Archived Client Updates |

April 29, 2020, 10:59 am

Good Morning to our Clients and Dear Friends,

Hope you are doing well! Halfway to the weekend! There isn’t much to say today except we look forward to seeing you tomorrow.

ASC Roadmap to Recovery – A Virtual Conference to Prepare for Re-Opening and Resuming Elective Procedures in the New World

There are very few slots left!

Thursday, April 30, 2020
9:00 AM to 3:00 PM

The “ASC Roadmap to Recovery – A Virtual Conference to Prepare for Re-Opening and Resuming Elective Procedures in the New World” is coming together. Re-Opening or Ramping-Up Elective Procedures in your Ambulatory Surgery Center is not going to be as easy as opening the doors or scheduling more patients. In our New World, things will be very different. Join us for this Interactive, full-day conference to discuss the process for re-opening and restarting elective procedures for ASCs and issues related to performing surgery during and after COVID-19. This conference is free for all Ambulatory Healthcare Strategies Retainer Clients and $99.99 for all others. From the leader in ASC Virtual Conferences!
If you are a retainer client of Ambulatory Healthcare Strategies, please sign up for the conference through your AHS Contact.For all others interested in signing up, visit: https://us02web.zoom.us/webinar/register/WN_GAY0lXKBRKeoEbUxVodsyQ

For a copy of the full agenda, visit: https://ascpodcast.com/a-roadmap-to-recovery/

If you are not available for the Live Conference, a recording will be available for our retainer clients or for purchase for all others.

NY Governor Cuomo Announced 12 Guidelines for reopening

There is still very little guidance here for surgery centers and none of it is really new unfortunately. Here are the most applicable:

CDC Guidelines: Based on CDC recommendations, once a region experiences a 14-day decline in the hospitalization rate they may begin a phased re-opening.
Business Precautions: Each business and industry must have a plan to protect employees and consumers, make the physical work space safer and implement processes that lower risk of infection in the business.
Building Health Care Capacity: To maintain the phased re-opening plan, each region must have at least 30 percent of hospital beds and ICU beds available after elective surgeries resume.

See the full guidelines here.

ASGE Released New Reopening Guidelines

The purpose of this document is to present recommendations to employ for mitigation of infection risks during the gradual reopening of endoscopy centers and GI clinics. It is anticipated that physician and facility readiness to resume clinical operations will vary based upon the status of the pandemic in a given geographic location and will evolve gradually based on local conditions and guidance from public authorities. Not all proposed measures will be applicable to all practice settings at all times. Gastroenterologists and their administrators need to exercise discretion in implementing individual suggestions, with the goal of supporting their reopening efforts while ensuring the safety of patients, staff, and providers.

See the full update here.

In a joint statement, they also released guidance on management of endoscopes and endoscope reprocessing.

See this guidance here.

Stay Safe!

—

John J. Goehle, MBA, CASC™, CPA

Chief Operating Officer
Ambulatory Healthcare Strategies, LLC
Rochester: 585-594-1167
Albany: 518-594-1167
Fax: 585-391-1402
Publications: 858-633-6392

April 28, 2020, 11:43 am

Good Morning to our Clients and Dear Friends,

Hope you are all in good health and spirits!

ASC Roadmap to Recovery – A Virtual Conference to Prepare for Re-Opening and Resuming Elective Procedures in the New World

There are only a few slots remaining!

Thursday, April 30, 2020
9:00 AM to 3:00 PM

For a copy of the full agenda, visit: https://ascpodcast.com/a-roadmap-to-recovery/

If you are not available for the Live Conference, a recording will be available for our retainer clients or for purchase for all others.

Action Required: CARES Act Provider Relief Fund

Providers who have already received payments from the CARES Act Provider Relief Fund may be eligible to receive additional funds

Providers who have already received payments from the CARES Act Provider Relief Fund must attest to each payment associated with their billing Taxpayer Identification Number(s). In addition, providers who have already received payments will need to upload their most recent IRS tax filings as well as estimates of lost revenues for March and April 2020.

Here is the link.

Consents

There has been a discussion of whether adding language to the surgical consent about COVID-19 would be necessary. To speak to this issue, we would recommend that you add language to your consent so that patients understand the added risk of having surgery during the Pandemic.

See this example consent from American Society of Plastic Surgeons.

Counter Shields for Front Desk

While determining your protocols for reopening, you may want to consider adding counter shields to your front desk to add an additional level of safety. We already have some centers adding these.

Facial Hair

If you are wearing an N95 Face Mask, Facial Hair should be modified to comply with CDC guidelines here.

Updated Reopening Checklist

As we spoke about in previous emails, we have developed a Checklist to assist centers in reopening/resuming normal operations. It includes Governance Responsibilities, Administration, Infection Control, Clinical Care, Buildings and Systems, HR/Staffing/Education, Pharmacy, and Sterilization.

Here is the Updated Reopening Checklist.

HHS/Medicare Advanced Payment Program Suspended

In light of the $175 billion recently appropriated for healthcare provider relief payments, on April
26, 2020 the Centers for Medicare & Medicaid Services (CMS) announced that it is reevaluating the amounts that will be paid under its Accelerated Payment Program and suspending its Advance Payment Program to Part B suppliers effective immediately.

See the full announcement.

NY Update from Garfunkel Wild about HR

The Equal Employment Opportunity Commission has issued new guidance for workplaces, dated April 17, 2020, as they start the process of preparing for the impending re-opening of their entities in the face of the Covid-19 pandemic. The following provides clarity on how to respond to disability-related inquiries and medical exams during the Covid-19 crisis. Importantly, it is critical that one stay abreast of any new developments through vigilant scrutiny of new governmental releases or inquiries with counsel concerning this subject matter, particularly given the rapid pace at which the governing law in this area is changing as the Covid-19 crisis evolves.

Here is the full Update.

Apologies for Delay in Email Responses

To everyone still waiting for a response to their emails, I apologize that with the large number to review and respond, it is taking longer to get back to you than I’d like. Please be assured that I will get to your email. Anything urgent please mark with “URGENT”.

Stay Safe!

—

John J. Goehle, MBA, CASC™, CPA

Chief Operating Officer
Ambulatory Healthcare Strategies, LLC
Rochester: 585-594-1167
Albany: 518-594-1167
Fax: 585-391-1402
Publications: 858-633-6392

April 27, 2020, 11:40 am

Good Morning to our Clients and Dear Friends,

We hope the weekend treated you well and was a nice reprieve!

ASC Roadmap to Recovery – A Virtual Conference to Prepare for Re-Opening and Resuming Elective Procedures in the New World

Thursday, April 30, 2020
9:00 AM to 3:00 PM

For a copy of the full agenda, visit: https://ascpodcast.com/a-roadmap-to-recovery/

If you are not available for the Live Conference, a recording will be available for our retainer clients or for purchase for all others.

N95 Masks and Fit Testing

N95s are recommended to be worn during any procedures that could cause Aerosolization. You should be evaluating your ability to comply with these recommendations. Supplies of N95s are still low, you should not be restarting procedures if you do not have enough PPE.

Appropriate fit testing will need to be done for all staff members who wear the N95 masks. To do this, you will need the test kit or have an outside company fit test your employees.

Extended and reuse of masks may be necessary due to the low supply. You should have a policy in place on how you will do this if it is necessary. Also, you should be covering the n95 with a surgical mask to protect it during procedures. Otherwise, reuse should not be done.

There should be a risk assessment performed when you make these decisions on whether or not to use N95s. You should also have contingencies in place for running out of supply.

COVID-19 Testing Update

If you are looking into testing patients and/or staff members, only use tests that have FDA EUAs and are authorized for use in a patient care setting operating under a CLIA waiver (listed under “Authorized Setting” with a “W”). Use the table here to check.

For getting tests from suppliers, be very careful when purchasing. Do due diligence and only buy from known or credible entities. Your GPO may be your best resource for doing this.

New York State ACS Elective Procedure Webinar

Governor Cuomo announced elective outpatient treatments can resume on April 28 in counties and hospitals without significant risk of a COVID-19 surge. However, the state has not yet issued guidance.

To ensure these services can be resumed safely, the American College of Surgeons and other associations created a roadmap to guide readiness, prioritization and scheduling.

Mark Reiner, MD FACS, Chair of the Manhattan Council of the NY Chapter ACS will present this roadmap in a Safely Resuming Elective Procedures webinar on Monday, April 27, at 3 p.m.

This webinar will be co-hosted by HANYS and the New York Chapter of ACS.

Please register online. (There are a few hoops to jump through but it is free for everyone).

Announcing the “ASC Finance, Accounting and
Reimbursement Seminar Presented by: Coding Compliance Management, LLC and the ASC Podcast with John Goehle June 11 and 12th 2020.

Ambulatory Surgery Center Administrators, Nurse Managers and Business Office Managers face unique challenges in managing the financial aspects of an ASC. Join us for this intensive, two-day virtual conference to discuss all aspects of Finance, Accounting and Reimbursement in the ASC setting sponsored by Coding Compliance Management, LLC and the ASC Podcast with John Goehle.

This conference is ideal for anyone interested in understanding basic finance principles as well as those that know finance but want to learn more how it differs in the ASC setting. The conference also will provide an understanding of reimbursement and coding in the ASC setting. We are applying for AEUs for CASC Certified Administrators and CEUs for Coding and Billing professionals certified through AAPC.

For more information and the agenda: https://ascpodcast.com/finance-accounting-reimbursement/

Staffing and Systems Update

Our accounting department is fully back up and running. Everything should be reconciled by the end of day today. All staff are safe and healthy including puppies!

Stay Safe!

—

John J. Goehle, MBA, CASC™, CPA

Chief Operating Officer
Ambulatory Healthcare Strategies, LLC
Rochester: 585-594-1167
Albany: 518-594-1167
Fax: 585-391-1402
Publications: 858-633-6392

April 24, 2020, 11:48 am

Good Morning to our Clients and Dear Friends,

Happy Friday! We have another light day of news. Please continue to send any questions our way.

There will be a recorded podcast from ASC Podcast with John Goehle over the weekend. The podcast is available on iTunes, Google Play, YouTube, TuneIn, Amazon Alexa or through the website at https://ascpodcast.com.

ASC Roadmap to Recovery – A Virtual Conference to Prepare for Re-Opening and Resuming Elective Procedures in the New World

Thursday, April 30, 2020
9:00 AM to 3:00 PM

For a copy of the full agenda, visit: https://ascpodcast.com/a-roadmap-to-recovery/

If you are not available for the Live Conference, a recording will be available for our retainer clients or for purchase for all others.

Updated Reopening Checklist

Here is the Updated Reopening Checklist.

Determining the COVID-19 Status of Patients

Until centers are able to effectively test for COVID-19, one of the most important decisions that each center will need to make as they look to resume normal operations is the assumed health statuses for patients, visitors, and staff. If each of these groups are treated as COVID Positive, Suspected COVID-19 Carriers, or healthy, at a minimum it could have implications on screening, PPE, HVAC settings, and operational protocols.

When pre-admission testing becomes available, the center may need to reevaluate.

We will most likely see States playing a major role in this determination, but until we receive guidance the governing body is responsible.

PPE, Testing, and other supply Venders

Be very careful when buying supplies in these uncertain times. Your best resource is your GPO to ensure that the suppliers are legitimate and that prices are not overly inflated. If you need a GPO contact please reach out to John.

Always, always, always do due diligence when purchasing from an unknown source.

