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"Office-Based" Procedures in ASC

IAmTheOne1

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Sep 28, 2016
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    Have a question about logistics/legality of a pain practice set-up...

    Currently have a clinic practice (with no flouro room) adjacent to our own ASC (separated by a wall). Therefore basically all procedures are being done in the ASC. For HMO / out-of-network patients, they are being taken to an in-network ASC at a different location. Ideally, would like to keep these patients in-house and perform "office-based" procedures on them but would like to avoid putting in a separate fluoro room on the clinic side of our practice due to lack of space. Would also be nice to start doing simple injections in this new "office-based" set up so patients don't have to wait (and also is an overall cost-saving and more efficient).

    Currently our ASC is only being utilized 3 days a week. I have heard it is possible to use the ASC fluoro room on the days when the ASC is not being utilized for "office-based" procedures. Can anyone shine any light on this? Does anything need to be done prior to beginning to do this? Any insight is appreciated...
     

    Agast

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      I have heard of this being done. I suppose if you leased space from any ASC on their off days and you’re not billing facility-related niceties you would be ok. Obviously the same location cannot be billed as an ASC and an office on the same day.
       
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      pmrmd

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        This is absolutely being done but depends on the regulation of your state.

        Also it would be horrible if the State shows up for the CMS audit that day and the ASC is working as an office. Oops.

        Next problem is the patient that has an HMO in 2021 then switches to a contracted ASC plan in 2022, and you take them next door and they ask why the heck they have a huge facility copay now when it was just an office copay before.
         

        gdub25

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          I have personally built and set up a facility that bills as two different locations out of the same physical space. When registering your facility with CMS and the state department of health you have to indicate the days and hours of operation for your facility. As long as the two facilities days of operation are different then you’re good to go. In your case you’d only have one facility licensed by CMS and the state (the ASC) and the “office based clinic” could be any other day that the ASC is not listed to have business hours. The thing you’d need to check would be the ASC’s Medicare form 855B to see what days you’ve got listed to have business hours. You guys may only be open 3 days a week in practice at the center but if you’ve listed you’re open 5 days a week then you wouldn’t be able to do the office procedures in there. If you do in fact have 5 days per week listed then you can easily send in a change request and change the days your open.
           
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          IAmTheOne1

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          Sep 28, 2016
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            I have personally built and set up a facility that bills as two different locations out of the same physical space. When registering your facility with CMS and the state department of health you have to indicate the days and hours of operation for your facility. As long as the two facilities days of operation are different then you’re good to go. In your case you’d only have one facility licensed by CMS and the state (the ASC) and the “office based clinic” could be any other day that the ASC is not listed to have business hours. The thing you’d need to check would be the ASC’s Medicare form 855B to see what days you’ve got listed to have business hours. You guys may only be open 3 days a week in practice at the center but if you’ve listed you’re open 5 days a week then you wouldn’t be able to do the office procedures in there. If you do in fact have 5 days per week listed then you can easily send in a change request and change the days your open.
            This is very helpful, thank you!
             

            Orin

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              Thanks for the distraction. There are some fun S.O.S songs out there according to my 5 minutes of researching (LMGTFY - Let Me Google That For You). I'm going go with this one next time someone asks me about SOS.


              "Yeah, they sent the taxman I lost my job, and
              You got hooked on oxycodone
              They shut the lights off
              They took the car, and I bought a sawed-off shotgun

              I'd rather be crazy than to take these pills
              I'm sick of being okay against my will
              I'm losing it
              Ain't a thing in this world that I'm gonna miss
              It's all fake smiles and leather jackets
              We're full of it, yeah we're full of **** I don't know who to trust"
               
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