CMS updates guidelines for ambulatory surgical centers—can hospital SOM be far behind?

by A.J. Plunkett (aplunkett@decisionhealth.com)

CMS has updated Appendix L of its State Operations Manual (SOM) with guidance on new or revised Conditions for Coverage (CfC) for ambulatory surgical centers (ASC) that have been formalized in various final rules from the last few years.

That includes revisions related to NFPA requirements, burden reduction, interoperability, and emergency preparedness requirements. Other updates reflect procedures for declaring an immediate jeopardy and clarification of the definition of an ASC, as well as various infection control, medical record, and other revised requirements.

Often the changes are minor or an update in language, such as a change from referencing “CMS regional offices” to “CMS locations.” There are also updates to the ASC system tags used by CMS in the interpretive guidelines.

The changes were published in the June 3 memo QSO-22-16-ASC, which also notes that the last time Appendix L was updated was in late 2019, and that “currently, the online version of Appendix L has several placeholders in the tags that note ‘guidance pending and will be updated in a future release’.”

The QSO memo says that the changes attached to the memo is an advanced copy of Appendix L and “provides those updates.”

The reference to “guidance pending” is also the same language used for the interpretive guidelines for several substantive changes to Conditions of Participation (CoP) outlined in hospital Appendix A, which is also awaiting update.

Like Appendix L, the online version of Appendix A says it was last revised on February 2, 2020.

No word yet on if Appendix A is next. The Accreditation & Quality Compliance Center will keep watch.

Summary of changes to Appendix L

In the meantime, here is the summary of changes to the ASC requirements and guidelines as outlined by CMS:

  • Definition of an ASC—Minor clarifications added to the guidance for space sharing and recovery centers.
  • New periodic written notice requirement—Added guidance regarding written notice to the local hospital about the ASC’s operations and patient population served.
  • Anesthetic risk and evaluation—Revised tag numbering and added guidance based on the regulation change to allow a physician or anesthetist to examine the patient to evaluate the risk of anesthesia.
  • Fire and building safety—Added guidance in several tags to align with the regulatory changes and adoption of the 2012 editions of the Life Safety Code and Health Care Facilities Code.
  • Medical records—Clarified language related to medical records systems and confidentiality of clinical records.
  • Infection control—Added clarifications related to reporting of infection control breaches that could potentially expose patients to the blood or bodily fluids of another.
  • Patient assessment and admission—Added guidance addressing the regulatory change to the history and physical requirements.
  • Emergency preparedness—Cross-reference added to Appendix Z for the ASC emergency preparedness tags.
  • Other technical corrections—Corrected regulatory numbering, added acronyms, and revised terminology to align with CMS Regional Office name change to “CMS Location.”
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