not require a particular patient to have this comprehensive H&P, the surgeon can still require it.

Another major change relates to the mandate that an ASC has a written transfer agreement with a hospital or that the surgeon have hospital admitting privileges.  CMS noted the removal of:

“… the provisions requiring ASCs to have a written transfer agreement with a hospital that meets certain Medicare requirements or ensuring that all physicians performing surgery in the ASC have admitting privileges in a hospital … [but ASCs still] will be required to periodically provide the local hospital with written notice that outlines the ASC operation and patient population served by the ASC facility.  All ASCs must continue to have an effective procedure for immediate transfers to a hospital for patients requiring emergency medical care beyond the capabilities of the ASC

We are happy to assist groups and facilities with general claims issues and other coverage topics, which include proper code selection, chart reviews, and payer action questions.  We provide training on these and other subjects.  You can download our “App”, Corcoran 24/7 via one of the links below. (800) 399-6565


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