NY State Update

The Governor’s office is working on a plan. Expected to release as early as today. Big debate is county vs regional approach. We will update you when we have more information.

Stay Safe!

—

John J. Goehle, MBA, CASC™, CPA

Chief Operating Officer
Ambulatory Healthcare Strategies, LLC
Rochester: 585-594-1167
Albany: 518-594-1167
Fax: 585-391-1402
Publications: 858-633-6392

April 23, 2020, 10:48 am

Good Morning to our Clients and Dear Friends,

Hope you are all doing well! There isn’t too much to talk about today as we await additional guidance regarding the reopening process. Please remember to reach out with any questions you might have.

CMS Released Phase 1 Recommendations for Reopening

See the most recent guidance from CMS regarding reopening.

Here is the link.

ASC Roadmap to Recovery – A Virtual Conference to Prepare for Re-Opening and Resuming Elective Procedures in the New World

For a copy of the full agenda, visit: https://ascpodcast.com/a-roadmap-to-recovery/

If you are not available for the Live Conference, a recording will be available for our retainer clients or for purchase for all others.

Staff and Systems

All our staff are healthy and still staying isolated as much as possible. Our Accounting Department is coming back online slowly as furloughed employees return. We should be back up to full speed on Monday.

Stay Safe!

—

John J. Goehle, MBA, CASC™, CPA

Chief Operating Officer
Ambulatory Healthcare Strategies, LLC
Rochester: 585-594-1167
Albany: 518-594-1167
Fax: 585-391-1402
Publications: 858-633-6392

April 20, 2020, 10:39 am

Good Morning to our Clients and Dear Friends,

Hope all is well with you as we enter a new week.

AORN, ASA, AHA, ACS and others release guidelines for resuming elective surgeries

WITH PROVIDERS EAGER TO RESUME elective surgical procedures as COVID-19 cases begin to decline in some regions, a group of prominent trade associations released joint guidelines April 17 that are intended to help them assess their readiness to do so.

See here for the full guidelines.

Draft AHS COVID-19 Reopening Checklist

Ambulatory Healthcare Strategies has drafted up a checklist to help you reopen.

Some of the items we don’t have answers on yet are:

Testing
Masks
Elective vs Non Elective Changes

Get the DRAFT list here.

ANNOUNCING ASC Roadmap to Recovery – A Virtual Conference to Prepare for Re-Opening in the New World

Thursday, April 30, 2020
9:00 AM to 3:00 PM

Re-Opening your center is not going to be as easy as opening the doors. In our New World, things will be very different. Join us for this Interactive, full-day conference to discuss the process for re-opening and issues related to performing surgery during and after COVID-19. This conference is free for all AHS Retainer Clients and $99.99 for all others.

If you’d like to join in:

For AHS Retainer Clients: Contact your primary contact.

For all others follow this link to register.

Stay Safe!

—

John J. Goehle, MBA, CASC™, CPA

Chief Operating Officer
Ambulatory Healthcare Strategies, LLC
Rochester: 585-594-1167
Albany: 518-594-1167
Fax: 585-391-1402
Publications: 858-633-6392

April 16, 2020, 10:56 am

Good Morning to our Clients and Dear Friends,

Hope you and your family are doing well!

ASC Podcast today at 3pm

We will have a live Podcast today at 3:00 pm. Today we will be discussing on-going effects of the CoronaVirus, 1135 Waivers, Possible Drug Issues, and listener questions.

To Access the podcast Live:

On Podbean: https://www.podbean.com/lsw/John/s-75WnCL1Hyj

On Youtube: https://www.youtube.com/channel/UC-hvEz0wQCixVHuMAODSiow

Update 1135 Waivers for Life Safety Testing/Inspections

We have modified the ASHE waiver request to be specific to ASCs. Based on our interactions with AAAHC, it is now our recommendation that if you do need to postpone any Life Safety inspections/testing that you submit an 1135 Waiver Request to your Regional CMS office. Please do not use the ASHE waiver form as it is very customized to hospitals. The preference of course is still that you continue all testing/inspections. If you are shut down and not able to perform all Life Safety inspections/testing, you should still submit this Waiver Request.

Please see the ASC Specific Waiver Request attached. Please note that there are a number of items that you will still need to customize to your center.

Pharmacy Update from DSCSA via George Scouras

It looks like the DSCSA is making allowances for emergency transfers of medications especially when initiated by the state as long as the transfer is done in a secure manner.

Here is their full response:

“We are aware of drug supply issues for highly affected areas by COVID-19. We recognize that hospitals and medical facilities are preparing for and/or actively treating the surge of COVID-19 patients.

The Secretary of Health and Human Services declared a public health emergency on January 31, 2020, under section 319 of the Public Health Service Act, in response to COVID-19. Please see https://www.fda.gov/drugs/drug-supply-chain-security-act-dscsa/public-health-emergencies-and-dscsa-requirements for more information.

We are actively working to provide more clarity and guidance on the scope of the regulatory relief to you and the other supply chain stakeholders.

Check FDA’s website for updates: https://www.fda.gov/drugs/drug-supply-chain-security-act-dscsa/drug-supply-chain-security-act-law-and-policies

The DSCSA Implementation team”

Governor Orders on Masks

Many States including New York, California, Connecticut, Maryland, and Pennsylvania are now mandating or are expected to mandate in the next few days the wearing of masks in public by all citizens.

ASCs in these areas and any other states that require masks to be worn should be requiring that masks are worn by all persons that enter ASC premises.

Stay Safe!

—

John J. Goehle, MBA, CASC™, CPA

Chief Operating Officer
Ambulatory Healthcare Strategies, LLC
Rochester: 585-594-1167
Albany: 518-594-1167
Fax: 585-391-1402
Publications: 858-633-6392

April 15, 2020, 10:07 am

Good Morning to our Clients and Dear Friends,

Happy Hump Day! Hope you are all well!

Reminder to Post Families First Coronavirus Response Act Notice

This poster must be posted in a conspicuous area.

See the Poster here.

See the FAQ here.

Update HHS CARES ACT Medicare Grants

Providers will receive a portion of the initial $30 billion based on their share of total Medicare FFS reimbursements in 2019. Total FFS payments were approximately $484 billion in 2019.

Providers will be paid via Automated Clearing House account information on file with the Centers for Medicare & Medicaid Services (CMS) or United Health Group (UHG), who CMS is partnering with to distribute the funds. The automatic payments will come to providers via Optum Bank with “HHSPAYMENT” as the payment description. Providers who normally receive a paper check for reimbursement from CMS will receive a paper check in the mail for this payment as well, within the next few weeks.

Within 30 days of receiving the payment, providers must sign an attestation confirming receipt of the funds and agreeing to the Terms and Conditions of payment. The portal for signing the attestation will be open the week of April 13, 2020. If a provider receives payment and does not wish to comply with the Terms and Conditions, the provider must contact HHS within 30 days of receipt of payment and remit the full payment to HHS.

A provider can estimate their payment by dividing their 2019 Medicare FFS (not including Medicare Advantage) payments by $484,000,000,000 and multiply that ratio by $30,000,000,000. This comes to approximately 6.2 percent of your FFS payments in 2019.

See the full clarification from ASCA here.

NYS Department of Labor following up on Executive Orders

We have heard from an ASC that has been approached by the department of labor asking why they were still open and reminding them of the civil and criminal penalties for not following the governor’s orders. They are asking for documentation of what essential services they are providing. We point this out to underline the possible repercussions to remaining open and doing more than urgent and non-elective procedures. The department of labor getting involved is most likely a response to an inquiry from an employee.

KN95 Masks

There has been some discussion on these being a possible substitute to N95 masks. We do not recommend using these for surgeries due to the guidance being unclear. There are certain circumstances where these would be appropriate, but during surgery is not among them.

On March 24, 2020, the FDA issued an Emergency Use Authorization (EUA) for importing non-NIOSH-approved N95 respirators. Under this EUA, among other criteria, the FDA accepts marketing authorization from Australia, Brazil, Europe, Japan, Korea, and Mexico who have similar standards to NIOSH. The FDA did not list KN95 respirators in this EUA because of concerns about fraudulent products listed as KN95s. On April 3, 2020, in response to continued respirator shortages, the FDA issued a new EUA for non-NIOSH-approved N95 respirators made in China, which makes KN95 respirators eligible for authorization if certain criteria are met, including evidence demonstrating that the respirator meets certain standards.

Here is the full article.

It’s A New World Conference 2020 – It’s not too late to join in!

The first day of the conference is almost over and it has been fantastic with positive responses from viewers. Great Speakers, great questions and incredibly timely information.

Don’t worry if you missed the first day, you can still sign up and you will still get the recording. Day One of the Virtual ASC Conference is done and it was an incredible success. You can sign up for both days and get a recording of the first day and join the Friday Session. The conference has been approved for 14.5 AEUs and 1 IPCU for those who hold the CASC and CAIP credentials.

For more information about the conference: https://ascpodcast.com/register-for-the-its-a-new-world-conference-2020/

Stay Safe!

—

John J. Goehle, MBA, CASC™, CPA

Chief Operating Officer
Ambulatory Healthcare Strategies, LLC
Rochester: 585-594-1167
Albany: 518-594-1167
Fax: 585-391-1402
Publications: 858-633-6392

April 13, 2020, 10:16 am

Good Morning to our Clients and Dear Friends,

Happy Monday! Hope everyone had a good Easter/Passover weekend! Don’t forget to sign up for the Virtual Conference tomorrow and Friday.

While we intended to have a podcast today, there doesn’t appear to be enough material right now. We are looking to do a podcast on Wednesday or Thursday. Stay tuned.

Specific Steris and Sterrad Machines are Granted EUAs from FDA for N95 Mask Decontamination

Please see the EUA and Instructions for specific Steris Machines.

Please see the EUA and Instructions for specific Sterrad Machines.

If this is a process that you are considering, please make sure that you are following the instructions to the letter otherwise you could be putting your staff at risk. Please see the FDA’s EUA website for all the details and emergency use authorizations.

Updates for NY StateGovernor Andrew M. Cuomo this weekend announced he will issue an Executive Order directing employers to provide essential workers with cloth or surgical masks free of charge to wear when directly interacting with the public. He is expected to sign the order for this today.

See a note from Jon VanValkenburg:

“The Governor’s office called us yesterday seeking help from ASCs in New York. Hospitals all over the State are now reporting risk of running out of sedative drugs necessary for COVID-19 patients on ventilators. The Governor’s office is looking to see if we have inventories of propofol, versed, fentanyl, and morphine available to be redistributed to a hospital in need. I have attached a spreadsheet for NYSAASC members to report the amount of these drugs that your facility has available to redistribute IF necessary. Please report only the amount you have available to commit at this time. I feel confident that any facility that does have medications redistributed will eventually be reimbursed.

We are trying to get this information to the Governor’s office by Monday afternoon, so please respond as soon as possible. Thank you for your assistance and please let me know if you have any questions.”

See the attached spreadsheet. Please send to [email protected] once complete

It’s a New World Conference 2020 – Starts Tomorrow!

There is still time to sign up for tomorrow and Friday’s Virtual Conference! Even if you can’t be there live for both days, if you sign up for the whole conference, you will get the recordings for both days. Remember also that we have applied for between 12 and 14 AEUs for CASC Certified Administrators and 1 IPCU for CAIP Certified Infection Control Coordinators.

Almost all of our centers are either not in operation at the present time, or have a very limited schedule. To provide opportunities for continuing education for managers and employees, the ASC Podcast with John Goehle announces “It’s a New World Conference 2020 – A Virtual Conference for Ambulatory Surgery Center.

