In last month’s issue of the The AuxoMedical Examiner we addressed Occupation Safety and Health Administration (OSHA) workplace safety rules and safety programs. In that article it was noted that: More workers are injured in the healthcare and social assistance industry sector than any other private industry sector.

That said, it follows that healthcare providers, including ASCs, are likely to be the object of scrutiny by OSHA. As an operating entity in a high risk industry sector, it is quite possible that your ASC will be scheduled for an OSHA inspection (audit) to assure compliance with OSHA requirements.

But put that in context. OSHAs objective is not to be punitive. Rather it seeks to help employers and workers reduce on-the-job hazards to prevent injuries, illnesses and deaths.

Let’s take a look at what you may expect when the OSHA compliance safety and health officer (CO) shows up on your doorstep, typically without advance notice. Following that, we’ll look at how you may best position your ASC to not be a target for an OSHA inspection and the payoffs for being proactive.

More workers are injured in the healthcare and social assistance industry sector than any other private industry sector.

So says the Occupational Safety and Health Administration (OSHA). One study put the incidence rate for work related nonfatal injuries and illnesses in health care and social assistance at nearly 40% higher than that experienced in all private industry.

Healthcare is the fastest-growing sector of the U.S. economy, employing over 18 million workers. Health care workers face a wide range of hazards on the job, including sharps injuries, harmful exposures to chemicals and hazardous drugs, back injuries, latex allergy, violence, and stress. Although it is possible to prevent or reduce healthcare worker exposure to these hazards, healthcare workers continue to experience injuries and illnesses in the workplace.

 Annually, using established criteria, the CMS reviews the “inpatient only” (IPO) list to determine which, if any, procedures are to be removed. In a previous newsletter, we mentioned how Total Knee Arthroplasty may be removed from the Medicare Inpatient Only list. The winners for CY 2017 are five spine procedures along with two laryngoplasty procedures. Total knee arthroplasty (TKA) procedures did not make the final cut.

Illustration of a Total Knee Arthroplasty procedure

The CY 2017 OPPS/ASC final rule discussed comments it received regarding the removal of (TKA) from the IPO list. Despite the overwhelming support for its removal, the CMS did not propose making an immediate change, but “will consider all of these comments in future policy making.”

Plus Virginia Reform Efforts

Certificate of Public Need (COPN) programs are a fact of life in 36 states (Virginia included) as well as the District of Columbia. These laws require government consent before a health care facility may expand, offer a new service or purchase certain medical devices.

The Case for Certificate of Need Laws

The initial intent of COPN programs was to contain health care facility costs through coordinated government/private enterprise planning of facility construction and added services. The assumption was to limit facilities to provide only enough capacity to meet actual need or demand in a given geographical area. Presumably, that would avoid price increases by health care accommodations that were struggling to meet overhead not funded by sufficient patient loads.

Source: NCSL, August 2016