As I See It

It really isn’t that hard

There’s no need to fear Medicare inspections.

By Paul S. Koch, MD, Editor Emeritus

“We’re from Medicare and we’ll be here for three days inspecting your facility.” And with that greeting the team walks into the surgery center for their unannounced visit.

We have had Medicare inspections ever since we opened our first surgery center in 1985. Back then one person would come in for a few hours, but now it takes almost a week. They used to read policy books and review employee records. Now they follow a patient through the facility to see if we follow our written policies. It’s a better inspection.

No surprises

There have been many articles and lectures detailing horror stories about these inspections, but this is not one of them. I’ve also read about facilities with 150 deficiencies whining about how tough the inspectors were. Come on, if you’ve got that many deficiencies, you’re just not paying attention.

I think Medicare, or CMS, or whoever ultimately is in charge has been very fair to us. They tell us what they expect and keep few secrets. That doesn’t mean we necessarily agree with them or like their decisions, but they do announce everything.

CMS publishes a document called the Conditions for Coverage in which is detailed every requirement to achieving Medicare Certification for a surgery center. The document is not a secret. You can Google it and find it online. It’s about 165 pages long and covers everything from welcoming the inspectors to maintaining a clean environment to doing criminal background checks on employees. Nothing is left out; everything is there in black and white. They spell out what we have to do to be certified, and then they hold us to it.

Do your homework

A few years ago I printed 25 copies, put them in binders and gave a copy to every employee at our surgery center. Every Tuesday afternoon we collectively reviewed 20 pages or so until we worked our way through the whole manual. After reading each paragraph we asked: “Do we do this? Are we in compliance?” If we were not we would have to be by the next week in order to move on.

This exercise helped the entire staff participate in writing our policies, understanding them and following them.

It paid off. The next time we were inspected we had only two deficiencies. A year or so later they came back and this time we happily had no deficiencies. I give credit to manager and staff reading the Conditions and doing what it said we had to do.

So, if Conditions says to have someone certified in infection control, get someone certified. If it says to read and follow instructions on every spray can, read and follow.

If it says to meet at midnight and hop around on one foot, gather together and hop. If it says to feed the inspectors Twinkies, have a box on hand. (It doesn’t. They’re for me.)

There are no secrets. They are not trying to trick us. They publish the requirements for all to see, and all they want is for us to follow them. OM

Paul S. Koch, MD is editor emeritus of Ophthalmology Management and the medical director of Koch Eye Associates in Warwick, RI. His e-mail is pskoch@clarisvision.com.