As you bring your employees back on your payroll to meet the provisions of the Paycheck Protection Program or experience downtime, use this time to improve your skills and learn some new things. This two day “Virtual Conference” will be held on April 14th and 17th.

This 2-day, on-line “Virtual ASC Conference” will be both fun and informative. Great speakers, important topics, entertaining discussions and periodic visits by an 10 week old puppy are sure to make this conference a very different online education experience!!

For the agenda, click here.

To register, click here.

If you are a retainer client of Ambulatory Healthcare Strategies, you will get a FULL rebate for up to 5 attendees on your June 2020 Retainer bill. Note that one site using one computer to connect is one attendee even if more than one person is watching.

Stay Safe!

—

John J. Goehle, MBA, CASC™, CPA

Chief Operating Officer
Ambulatory Healthcare Strategies, LLC
Rochester: 585-594-1167
Albany: 518-594-1167
Fax: 585-391-1402
Publications: 858-633-6392

April 10, 2020, 10:02 am

Good Morning to our Clients and Dear Friends,

Happy Friday! We thank all of our centers who have been able to rise to the occasion and support St. John’s Hospital in Riverside this morning. We are proud to be associated with so many caring and generous centers!

At this time we are in “wait and see” mode. There isn’t much new coming out as we stand ready to be called upon during the apex of the virus. ASCs should be continuing to work on preparing a plan to help the hospitals.

Checklist for Starting Back Up

We are working on a step by step tool to prepare ASCs as they prepare to return to normal operations once the current restrictions are loosened.

It’s a New World Conference 2020 – REGISTER BEFORE WE RUN OUT OF SPACE!

Almost all of our centers are either not in operation at the present time, or have a very limited schedule. To provide opportunities for continuing education for managers and employees, the

ASC Podcast with John Goehle announces “It’s a New World Conference 2020 – A Virtual Conference for Ambulatory Surgery Center.

For the agenda, click here.

To register, click here.

Stay Safe!

—

John J. Goehle, MBA, CASC™, CPA

Chief Operating Officer
Ambulatory Healthcare Strategies, LLC
Rochester: 585-594-1167
Albany: 518-594-1167
Fax: 585-391-1402
Publications: 858-633-6392

April 9, 2020, 10:14 am

Good Morning to our Clients and Dear Friends,

Happy Thursday, we hope you and your loved ones are doing well.

Hospitals without Walls Update from ASCA

Following the additional guidance released on April 3rd (see here), we still do not recommend that you become a hospital due to the number of unknowns at this time. We feel the best way to assist the community is to become an extension of an existing hospital or taking on cases from the hospital within your current scope of practice.

ASCA put together a checklist for providing the additional services allowable under the Hospitals without Walls program. This checklist, developed by ASCA, is designed to help ASCs identify the basic elements they need to consider before providing expanded services under the temporary rules and waivers the Centers for Medicare & Medicaid Services (CMS) announced during the national emergency declared in response to the COVID-19 pandemic.

NY Executive Order 212.14 Legal Consequences

Please see this article for the potential legal consequences to remaining open with not making use of telecommuting when possible.

LeapFrog

We are aware that the Leapfrog Group is reaching out to ASCs regarding a survey of the industry. It is our recommendation that you DO NOT respond or participate in this survey. Unfortunately, Leapfrog’s previous surveys on behalf of the industry have not portrayed us favorably or accurately.

Healthcare Provider Liability

New York and the Federal Government via the CARES Act have granted certain immunities to healthcare providers during the disaster. The CARES Act protections are targeted solely at volunteers while the New York provisions are more general.

See JDSUPRA and Barclay Damon‘s articles for the NYS changes.

See AMA for the explanation of the Federal Changes.

Medication Shortages

Consider your current medication inventory including propofol, fentanyl, midazolam, IV solutions, and paralytics as these drugs are running low. Reach out to your supplier to secure the quantities you feel are necessary upon reopening. Be proactive, but please do not hoard.

It’s a New World Conference 2020 – REGISTER BEFORE WE RUN OUT OF SPACE!

Almost all of our centers are either not in operation at the present time, or have a very limited schedule. To provide opportunities for continuing education for managers and employees, the

ASC Podcast with John Goehle announces “It’s a New World Conference 2020 – A Virtual Conference for Ambulatory Surgery Center.

This 2-day, on-line “Virtual ASC Conference” will be both fun and informative. Great speakers, important topics, entertaining discussions and periodic visits by an 8 week old puppy are sure to make this conference a very different online education experience!!

For the tentative agenda, click here.

To register, click here.

Staff and Systems Update

We at AHS are all healthy and doing well minus the seasonal allergies of course. Most of us are home up in Rochester, NY in isolation. Zach is still stuck down in Atlanta and Laurie is safe in her cave on Cape Cod. Jim should be finally driving back from Florida on Monday and Tuesday before hunkering down in Rochester. We all miss our visits with you and hope to be able to resume once the pandemic has concluded. In the meantime, we are all prepared to host zoom meetings with you as we continue our support for you and your vital organizations. Reach out if you need us!

Stay Safe!

—

John J. Goehle, MBA, CASC™, CPA

Chief Operating Officer
Ambulatory Healthcare Strategies, LLC
Rochester: 585-594-1167
Albany: 518-594-1167
Fax: 585-391-1402
Publications: 858-633-6392

April 8, 2020, 11:36 am

Good Morning to our Clients and Dear Friends,

I am sure you missed our daily updates yesterday – but we were very busy with the incredibly successful Infection Control Virtual Conference. We are back today with our regular updates!

Starting later today, for those of you who did not attend yesterday’s Infection Control Virtual Conference you can access it here. If you are a paid retainer client of Ambulatory Healthcare Strategies, during the CoronaVirus crisis, you can listen to the conference for no charge by contacting John and requesting access. For all others, it will be available for purchase.

Live ASC Podcast Today

The next live ASC Podcast with John Goehle will be this afternoon at 3:00 pm.

Live Podcast at 3:00 EDT on April 8, 2020. Today we will discuss Life Safety Oversight during the Coronavirus, PPP (SBA) Issues, CMS Hospital without Walls and take listener questions.

Here is the link to the Podbean for the Podcast.

To watch on youtube Live search “John Goehle” on Youtube.

New York Governor’s Executive Order

As Jon VanValkenburg and Lisa Alteri sent out this morning, there is a new Executive Order from Governor Cuomo.

See quote below from Lisa Alteri:

“Executive Order 202.14 was just posted and based on the language included below, all NYSAASC members should report their inventory, including PPE, ventilators, respirators, bi-pap, anesthesia, or other necessary equipment. Since the Department of Health reached directly out to the Association I believe if all members have not completed the survey they should complete timely. While I don’t expect equipment will be needed, based on the current data and projections, I did reach out to the Department of Health inquiring how this information will be collected. If HERDS has not been updated for a survey they may just request more information from the Association, but I will keep everyone updated.”

As far as we have seen, no mechanism has been created yet for the gathering of the information. We will monitor and update you if anything is released.

Here is the executive order.

Testing and Maintenance During CoronaVirus

We understand that there are differing opinions out there on this subject, but we recommend that you continue all testing, maintenance, and drills (figure just Fire because COVID-19 can be counted as your drill if you write it up). Maintenance personnel should be considered essential personnel in all states.

Your ability to maintain your Life Safety Documentation will be determined in large part by the current status of your center. You should be performing all maintenance/testing possible especially if your center is fully open/staffed. Any ongoing maintenance/testing that is not possible to complete due to unavailable vendors, unavailable staff, or some other extenuating circumstance should be specifically documented as a conscious decision to suspend the maintenance/testing for a specific reason. This documentation should be maintained to show to surveyors so they can see that the decision was part of the center’s response to the disaster, not just a lapse in documentation. Any discontinuation in equipment maintenance/testing should be evaluated in coordination with manufacturers and documented as having been done in coordination with manufacturers. Upon resuming normal operations, the center should make a significant effort to perform testing/maintenance prior to the use of all equipment. For example, after a lull in weekly/monthly ongoing maintenance/testing a center might consider performing the full annual testing upon return to the center even if it is not due.

We know that there has been information about requesting an 1135 waiver for suspending Life Safety Testing. We don’t believe that this is necessary at this point and time from what we have heard from accrediting organizations and the lack of response from CMS. We should not be overwhelming CMS with these waiver requests. In addition, centers should be very careful about using the template provided by ASHE, which uses Joint Commission standards and focuses on Hospital requirements.

Please see Keyes Answer for further guidance.

Paycheck Protection Program Update

There continue to be some challenges with the PPP, our friend Keith Gruebele from BHG Funding has the following recommendations:

Unfortunately due to some ruling changes in the SBA we are unable to process new applications for the PPP loans.

Ask the lending source you are going to if they are licensed to offer SBA loans and if they have already established funding for the PPP Program.
The PPP Program is a good solution and should be utilized but it is temporary in nature and only covers payroll and some overhead costs. Centers need to be cautious to utilize the funds explicitly as intended and be able to document all the disbursements for the loan proceeds to avoid nullifying the forgiveness by the SBA.
Centers should still continue to look for long term working capital solutions, monies to keep them afloat, such as working capital loans or an SBA 7a loan depending on the size of the request and their timing availability.
Utilize this time in the business office to consider a refinance of all existing debt into an SBA loan that allows you to restructure short term or higher interest debt with longer term/cheaper payments. You can always pay a loan down early!
Make sure centers have ideally a 6 month cash on hand reserve available, but at worst case a minimum of 3 months.

Keith is going to join us this afternoon on the live podcast for more advice.

The ASC Association has provided an excellent list of resources for the program here.

The application period began on Friday. We discussed it during Friday’s live podcast, however, several clarifications are necessary based on information that was not available at the time of the podcast.

The Department of Treasury provided an Information Sheet. that provided more information about how the program works for Small businesses.

The loan amounts will be forgiven as long as:

The loan proceeds are used to cover payroll costs, and most mortgage interest, rent, any utility costs over the 8 week period after the loan is made; and
Employee and compensation levels are maintained.

Payroll costs are capped at $100,000 on an annualized basis for each employee. Due to likely high subscription, it is anticipated that not more than 25% of the forgiven amount may be for non-payroll costs. Loan payments will be deferred for 6 months.

CMS Memorandum Reminder regarding Temporary Closure

In this Memorandum CMS states that CMS will not take administrative actions with respect to facilities who need to temporarily close during the outbreak, however, facilities are expected to resume operations or voluntarily terminate their Medicare enrollment within 30 days of the public health emergency being lifted.

In addition, CMS states that Facilities needing to temporarily shut down or limit operations should post notices at their business as well as on public facing websites and social media platforms during this emergency.

See the full Memorandum Here.

It’s a New World Conference 2020 – REGISTER BEFORE WE RUN OUT OF SPACE!

Almost all of our centers are either not in operation at the present time, or have a very limited schedule. To provide opportunities for continuing education for managers and employees, the

ASC Podcast with John Goehle announces “It’s a New World Conference 2020 – A Virtual Conference for Ambulatory Surgery Center.

For the tentative agenda, click here.

To register, click here.

Stay Safe!

—
John J. Goehle, MBA, CASC™, CPA

Chief Operating Officer
Ambulatory Healthcare Strategies, LLC
Rochester: 585-594-1167
Albany: 518-594-1167
Fax: 585-391-1402
Publications: 858-633-6392

April 6, 2020, 10:16 am

Good Morning to our Clients and Dear Friends,

We hope you had a great weekend. Note that this is a SHORT update – but there are two major things that you need to do today!! (1) Sign up for the Infection Prevention Training tomorrow and (2) Sign up for the Paycheck Protection Program.

