VOLUME 26, ISSUE 1
with asking rhetorical questions. While I enjoy working at the hospital, if I am not a hospital employee why is this my issue?
The answer is simple as an Independent Contractor/Private Practice Anesthesiologist and Medicare provider it is my responsibility to know and comply with the Medicare COPS/IGs or threaten my hospital’s ability to be paid by Medicare for services rendered and as such our fates are intertwined.
My advice from that experience: review and memorize and have easy access to the COPS and IG’s (Save these webpages on your smartphone www.asahq.org/Home/For Members/Clinical
Information/Interpretive Guidelines Implementation
Templates and cms.gov/Regulations-and-Guidance /Guidance/Transmittals/downloads/R74SOMA.pdf). Also know who the CMS designated director is or designate a partner to be the CMS /DNV/TJC Compliance Liaison and phone him/her when the inspectors arrive so they can meet with the “Anesthesiology Department”.
My most recent experience has been much more positive because many of the rules surrounding the COPS and IGs are subject to interpretation. So, the encounter went something along the lines of this:
Me: “Welcome to our Hospital, thank you for coming, how can I be of Service?”
Hospital Inspector: “You need to take the needles and syringes off of the top of the Pyxis Machine.”
Me: “Why?”
Hospital Inspector: “They are unsecure and anyone could walk in and use them.”
Me: “The operating room suite is secured by key pads, cameras, and O.R. personnel, with security guards available on call during the daytime and moving the needles and syringes into the pyxis could delay the administration of life saving medications when seconds count.”
Hospital Inspector: “What about after hours?
What if the janitor comes in and uses the needles and syringes?”
Me: “Again, the cameras, keypads, and hospital security are available.”
Hospital Inspector: “That seems reasonable. Be sure to define your security measures to the CMS inspectors.”.
Lesson learned is it does pay to engage inspectors and consultants. Had I not done so our needles and
syringes, items easily acquired “on the street” for any potential abuser, would have been inconveniently, unnecessarily, and I would argue unsafely locked away based on this consultant’s recommendation.
Also worth mentioning, because our group has had to revise our Anesthesiology records and postoperative notes on a number of occasions based on inspectors and consultants’ vague recommendations; whether your group is still using paper or is using an AIMS, consider the following in your Post Anesthesia Note based on CMS COPS and the ASA IGs Template:
