CMS updates ASC guidance, revisions for surveyors

Editor's Note

The Centers for Medicare & Medicaid Services (CMS) has recently updated its State Operations Manual (SOM) Appendix L—Guidance for Surveyors: Ambulatory Surgical Centers (ASCs), making conforming revisions to the regulatory tags and interpretive guidelines, as well as clarifications and technical corrections to other guidance areas including medical history and physical (H&P) assessment, periodic written notice, and anesthesia risk assessment.

Here are some highlights regarding the revisions:

• Medical H&P Assessment. ASCs now “must develop and maintain a policy that identifies those patients who require a medical history and physical examination prior to surgery.” While Appendix L has been updated to indicate that H&Ps were no longer required by CMS in all cases, surveyors should confirm that medical records include a “medical history and physical assessment, as applicable, if required by the ASC’s policy.”
• Periodic Written Notice Requirement. The revised Appendix L adds further guidance that the ASC provide the notice upon opening of the facility and at least every 24 months “to ensure the ASC keeps the local hospital informed and up-to-date on ASC information and any pertinent patient population changes.” The revised appendix also provides guidance on what the notice must include.
• Anesthetic Risk Assessment. New language now allows an anesthetist or physician to do an anesthesia risk assessment: “(1) Immediately before surgery - (i) A physician must examine the patient to evaluate the risk of the procedure to be performed; and (ii) A physician or anesthetist as defined at § 410.69(b) of this chapter must examine the patient to evaluate the risk of anesthesia.”

The revisions also include language on informed consent and updates to the Infection Control Surveyor Worksheet.