Infection Prevention Training April 7th – Tomorrow!

Time is running out to sign up for our live “Virtual Conference”, tomorrow, April 7, 2020 at 8 am. The live infection control format will allow you to ask questions and interact with the hosts. The ASC Infection Prevention Coordinator Training will provide Infection Control Nurses, and others interested in learning more about Infection Control in the ASC setting the tools needed to manage an ASCs infection control program and demonstrate compliance with the CMS and Accreditation Requirements for education. Attendees will receive a certificate of attendance and resources. For more information, please visit: https://ascpodcast.com/asc-infection-prevention-coordinator-training/.

If you are a paid retainer client, you can sign up for no charge. We have opened up the registration for more than one person from each center. For more information, contact your AHS contact or John Goehle.

Live ASC Podcast on Wednesday

The next live ASC Podcast with John Goehle will be on Wednesday, April 8, 2020. More information to come.

Paycheck Protection Program

As part of the CARES program, ASCs have the ability to borrow money to re-employ (or keep their staff on payroll). We highly recommend that ALL centers consider this program and apply TODAY (if you didn’t already). The money appropriated for the program is likely to run out quickly so time is of the essence. We have heard from some of our clients that they are having problems applying for the program through their bank or through their lender. IF YOU ARE HAVING PROBLEMS APPLYING FOR THE PROGRAM, PLEASE CONTACT JOHN AT 585-729-8781 FOR SOME POSSIBLE ALTERNATIVES.

The ASC Association has provided an excellent list of resources for the program here.

The Department of Treasury provided an Information Sheet. that provided more information about how the program works for Small businesses.

The loan amounts will be forgiven as long as:

The loan proceeds are used to cover payroll costs, and most mortgage interest, rent, any utility costs over the 8 week period after the loan is made; and
Employee and compensation levels are maintained.

The applications began on Friday (April 3, 2020).

You can apply through any existing SBA lender or through any federally insured depository institution, federally insured credit union, and Farm Credit System institution that is participating. Other regulated lenders will be available to make these loans once they are approved and enrolled in the program. You should consult with your local lender as to whether it is participating. Visit www.sba.gov for a list of SBA lenders.

As we noted on Friday, if your ASC is affiliated with a national company or a hospital, you may be restricted as to your eligibility for a loan under the Paycheck Protection Program.

On April 1, ASCA sent letters to the US Department of Treasury and SBA urging that ASCs with equity investors or business partners be eligible for the loans and loan forgiveness. While this interim final rule does not provide the flexibility ASCA requested, the SBA indicates that additional guidance about the applicability of affiliation rules will be provided. Many other associations, and members of Congress, advocated for similar flexibilities around the affiliation rules, and ASCA will continue to work to ensure that the broadest base of ASCs are eligible for these programs. We are still waiting for clarification of this language.

ASCA recommends that your center consult with your legal and lending partners about this interim final rule. The interim final rule is available here.

It’s a New World Conference 2020 – REGISTER SOON!!

Almost all of our centers are either not in operation at the present time, or have a very limited schedule. To provide opportunities for continuing education for managers and employees, the

ASC Podcast with John Goehle announces “It’s a New World Conference 2020 – A Virtual Conference for Ambulatory Surgery Center.

For the tentative agenda, click here.

To register, click here.

Stay Safe!

—

John J. Goehle, MBA, CASC™, CPA

Chief Operating Officer
Ambulatory Healthcare Strategies, LLC
Rochester: 585-594-1167
Albany: 518-594-1167
Fax: 585-391-1402
Publications: 858-633-6392

April 3, 2020, 10:41 am

Good Morning to our Clients and Dear Friends,

TGIF! We hope you and your family are faring well in these difficult times.

ASC Podcast Today at 3pm

The ASC Podcast with John Goehle celebrates its 100th Episode live today at 3:00 PM Eastern. The Staff of AHS and invited guests will discuss the current issues related to COVID-19, the Urgent need to apply for the Paycheck Protection Program, equipment during a shutdown, issues with N95 masks, and a discussion about the past and future of the podcast.

There are several ways to listen in on the discussion:

You can watch us by searching YouTube for “John Goehle” when the podcast goes live.

You can follow the link below to listen on Podbean:

https://www.podbean.com/lsw/John/s-vjvbfKjf6G

Paycheck Protection Program

The application period begins today.

As Garfunkel Wild sent out this morning: applications should be submitted to your Lender ASAP since it is first come first serve until money runs out. The total amount appropriated for the PPP is $349,000,000,000. The last day to apply for a PPP loan is June 30, 2020 provided funds are still available.

See the Garfunkel Wild alert here.

Note that if your ASC is affiliated with a national company or a hospital, you may be restricted as to your eligibility for a loan under the Paycheck Protection Program. The SBA regulations state that for both Business Loans (like the Paycheck Protection Loans) and Disaster Loans, an ASC must satisfy two criteria:

The size of the applicant alone (without affiliates) must not exceed the applicable size standard; and
The size of the applicant combined with its affiliates must not exceed the size standard designated for either the primary industry of the applicant alone or the primary industry of the applicant and its affiliates, whichever is higher.

It further states that: Concerns and entities are affiliates of each other when one controls or has the power to control the other, or a third party or parties control or has the power to control both. It does not matter whether control is exercised, so long as the power to control exists. Affiliation under any of the circumstances described below is sufficient to establish affiliation for applicants for SBA’s Business Loan [and] Disaster Loan.

ASCA recommends that your center consult with your legal and lending partners about this interim final rule. The interim final rule is available here.

Consider a Loan Advance
If your situation is particularly difficult, you may request a loan advance of $10,000. You will still have to go through the process listed above, but this is meant to provide immediate relief – and will take a few hours to complete the on-line application and to supply the supporting documentation. For more information go to this website at the Small Business Administration:
Link to SBA Loan Advance

Endoscope Reprocessing Machine Upkeep

This is a revision to previous guidance on shutting down all equipment (other than refrigerators). We want to clarify that you should be following manufacturer’s instruction when shutting down any equipment.

Medivators released a statement regarding their endoscope reprocessors not to shut the AER down for any period of time and to reduce microbial contamination in the AER when not in clinical use. Here is the link to the guidance.

Olympus put out a customer letter this week, referring to the AER’s IFU and stating that if an OER-Pro will be stored for more than 14 consecutive days, it should be prepared for long-term storage. Once OER-Pro operation is resumed, a separate process is followed for preparation of the OER-Pro, prior to resuming use. Here is the link to the guidance.

N95 Masks

GI Societies have provided guidance that for areas with continued community spread, all personnel in a GI procedure room should be wearing N95 masks.

Remember use of an N95 respirator is only viable if it has been fit tested. Options for fit testing include: Sending staff to a local occupational health service provider or having fit-testing personnel test staff on site. Each test takes about 7 minutes.

Here is the guidance from the GI Societies:

Use of Personal Protective Equipment in GI Endoscopy

ENDOSCOPIC PROCEDURES DURING THE COVID-19 PANDEMIC

Guidance from the American Society of Anesthesiologists:

Due to the long incubation period of COVID-19 and the number of asymptomatic individuals with COVID-19, the ASA recommends as optimal practice that all anesthesia professionals should utilize PPE appropriate for aerosol-generating procedures for all patients when working near the airway. Ideally, anesthesia professionals should use properly fitted N95 masks or powered air purifying respirators (PAPRs).

See the full guidance here:

Update from NYSAASC (NY CENTERS ONLY)

NYSAASC is working closely with the NYS Department of Health to identify the ways that ASCs can BEST assist with addressing the COVID-19 crisis. It is important that we engage with them to help direct the plans in a way that helps address the crisis while still protecting the viability and security of our facilities. To that end, NYSAASC is seeking your help in identifying the resources of ASCs in New York. Please take the time to complete the attached spreadsheet for your facility and email it to Jon VanValkenburg as soon as possible at [email protected].

It’s a New World Conference 2020 – REGISTRATION OPEN

The ASC Podcast with John Goehle announces “It’s a New World Conference 2020 – A Virtual Conference for Ambulatory Surgery Center. As you bring your employees back on your payroll to meet the provisions of the Paycheck Protection Program or experience downtime, use this time to improve your skills and learn some new things. This two day “Virtual Conference” will be held on April 14th and 17th.

Take advantage of this time and increase the skills of you and your staff by attending our 2-day, on-line “Virtual ASC Conference”. We promise it will be fun and informative. Great speakers, important topics, entertaining discussions and periodic visits by an 8 week old puppy are sure to make this conference a very different online education experience!!

For the tentative agenda, click here.

To register, click here.

Infection Prevention Training April 7th – Filling up Fast!

ASC Infection Control Nurses – Do you need to demonstrate for your compliance with the CMS and Accreditation Requirements for education in ASC specific infection control oversight? Join us for our ASC Infection Prevention Coordinator Training – A live “Virtual Conference” on April 7, 2020 at 8 am. Attendees will receive a certificate of attendance and resources. The live format will allow you to ask questions and interact with the hosts. For more information, please visit: https://ascpodcast.com/asc-infection-prevention-coordinator-training/. If you are a paid retainer client, you can sign up to one person for no charge. For more information, contact your AHS contact or John Goehle.

Stay Safe!

—

John J. Goehle, MBA, CASC™, CPA

Chief Operating Officer
Ambulatory Healthcare Strategies, LLC
Rochester: 585-594-1167
Albany: 518-594-1167
Fax: 585-391-1402
Publications: 858-633-6392

April 2, 2020, 10:51 am

Good Morning to our Clients and Dear Friends,

It’s almost Friday! We hope you and your family are faring well in these difficult times.

Telecommuting Policy

For those with employees working from home or working from home themselves, you should be adding a telecommuting policy to your policy manual. We have attached an example policy. For those of you who are retainer clients, please modify this policy to fit your specific needs and speak to your main AHS contact to have it added to your policy manual.

New GI Guidance from American Society for Gastrointestinal Endoscopy

Use of Personal Protective Equipment in GI Endoscopy

ENDOSCOPIC PROCEDURES DURING THE COVID-19 PANDEMIC

CARES Act Summarized Guidance

You can apply beginning Friday, April 3, 2020. Please apply as quickly as you can because there is a funding cap.

All loans will have the same terms regardless of lender or borrower.

No Personal Guarantees or Collateral is required for applying for the loan.

Permissible Use of Loan Proceeds

Payroll Costs;
Salaries/wages (excluding compensation of an individual employee in excess of an annual salary over $100,000)
Payment for vacation, parental, family, medical or sick leave (does not include emergency paid sick leave and emergency paid family and medical leave under the Families First Coronavirus Response Act (“FCCRA”);
Allowance for dismissal or separation;
Payment required for the provisions of group health care benefits, including insurance premiums;
Payment of any retirement benefit; and
Payment of state or local tax assessed on the compensation of employees.
Costs related to the continuation of group health care benefits during periods of paid sick, medical, or family leave
and insurance premiums;
Payments of interest on any mortgage obligations (which does not include any prepayment of or payment of principal
on a mortgage obligation);
Rent;
Utilities; and
Interest on other debt obligations incurred before Covered Period.

Loan Forgiveness

Borrowers may be eligible for forgiveness and cancellation of indebtedness up to the full amount of the Loan. The SBA website indicates that “due to likely high subscription, it is anticipated that not more than 25% of the forgiven amount may be for non-payroll costs”.

The amount eligible for forgiveness equals the following incurred during the 8-week period after the origination of the Loan:

payroll costs
mortgage interest payments
rent
covered utility payment costs

Any Loan with a remaining balance due after the loan forgiveness period is due within 10 years.

Reduction to Loan Forgiveness

In order to have the loan forgiven, you must keep the employees on your payroll or rehire them quickly and maintain current salary levels. Forgiveness will be reduced if full-time headcount declines, or if salaries and wages decrease. The borrower has until June 30, 2020 to restore any employees to be fully eligible for loan forgiveness.

For the Additional Guidance from Garfunkel Wild see here.

Consider a Loan Advance

If your situation is particularly difficult, you may request a loan advance of $10,000. You will still have to go through the process listed above, but this is meant to provide immediate relief – and will take a few hours to complete the on-line application and to supply the supporting documentation. For more information go to this website at the Small Business Administration:

Link to SBA Loan Advance

It’s a New World Conference 2020 – REGISTRATION OPEN

For the tentative agenda, click here.

To register, click here.

Infection Prevention Training April 7th – UPDATED AGENDA

Don’t forget to check out our guidance at www.ascpodcast.com.

Stay Safe!

—

John J. Goehle, MBA, CASC™, CPA

Chief Operating Officer
Ambulatory Healthcare Strategies, LLC
Rochester: 585-594-1167
Albany: 518-594-1167
Fax: 585-391-1402
Publications: 858-633-6392

April 1, 2020, 10:33 am

Good Morning to our Clients and Dear Friends,

Hope you are all doing well! There isn’t (wasn’t when we started writing this) much to say today as we await more news/progress on the “hospital without walls” program.

It’s a New World Conference 2020 – A Virtual Conference for Ambulatory Surgery Center

The ASC Podcast with John Goehle announces “It’s a New World Conference 2020 – A Virtual Conference for Ambulatory Surgery Center. Use this time to improve your skills and learn some new things. This two day “Virtual Conference” will be held on April 14th and 17th. For the tentative agenda, visit: https://ascpodcast.com/its-a-new-world-conference-2020/. Registration will be open shortly!

ASCA COVID-19 Update Today

https://ascassociation.formstack.com/forms/covid_19_response_webinar_registration

Infection Prevention Training April 7th

Hospital Cooperation

Please reach out to us if you are in contact/negotiations with a hospital so we can support you and other centers as you go through the process.

If you are planning on contracting with a hospital start thinking about all of the items that would need to be sorted out. For example: who would have to be on site, providing orientation training to staff coming in, documenting and maintaining equipment, procedures you will perform, who needs privileges, how much of the center will be turned over, what will you do with the drugs, etc…

Comment on Sterrad Sterilization of N95 Masks

Just a quick note, we do not recommend sterilizing N95 masks. Some of you may have sent information that this was possible, however please refer to CDC guidance here.

The ONLY approved process for decontaminating N95 masks appears to be Battelle, which requires that masks be sent to their facility and they will decontaminate the masks. See FDA approval of the process here.

AAAHC Additional Guidance

Change Notification
For service scope changes including temporary closures, suspension, and expansion of services directly associated with COVID-19, requirements for submission of the AAAHC Change Notification is waived until further notice.For all facilities, if your primary contact changes during this time, email AAAHC at [email protected] as we want to make sure we can reach you.CMS Position Regarding Temporary Closure
If a healthcare facility temporarily closes because it only provides elective cases/non-emergency treatment or appointments consistent with CDC and CMS recommendations, CMS would not view this as a cessation of business and, therefore, would not be deemed as a voluntary termination of the Medicare agreement under 42 C.F.R. §489.52 or §416.35(a)(3). Facilities needing to temporarily shut down or limit operations should post notices at their business as well as on public-facing websites and social media platforms during this emergency.COVID-19
Report suspected or confirmed cases of COVID-19 if you are within a survey window or if a case occurred within 14 days post survey by notifying AAAHC immediately at 847.324.7485. There is no need to report community outbreaks to AAAHC—just cases in your organization.Expiration
With a few exceptions, during this period, all accredited organizations will remain accredited regardless of anniversary/expiration date. Once normal operations resume across the country, AAAHC will schedule surveys through a “catch-up” process.Survey Activity
Surveys have been postponed with the exception of those organizations with identified Immediate Jeopardy, Infection Control deficiencies, or other deficiencies resulting in heightened safety risk to patients and employees, and Initial and Early Option (EOS) surveys.

Are you Considering Leasing Your ASC to the Hospital:

Here are some suggestions for calculating the lease rate:

The Sum of the Following:

Rent Expense and common area maintenance
Utilities expense
Other Overhead Costs, Including Insurance, Maintenance, etc.
Depreciation

Divided by the period of time for the lease payment (eg. Day, week, month). For example, if you are renting by the month – total the above and divide by 12 to come up with a monthly rate.

PLUS

Variable costs that you will incur:

Staff that you will provide to the hospital (maintenance, facility supervision such as a nurse manager) etc.
Any supplies that you might be asked to provide.

These are just some brief ideas. Please contact AHS if you are considering leasing your space.

Stay Safe!

—

John J. Goehle, MBA, CASC™, CPA

Chief Operating Officer
Ambulatory Healthcare Strategies, LLC
Rochester: 585-594-1167
Albany: 518-594-1167
Fax: 585-391-1402
Publications: 858-633-6392

March 31, 2020, 10:41 am

Good Morning to our Clients and Dear Friends,

Hope you are all doing well!

Live Podcast Today at 3pm

Live Podcast for 3 pm on Tuesday, March 31st. The Staff of AHS will be discussing the latest COVID-19 Issues, including the “Hospital Without Walls” program, Coding, Billing and IT issues during the Pandemic and more. Special Invited Guests, Nelson Gomes with Medicus IT, Cristina Bentin with Coding Compliance Management and Ann Geier with SIS.

Here is the link to the Live podcast on podbean.

CMS “Hospitals without Walls” ie. ASCs

Increase Hospital Capacity – CMS Hospitals Without Walls:
CMS will allow communities to take advantage of local ambulatory surgery centers that have canceled elective surgeries, per federal recommendations. Surgery centers can contract with local healthcare systems to provide hospital services, or they can enroll and bill as hospitals during the emergency declaration as long as they are not inconsistent with their State’s Emergency Preparedness or Pandemic Plan. The new flexibilities will also leverage these types of sites to decant services typically provided by hospitals such as cancer procedures, trauma surgeries and other essential surgeries.CMS will now temporarily permit non-hospital buildings and spaces to be used for patient care and quarantine sites, provided that the location is approved by the State and ensures the safety and comfort of patients and staff.

We are reaching out to ASCA for more information and we’ll discuss it during today’s podcast. We will provide additional guidance as it becomes available. Here is the original document.

SAVE THE DATE for ASC Virtual Conference Hosted by the ASC Podcast

This conference will be held on April 14th and 17th and will cover a multitude of topics including: emergency preparedness, survey preparedness, cost reduction, IT, patient financing of copays and deductibles, writing minutes, pharmacy, governing body oversight, and infection control.

More details to come!

Infection Prevention Coordinator Training (updated times)

Overview:

A live on-line training program to prepare nurses for the role as an infection control infection prevention coordinator or to improve the skills of infection prevention coordinators in the ambulatory surgery setting. This full-day course will focus both on the basic skills necessary to become an infection control coordinator and to build on skills that current coordinators already have. Particular emphasis will be placed on the infection control challenges of our current environment and preparing for more rigorous surveys in the near future.

The on-line (web-based) conference will be presented live on April 7, 2020 from 8 am to approximately 3 pm (with a break for lunch)

The conference will be recorded and available shortly after the live conference.

For Certified Ambulatory Surgery Infection Preventionists (CAIP), Six IPCU Credits have been applied for with the Board of Ambulatory Surgery Certification

Agenda:

Part 1: The Role and Responsibilities of the Infection Preventionist
Part 2: Developing An Effective Infection Control Plan
Part 3: Performing an Infection Control Risk Assessment
Part 4: Performing an Infection Investigation
Questions and Answers

For More Details visit the page at ascpodcast.com:

https://ascpodcast.com/asc-infection-prevention-coordinator-training/

What “Attendees” will be Provided:

In addition to the presentation, attendees will be provided with:

All the slides from the presentation
Tools to assist you in your duties as an infection control preventionist
- Risk Assessment
- Surveillance Tools
Certificate of “Attendance” that demonstrates training as an Infection Control Preventionist

Presenters:

Laurie T. Roderiques RN, BSN, CNOR, CASC, CAIP, LNC (Presenter)
John J. Goehle, MBA, CASC, CPA (Moderator)

To Sign up for this On-Line Conference:

When: Apr 7, 2020 08:00 AM Eastern Time (US and Canada)
Register in advance for this webinar:
Register for the On-Line Conference (For Non-AHS Retainer Clients)
If you are a paid Retainer Client of AHS, please email or call your contact at AHS or John Goehle to Register. Slots are limited, so please only one attendee per facility.

After registering, you will receive a confirmation email containing information about joining the webinar.

NYS is Seeking Qualified Health Professionals:

Health professionals who are interested in supporting the state’s response should visit https://coronavirus.health.ny.gov/get-involved-how-you-can-help and complete the survey.

Stay Safe!

—

John J. Goehle, MBA, CASC™, CPA

Chief Operating Officer
Ambulatory Healthcare Strategies, LLC
Rochester: 585-594-1167
Albany: 518-594-1167
Fax: 585-391-1402
Publications: 858-633-6392

The information provided in this email is not intended to be a comprehensive resource for all rules, regulations and standards that an Ambulatory Surgery Center must meet. The advice provided should not be considered as, nor does it constitute legal advice or opinion. When reviewing specific situations involving legal and regulatory issues, attorneys and other professionals should be consulted.

PRIVILEGED AND CONFIDENTIAL: This E-mail message and all attachments are property of the sender and are intended for the use of the individual or entity to which it is addressed and may contain information that is privileged, confidential and exempt from disclosure under applicable law. If the reader of this E-mail message is not the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited.

Mr. Goehle is the host of the “ASC Podcast with John Goehle” – a podcast for members of the ASC industry. The podcast is available on iTunes, Google Play, YouTube, TuneIn, Amazon Alexa or through the website at https://ascpodcast.com.

Mr. Goehle is a nationally-recognized author of several books about the health care industry including “The Survey Guide for ASCs A Guide to the CMS Conditions for Coverage & Interpretive Guidelines for Ambulatory Surgery Centers – 2017 Edition”, and “Ambulatory Surgery Center Governance – A Guide for Owners & Governing Body Members”.

Mr. Goehle’s books are available on his bookstore website at http://www.reg-books.com or through Amazon and Barnes and Noble (online).

March 30, 2020, 10:40 am

Good Morning to our Clients and Dear Friends,

Hope you are all doing well!

At this point we do not intend to do a Live Podcast or Zoom Conference today. This may change if we have high demand or more news. Please feel free to contact your main contact at AHS or me at 585-594-1167 with any questions.

Coronavirus Aid, Relief, and Economic Security (CARES) ACT

The CARES Act was signed into law on Friday. Here is the information for Small Businesses:

Economic Injury Disaster Loans and Loan Advance
To apply for a COVID-19 Economic Injury Disaster Loan, click here.
In response to the Coronavirus (COVID-19) pandemic, small business owners in all U.S. states, Washington D.C., and territories are eligible to apply for an Economic Injury Disaster Loan advance of up to $10,000. The SBA’s Economic Injury Disaster Loan program provides small businesses with working capital loans of up to $2 million that can provide vital economic support to small businesses to help overcome the temporary loss of revenue they are experiencing.The loan advance will provide economic relief to businesses that are currently experiencing a temporary loss of revenue. Funds will be made available within three days of a successful application, and this loan advance will not have to be repaid.

Warning: This is a very long process and will require a number of items from ownership. The form just changed back to being online.

NYS DOH 1135 Waiver Request Approved by CMS

Most of the Waivers deal with the process of being approved or paid by CMS.

Here is the full Waiver.

New NYS Return to Work Guidance

Essential personnel who have been exposed to a confirmed case of COVID-19 can be permitted to work in the required workplace setting if all of the following conditions are met:

Working from home would not be feasible for job duties;
Personnel are asymptomatic;
Personnel quarantine themselves when not at work;
Personnel undergo temperature monitoring and symptom checks upon arrival to work and at least every 12 hours while at work, and self-monitor (i.e. take temperature, assess for symptoms) twice a day when at home;
Personnel required to interact with individuals within 6 feet should wear a facemask1 while working for 14 days following the last exposure;
Personnel whose job duties permit a separation of greater than 6 feet should have environmental controls in place to ensure adequate separation is maintained, and do not need to wear a facemask;
If personnel develop symptoms consistent with COVID-19 (e.g., fever, cough, or shortness of breath) while working, they should immediately stop work and isolate at home; and
Testing will be arranged for any personnel with symptoms.

Essential personnel with confirmed or suspected COVID-19 can be permitted to work in the required workplace setting if all of the following conditions are met:

Working from home would adversely impact essential services or functions, including critical public health and public works infrastructure in New York or the response to the COVID-19 public health emergency;
Personnel have maintained isolation for at least 7 days after illness onset (i.e. symptoms first appeared) and have not had a fever for at least 72 hours, without the use of fever-reducing medications, and with other symptoms improving;
Personnel who are recovering from COVID-19, according to the above condition, must wear a facemask1 for 14 days following onset of illness.

See the full guidance here.

EXPANSION OF THE ACCELERATED AND ADVANCE PAYMENTS PROGRAM FOR PROVIDERS AND SUPPLIERS DURING COVID-19 EMERGENCY

On Saturday, CMS announced it was expanding its accelerated and advance payment program for Medicare providers. Accelerated and advance Medicare payments generally provide emergency funding based on historical payments when there is disruption in claims submission or claims processing. CMS has expanded the program for all Medicare providers during the public health emergency related to COVID-19.

To qualify for accelerated or advance payments, the provider or supplier must:

Have billed Medicare for claims within 180 days immediately prior to the date of signature on the provider’s/ supplier’s request form
Not be in bankruptcy
Not be under active medical review or program integrity investigation, and
Not have any outstanding delinquent Medicare overpayments.

Medicare will start accepting and processing the Accelerated/Advance Payment Requests immediately. CMS anticipates that the payments will be issued within seven days of the provider’s request.

Here is the full notice.

Here is the list of Medicare Administrative Contractors (MACs).

Here is the link for centers in Connecticut, New York, Maine, Massachusetts, New Hampshire, Rhode Island, Vermont, Illinois, Minnesota, Wisconsin, Alaska, Arizona, Idaho, Montana, North Dakota, Oregon, South Dakota, Utah, Washington, Wyoming, California, Hawaii, Nevada, American Samoa, Guam, Northern Mariana Islands.

AAAHC Change Form Waived

We received notice on Friday that centers will no longer be required to submit the Change Form when they close down or suspend certain procedures due to COVID-19.

Infection Prevention Coordinator Training

Overview:

The on-line (web-based) conference will be presented live on April 7, 2020 from 8 am to approximately 5 pm (with a break for lunch)

The conference will be recorded and available shortly after the live conference.

For Certified Ambulatory Surgery Infection Preventionists (CAIP), Six IPCU Credits have been applied for with the Board of Ambulatory Surgery Certification

Agenda:

Part 1: The Role and Responsibilities of the Infection Preventionist
Part 2: Developing An Effective Infection Control Plan
Part 3: Performing an Infection Control Risk Assessment
Part 4: Performing an Infection Investigation
Questions and Answers

For More Details visit the page at ascpodcast.com:

https://ascpodcast.com/asc-infection-prevention-coordinator-training/

What “Attendees” will be Provided:

In addition to the presentation, attendees will be provided with:

All the slides from the presentation
Tools to assist you in your duties as an infection control preventionist
- Risk Assessment
- Surveillance Tools
Certificate of “Attendance” that demonstrates training as an Infection Control Preventionist

Presenters:

Laurie T. Roderiques RN, BSN, CNOR, CASC, CAIP, LNC (Presenter)
John J. Goehle, MBA, CASC, CPA (Moderator)

To Sign up for this On-Line Conference:

When: Apr 7, 2020 08:00 AM Eastern Time (US and Canada)
Register in advance for this webinar:
Register for the On-Line Conference (For Non-AHS Retainer Clients)
If you are a paid Retainer Client of AHS, please email or call your contact at AHS or John Goehle to Register. Slots are limited, so please only one attendee per facility.

After registering, you will receive a confirmation email containing information about joining the webinar.

Stay Safe!

—

John J. Goehle, MBA, CASC™, CPA

Chief Operating Officer
Ambulatory Healthcare Strategies, LLC
Rochester: 585-594-1167
Albany: 518-594-1167
Fax: 585-391-1402
Publications: 858-633-6392

March 27, 2020, 10:10 am

Good Morning to our Clients and Dear Friends,

Happy Friday! Hope you are all doing well!

Mental Health Hotline for Health Providers

We know many of you are under a lot of stress during this time. This is not the time to ignore your mental health. Please call the hotline if you need any support during these trying times. As of Wednesday, 6,175 Mental Health Professionals in New York State volunteered to help providers like you.

New York Hotline: 1-844-0863-9314

CDC (SAMHSA) Hotline: 1-800-985-5990

https://www.cdc.gov/coronavirus/2019-ncov/prepare/managing-stress-anxiety.html

LIVE ASC Podcast Today at 3pm EDT

Here is the link for the audio feed today: https://www.podbean.com/lsw/John/s-NzPeh0Kuk7

If you want to watch via youtube go to: https://www.youtube.com/channel/UC-hvEz0wQCixVHuMAODSiow

REMINDER: There are a number of very useful COVID-19 Resources on ASCPODCAST.COM

ASCA Surge Capacity Report

ASCA has released a proposed plan for ASCs to assist local hospitals. The proposed plan includes 5 options and the Regulatory Changes that would be necessary to allow ASCs help in this manner. Very interesting, nothing concrete but something to keep an eye on. See the full report HERE.

ASCA Demographic Form

ASCA has provided us with a nice form to use for alerting hospitals and governmental authorities of our available resources. Get the form Here.

ASC Quality Reporting to CMS Not Mandatory for 2019

The Centers for Medicare & Medicaid Services has confirmed with ASCA that ASC quality reports due May 15, 2020, for CY 2019 services are no longer mandatory although any reports submitted voluntarily will be made public. No payment penalties will be assessed on ASCs that do not report.

https://www.cms.gov/newsroom/press-releases/cms-announces-relief-clinicians-providers-hospitals-and-facilities-participating-quality-reporting

Update from Laurie on AORN Guidelines

On tonight’s ASC Podcast with John Goehle, Laurie will discuss the use of PPE and Environmental Cleaning Strategies for those of you performing procedures and those of you anticipating to perform them during the Pandemic.

Coronavirus Aid, Relief, and Economic Security (CARES) ACT

We are closely monitoring for the impact on our industry and we will update you as the information comes down.

Stay Safe!

—

John J. Goehle, MBA, CASC™, CPA

Chief Operating Officer
Ambulatory Healthcare Strategies, LLC
Rochester: 585-594-1167
Albany: 518-594-1167
Fax: 585-391-1402
Publications: 858-633-6392The information provided in this email is not intended to be a comprehensive resource for all rules, regulations and standards that an Ambulatory Surgery Center must meet. The advice provided should not be considered as, nor does it constitute legal advice or opinion. When reviewing specific situations involving legal and regulatory issues, attorneys and other professionals should be consulted.PRIVILEGED AND CONFIDENTIAL: This E-mail message and all attachments are property of the sender and are intended for the use of the individual or entity to which it is addressed and may contain information that is privileged, confidential and exempt from disclosure under applicable law. If the reader of this E-mail message is not the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited.

Mr. Goehle’s books are available on his bookstore website at http://www.reg-books.com or through Amazon and Barnes and Noble (online).

March 26, 2020, 12:02 pm

Good Morning to our Clients and Dear Friends,

Hard to believe it’s only Thursday – it’s been a long week. We hope you are all safe and doing well.

ASCPODCAST.COM

We have reformatted the web site slightly to make information a little easier to find as our resources expand and your needs are adjusting. Please also refer to previous emails that are also available on the ascpodcast.com website. Likewise, we thought we would reformat our daily update slightly to make things easier for you to act.

Therefore we are going to go with a “To Do List” format. Let’s see how it works.

Top TO DOs for TODAY (if not previously done)

Notify your Accrediting Organization that you are Temporarily Shut Down

See the attached form for AAAHC notification along with a drafted narrative to be attached. This should be emailed to the relevant regional office (see the bottom of the form). You should also notify your state if you haven’t already done so. For Joint Commission or HFAP, we recommend that you contact your Accreditation Account Executive to communicate your change in operations.

Do Post-op Calls Daily

You should still be following up on patients that have come to the center in the last 24-48 hours. If you have staff available, it is a good idea to do post-op calls for patients at 7 days and 14 days. We recommend that you use these calls to check on their health with regards to COVID-19 symptoms. Beth had a great idea on last night’s call to put a positive spin on these calls so that patients know that the center’s care about their wellbeing.

Develop a Plan for Responding to Medical Record Requests

From a practical point of view, if the need for the medical records was urgent—as opposed to a request by an attorney, for example—and an ASC employee was willing to go get them, we would say go get them. For other, non-emergent requests, we would recommend that you would respond with a letter explaining that you are shut down due to the governor’s order. Also, the requirement to provide copies of medical records within the statutory period is a NYS, Public Health Law requirement. Per 45 CFR 164.524(b)(2) you have 30 days to respond to a request. This would be one example of a reason to keep key staff on payroll, so there is someone to respond to such requests.

Small Business Disaster Relief Loan

As stated in the email last night, the SBA provides low-interest disaster loans to help businesses recover from declared disasters such as COVID-19.
Here is the link to their current application page, which is as of right now, up and running:
https://www.sba.gov/funding-programs/disaster-assistance

Please see the link here for eligibility. If you are out client, ALL of our centers appear to eligible. Applications are due depending upon your region, but most due dates appear to be in December.

There are 3 forms that must be completed and sent in. The forms can be downloaded and uploaded here.

We recommend that everyone consider at least beginning the application process.

We are continuing to monitor the news on the Coronavirus Stimulus Package and will give you updates as they become available.

Staff and Systems

All of our staff remain healthy and on task. Our call volume remains quite high but all calls are being answered within the day now. All of our systems (emails, intranets and extranets, Dropbox) are working at specifications.

The accounting system has patched up it’s disagreements with our billing system and they are friends again – all payments that have been made in our accounting system are now reflected in the billing system – hopefully after today you should not be receiving dunning incorrect dunning notices. Note, however, that our outsourced accounting department has furloughed 70% of their employees and there might be delays in posting payments.

I am also behind in billing – which I hope to get caught up today. Again, I want to thank everyone who has continued to pay on schedule! Without you we would not be able to continue providing support to you all as well as feeding our families.

Stay safe and please continue reaching out as needed.

–

John J. Goehle, MBA, CASC™, CPA

Chief Operating Officer
Ambulatory Healthcare Strategies, LLC
Rochester: 585-594-1167
Albany: 518-594-1167
Fax: 585-391-1402
Publications: 858-633-6392The information provided in this email is not intended to be a comprehensive resource for all rules, regulations and standards that an Ambulatory Surgery Center must meet. The advice provided should not be considered as, nor does it constitute legal advice or opinion. When reviewing specific situations involving legal and regulatory issues, attorneys and other professionals should be consulted.

PRIVILEGED AND CONFIDENTIAL: This E-mail message and all attachments are property of the sender and are intended for the use of the individual or entity to which it is addressed and may contain information that is privileged, confidential and exempt from disclosure under applicable law. If the reader of this E-mail message is not the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited.

Mr. Goehle’s books are available on his bookstore website at http://www.reg-books.com or through Amazon and Barnes and Noble (online).

March 25, 2020, 11:12 am

Good Morning to our Clients and Dear Friends,

We hope you all are doing well and staying safe. Please see today’s update below.

Top TO DOs for TODAY (if not done yesterday)

Ensure Your Infection Control Plan is Up to Date (Especially if you are remaining open)

Our Infection Control Plans will be scrutinized to a heightened degree following the COVID-19 pandemic. Even if you don’t have an upcoming survey, the legal consequences to remaining open without a proper infection control plan could be severe. If you aren’t staying open, your plans will still be looked at in the coming year by surveyors looking more closely at infection control. Be sure to include pandemic policies, emerging infectious disease policies, and temporary protocols including the screening, isolation, and COVID-19 addendum provided yesterday.

Complete/Continue Life Safety Testing and Maintenance documentation before you Close Down

We touched base with AAAHC, who gave guidance to ensure all documentation is compliant before you leave and then do proper testing when you return. For example, your biomedical testing/maintenance should be done when you return to the center, your refrigerators should be set up with a min/max thermometer (one that alerts you when it goes out of range is best), and any monthly/ quarterly maintenance should be resumed upon your return.

Prepare for Re-opening 3-5 Weeks from Today (if currently closed or planning to close)

You should replace your Heating, Ventilation, and Air Conditioning Filters upon return to your center if you have had an exposure. Everyone else should still carefully consider replacing/cleaning their filters upon return since COVID-19 is considered prevalent in our communities.

Be prepared to have life safety testing resume upon your return to the center. This is particularly important if you are cancelling contracts or you have let them lapse due to contractors/staff not being on site.

Remember the following systems:

Electrical
Medical Gas
Vacuum System
Sprinkler
Fire Protection
Emergency Lighting
HVAC
Elevator (if applicable)
Biomedical

All non-patient care/support staff should be working from home or furloughed

The only staff that should be onsite if you are doing surgery should be staff with direct support to active patient care for non-elective/urgent cases. This is only if the center has had a board meeting to determine how procedures would be determined to be not-elective/urgent. The physicians will need to complete a form for each case done to attest that it is a not-elective/urgent procedure. This is being enforced with fines and potential loss of license in New York State.

CONTACT YOUR ATTORNEY

There are many legal issues regarding employment practices and operations under the governor’s mandate. If you have not contacted your attorney, please do so immediately to ensure that your actions are not putting yourself at legal risk.

FYI – NYS 1135 Waiver Request

We are in the process of reviewing the request that NYS made to CMS today to receive a number of 1135 waivers. PLEASE NOTE THESE ARE NOT APPROVED YET AND ARE SUBJECT TO CMS APPROVAL.

See the request here:

https://coronavirus.health.ny.gov/system/files/documents/2020/03/1135_waiver_request.pdf

Other states with 1135 Waivers include:

These can be found here: https://www.cms.gov/About-CMS/Agency-Information/Emergency/EPRO/Current-Emergencies/Current-Emergencies-page

Infection Prevention Teleconference

We are tentatively scheduling an Infection Prevention Teleconference on Tuesday April 7th. This will be a full day conference via Zoom for infection preventionists and prospective infection preventionists. Attendees will receive a certificate of participation which can be used to demonstrate training in infection control oversight. More details to come.

Staff and Systems

All of our staff remain healthy and on task, however, our call volume is up dramatically. All of our systems (emails, intranets and extranets, Dropbox) are working at specifications. The only system not functioning properly is our billing system – I am working to get this fixed today. Thank you sincerely to everyone who has continued to pay on schedule! Without you we would not be able to continue providing support to you all as well as feeding our families.

Stay safe and please continue reaching out as needed.

—

John J. Goehle, MBA, CASC™, CPA

Chief Operating Officer
Ambulatory Healthcare Strategies, LLC
Rochester: 585-594-1167
Albany: 518-594-1167
Fax: 585-391-1402
Publications: 858-633-6392PRIVILEGED AND CONFIDENTIAL: This E-mail message and all attachments are property of the sender and are intended for the use of the individual or entity to which it is addressed and may contain information that is privileged, confidential and exempt from disclosure under applicable law. If the reader of this E-mail message is not the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited.

Mr. Goehle’s books are available on his bookstore website at http://www.reg-books.com or through Amazon and Barnes and Noble (online).

March 24, 2020, 11:14 am

Good Morning to our Clients and Dear Friends,

We hope you are doing well. This will be a quick update (maybe).

Podcast

There is no podcast today. We’re not sure about tomorrow yet, but you can find yesterday’s podcast if you haven’t already listened to it here.

Staff and Systems

All of our staff remain healthy and on task, however, our call volume is up dramatically – we are experiencing delays in getting back to our clients – for which we are very sorry. Please don’t hesitate to reach out to me by text at 585-729-8781 and mark it “URGENT” if your issue is absolutely urgent. All of our systems (emails, intranets and extranets, Dropbox) are working at specifications. The only system not functioning properly is our billing system – our accounting systems are currently not “talking” and therefore payments are not reported to billing – meaning that you are probably getting dunning notices (yet again) that are not accurate. I apologize for this – but with our decentralized system – there is no quick fix.

THE FOLLOWING IS ALL NYS SPECIFIC. Centers from other states may still find this information helpful.

I sent out two communications this morning.

Clarification that ASCs are an “Essential” service, AND a reminder that any staff that is non-essential (or can work from home) are not allowed to work in the center. Also note that you DO NOT need to submit a request to be considered an essential service.
Notification that hospitals are to create a plan to increase their capacity by 50% to 100% by whatever means they can. ASCs DO NOT have to submit a plan – Only the Hospitals do.
- Encouraging hospitals to work with other centers (eg. ASCs) to take their caseload
- Clarifying what is elective and non-elective surgery based on CDC guidelines.

Please read these emails and feel free to contact me if you have any questions or concerns.

Communication with Local Hospitals

A big takeaway from the communications this morning is that while we might have to shut down for now – we have both an opportunity and an obligation to work with the hospitals to assist in dealing with the COVID-19 situation. New York Centers should be reaching out to the local hospitals IMMEDIATELY to provide them information about what we can do for them.

Therefore, we recommend that you contact all of the hospitals near you and state (if you wish) that you are ready and able to do procedures. You might also want to think outside the box and consider if there are other cases that you may be able to do in your center.

It is important to act QUICKLY to communicate with the hospital. As part of the plan to DOH, hospitals are encouraged to consider using other facilities, such as DTC, ASC and OBS, to increase surge capacity, if needed, and if not controlled by the licensed hospital, will need to submit a letter of intent in conjunction with the ASC outlining the arrangement and sending it to DOH. This might not be the only opportunity to assist the hospitals, but the earlier you communicate – the more likely that you will be part of the solution.

COVID-19 INFECTION CONTROL ADDENDUM

We have written an example COVID-19 protocol addendum for your infection control program to send to your local hospitals and train your employees on. Please see it attached – it is specific to NYS, but can and should be modified to your specific center even in NYS.

The intent of this addendum is to prove to the hospital that you are taking COVID-19 seriously and are prepared to perform surgeries in the current environment.

BECOMING A TESTING SITE

Here is the contact information if you wish to apply to become a testing site. They are looking for you to have an addendum to your infection control plan specific to COVID-19. We have attached an example to this email.

Here are the two contacts for applying to become a testing site:

[email protected]
[email protected]

Here is what needs to be included in your application email:

Items to Include in Email Request to Become COVID-19 Testing Site

Ownership
Center location/County/Region
Square Footage
Current Article 28/Former/Future
Any other pertinent information about the actual site (ie. supply levels, staffing levels, facility layout, parking capacity, beds with Oxygen outlets)

NOTES ON CREDENTIALING

Note that regulations regarding credentialing, etc. are still in place and will be enforced. We will work with you to expedite these processes if you desire.

This means that any doctors from the hospital that would be performing their procedures at the ASC would still need to be credentialed and privileged with the ASC as per normal protocols

Ventilators

There has been a request for you to offer your ventilators to NYS DOH via Rachel Baker at 518-281-5120. While your Anesthesia Machines have ventilator capabilities, for any patient needing ventilatory support, anesthesia gas machines capable of providing controlled ventilation or assisted ventilation may be used outside of the traditional use for anesthetic indication. Because of significant differences between the anesthesia gas machine and traditional critical care ventilators, use or supervision by an anesthesia provider is recommended. Refer to the manufacturers’ websites for specific instructions on safe use of anesthesia gas machines for this indication.

Here is a link for more information:

https://www.fda.gov/medical-devices/letters-health-care-providers/ventilator-supply-mitigation-strategies-letter-health-care-providers

Stay safe!

—

John J. Goehle, MBA, CASC™, CPA

Chief Operating Officer
Ambulatory Healthcare Strategies, LLC
Rochester: 585-594-1167
Albany: 518-594-1167
Fax: 585-391-1402
Publications: 858-633-6392

Mr. Goehle’s books are available on his bookstore website at http://www.reg-books.com or through Amazon and Barnes and Noble (online).

March 23, 2020, 11:02 am

Good Morning to our Clients and Dear Friends,

Well, it hasn’t been a quiet weekend. Some more of our centers have had staff that have tested positive for Coronavirus and we are seeing owners pushing back against shutting down in those states that have government mandated curtailment of essential services.

During this difficult time, it’s important that we remember our moral obligations as healthcare providers and our responsibility to protect the health and safety of our patients and staff. It is our position that unless you have a very strong case for the urgency of a procedure – you should curtail operations in those locations where the government has ordered non-essential services curtailed. After this is all over, we will be evaluated based on our actions and those organizations that chose to continue their regular operations as though nothing happened will likely suffer a diminished public image as well as possible fines, penalties and lawsuits.

NY Governor’s Mandate

Unfortunately, over the weekend, some guidance came out from the NY Governor’s office that defined “Essential Services”. This was sent out in a separate email from the State Association (I sent it out under separate cover this morning). This guidance doesn’t include ASCs. We hope that this was an oversight, but in light of this, we are recommending that all centers file an “Exception”.

If you are in NYS and you choose to stay open – you will have to complete this form on-line. Here is a link:

https://esd.ny.gov/content/request-designation-essential-business-purposes-executive-order-2026

If you need assistance determining your region:

https://esd.ny.gov/regions

We propose that you include the following language in the description of the business the following statement: “While we assume it was an accidental oversight not to include Ambulatory Surgery Centers in the exempt list, we are requesting to be added as we continue to do non-elective procedures as directed by the governor and approved by our governing body.”. In addition you will need to provide a list of the procedures that you will continue doing and the reason those procedures are non-elective.

Deciding to Close or Not

I will reiterate our advice at this point – we still feel that the physician’s are responsible for defining what “essential” or “non-elective” services are. This should be done using the board meeting template and forms we have provided for each case. Recognize, however, that there are probably going to be lawsuits later that will call into question your decisions. It is imperative that you have a sound basis for your decisions and that you don’t make a blanket decision that ALL of your procedures are “essential”. Also ,maintain a log of all cases that you cancel to show that you ARE assessing all cases. We have provided an example log on the “action plan” web site at ascpodcast.com.

We must note, however, that you could be subject to SIGNIFICANT legal consequences by staying open. There are potential penalties that you could be subject to in addition to the lawsuits we mentioned earlier. Doing cases like routine arthroscopies, diagnostic GI procedures, most plastic surgeries, etc will be somewhat easy show are non-essential. This is even more of an issue if you have had some type of exposure in the center.

If you choose to close, you will have to document a board meeting with that decision. We will post an example set of minutes on the ascpodcast.com website for this purpose.

Cloth Masks

There has been some discussion about using cloth masks in lieu of disposable paper masks. This is NOT an acceptable practice for surgical cases. Even for non-surgical situations it is a poor practice and certainly does not protect the user. We highly recommend against using cloth masks.

Issues About Furloughing/Laying Off Employees

There are a lot of questions about the differences between a furlough and laying off staff. We have been working with our friends at Cohen Compagni Beckman Appler & Knoll, PLLC and they have a great post at:

https://ccblaw.com/news-blog/what-employers-need-to-know-about-furloughs-and-layoffs/

During a furlough an employee cannot do any work, including taking phone calls. If you ask the employee to do any functions, including taking phone calls, the employee would most likely lose unemployment benefits and would have to be paid by you. Non-Exempt employees would be required to be paid the hourly rate, exempt employees would be paid their full pay. A periodic email to the employee about the status of the operations is probably all right.

We will have Laura Spring, Esq. on a podcast this afternoon to discuss further and to take questions.

Contracts

You need to review all of your contracts to determine if you are obligated under any of those contracts to pay for services absent volume. There are often notice provisions in those contracts to provide for termination. Please review them and act accordingly.

Ventilators

If you shut down, you may wish to volunteer the anesthesia machines to the local hospital. For any patient needing ventilatory support, anesthesia gas machines capable of providing controlled ventilation or assisted ventilation may be used outside of the traditional use for anesthetic indication. Because of significant differences between the anesthesia gas machine and traditional critical care ventilators, use or supervision by an anesthesia provider is recommended. Refer to the manufacturers’ websites for specific instructions on safe use of anesthesia gas machines for this indication.

Here is a link for more information:

https://www.fda.gov/medical-devices/letters-health-care-providers/ventilator-supply-mitigation-strategies-letter-health-care-providers

If you are in NYS, the governor has specifically requested assistance – “If you are a regulated health facility, we are asking you by order of the department of health to make that ventilator available. ”

Please call  Rachel Baker from DOH at 518-281-5120

Website Reminder

Don’t forget to visit https://ascpodcast.com/coronavirus-covid-19-action-plan/ periodically to see a summary of your action plan for COVID-19, all of the applicable forms and references.

Social Distancing in Waiting / Pre-Op / Post-Op

Just a reminder to enforce social distancing in all areas of the ASC. Make it easy for your patients and family members to remember to stay apart. For example, rearrange furniture, tape off chairs, etc.

Live Podcast / YouTube Live Video

We will have a live podcast and Youtube live video today. The tentative time is 4:00 PM Eastern. It will be for the national audience.

Here is the link for the live audio podcast:

https://www.podbean.com/lsw/John/s-elDRiVzixV

We are switching our YouTube Live feed to be under “ASC Podcast with John Goehle”. If you go to the youtube.com website and search for “ASC Podcast with John Goehle” at about 3:50 pm or thereafter, you should see a link for the live feed. We apologize for any confusion, but we are upgrading all of our systems here to handle the dramatically increased volumes we are experiencing. Thank you for your patience.

If you have any questions that you would like addressed during the podcast – please send them to [email protected].

Staff and Systems

I know that this is a lot to ask, but any payments that you can make at this point will help us to stay in business. We are a small, family run business – we would appreciate anything you can do during this time.

Please be safe and let’s make sure we make good decisions during this difficult time.

—

John J. Goehle, MBA, CASC™, CPA

Mr. Goehle is a nationally-recognized author of several books about the health care industry including “The Survey Guide for ASCs A Guide to the CMS Conditions for Coverage & Interpretive Guidelines for Ambulatory Surgery Centers – 2020 Edition”, and “Ambulatory Surgery Center Governance – A Guide for Owners & Governing Body Members”.

Mr. Goehle’s books are available on his bookstore website at http://www.reg-books.com or through Amazon and Barnes and Noble (online).

March 20, 2020, 11:44 am

Good Morning to our Clients and Dear Friends,

Given the Governor’s mandates this morning, we are currently planning on a live podcast for NYS facilities at 2 pm Eastern Time.

Please keep us informed about your operational status. We can handle notifications to AAAHC on your behalf (if we are listed as a contact with AAAHC – eg. if we assist with, file or manage your application and plan of correction).

Please continue to review our updated “action plan” page on the ASC Podcast website:

https://ascpodcast.com/coronavirus-covid-19-action-plan/

We are trying not to repeat previous advice – please see our previous emails and refer to the web site.

NYS Governor Press Conference Notes:

If you are a New York ASC or Clinic, Effective on Sunday, it is VERY likely that you need to shut down! There are civil penalties for failure to follow the state’s mandates! If you stay open, you need to make sure that you can fully justify your decision and that the cases you are doing are critical to the patients.

Here are some bullet points from the press conference:

Effective Sunday – 100% of non-essential services are to shut down in NYS. This is not voluntary – it is mandatory and the state will monitor.
Civil fines and mandatory closure for businesses that don’t follow requirements. If you decide to stay open and you are not providing absolutely essential services – you will face legal consequences.
Hospitals will be ordered next week state-wide to cease non-essential surgery
Remain indoors to greatest extent to protect health
Our patient population over 70 of age are to stay at home – ie. should not be going in for surgery unless absolutely necessary.
If you have a ventilator, please contact DOH at 518-281-5120 to lend your ventilator to the effort. They will reimburse you.

Preparation and Shutdown:

As we watch what is happening nationally, it is clear that we must all prepare for, or are already in the process of shutting down. Here is some information:

You should be consulting your benefits/HR consultants and/or lawyers as you curtail operations as to the proper way to do it. You should be notifying your employees in writing as to your actions.

Here is some helpful information.

The terminology you use when you stop operations is important. The most notable difference between a furlough and a layoff is that a furlough assumes that an employee will eventually return to work at your center. Generally, furloughed employees are eligible to continue benefits (eg. health insurance) during the period of

This article appears to have a lot of good advice about the legal issues. Note that the article encourages you to seek advice from an employment lawyer:

https://www.legalmatch.com/law-library/article/furlough-and-layoff-differences.html

Another article emphasizes that an employee cannot do ANY work for you or take calls or emails during a furlough. I assume that a call or email to tell them when they come back to work is permitted:

https://www.thestreet.com/politics/what-is-a-furlough-14832476

Employees that Need to remain Employed

As noted above, furloughed employees may not do any work for you. Therefore, you will have to maintain at least a minimum staff. For example – the administrator, clinical leader and business office manager will need to be consulted regularly during the shutdown to plan for starting up. They might not need to be employed full-time, but they have to remain working.

Consider that you will still need to pay your bills, collect money, bill and follow-up on claims. You will need to have staff to do that.

For our clients, we will provide any background services you need, including documenting board meetings, keeping your policies up to date and adjusted during the rapidly changing environment and working with the administration to plan and implement the reopening process. We will also monitor the survey status for your operation.

What to Do Before You Start Working from Home

The following is some advice about what to take as you leave. Some of this is pretty obvious, but hopefully helpful to you:

Take materials with you to manage board, committee and staff meetings remotely. This can be on paper, or electronic.
Consider saving documents electronically on a password protected (and preferably encrypted) laptop.
- If you are a client of AHS, use our “Extranet” (through Dropbox) to organize your materials for use remotely. The Extranet is HIPAA compliant and has the ability to retrieve deleted documents and provides up to 30 past versions of every document on the Extranet. If we manage your QAPI, Policies, Emergency Plan, Governing Body and Education program – all of that information is already there (though you might not have access to all of it depending on the permissions)
You should also include contact information for all of your employees, board members, and providers, and contracted providers (eg. Anesthesia Providers).
Policy and Procedure Manual (even if it’s paper), including the Emergency Plan, Medical Staff By-Laws, Infection Control Plan, etc.
List of all of your vendors, consider taking your contract binder/or a copy of the binder with you for reference
Inventory of your supplies that are on-hand and what you will need before you start up again. If possible a list of expiration dates for all drugs so that you can reorder if they expire prior to reopen.
Make sure you reset your Min/Max settings on your refrigerators and as soon as you reopen check to see if the temperature was outside the appropriate range during the shutdown.
Empty the staff and patient refrigerator prior to shutting down.
Provide AHS with all of your alternate contact information while you are not on-site so that we can provide updates and assist as you begin operations. \
Work with your AHS content to scan or copy any additional documents that you might need when you work remotely.
- Alex and John (who are the access rights administrators) can lock down specific folders if you only want certain people to access them.
- Contact Alex if you need help setting up your home computer or laptop to access these files off site. It is ABSOLUTELY critical that any computer you use to access our Extranet be password protected.
Make sure that all of your supplies are off the floor in the event of flooding
Unplug all unused equipment. Obviously keep your file servers are on and that the servers continue to be backed up.
Reach out to your Pharmacy Consultant about how to handle refrigerated drugs.
Reach out to vendors of frozen allografts, etc. to inquire about how to maintain during an extended period of shutdown.
Consider forwarding company mail to a designated person during the shutdown

As we mentioned yesterday, we have created a document that will provide some advice about what you can do from home on our website. Here is the link again:

https://www.dropbox.com/s/ibfy3exfwebaq1g/Ideas%20for%20Using%20Staffing.docx?dl=0

—

John J. Goehle, MBA, CASC™, CPA

Mr. Goehle’s books are available on his bookstore website at http://www.reg-books.com or through Amazon and Barnes and Noble (online).

March 19, 2020, 11:03 am

Good Morning to our Clients and Dear Friends,

We hope all of you are doing well, please stay safe.

We are not going to repeat information that we have previously published on our daily update. Please see previous emails or go to: https://ascpodcast.com/ahs-daily-client-update/ for all previous emails. As we are updating our client listserv, we realized that the list was quite outdated – therefore a number of you are receiving this daily update for the first time. We apologize for that oversight.

For a full (and updated) list of resources, please visit our resources on COVID-19 on the ASC Podcast website. This page is due for some major updates today, please check back frequently at:

https://ascpodcast.com/coronavirus-covid-19-action-plan/

COVID-19 Update:

Updated list of countries with Level 3 travel Notices:

China
Iran
Most European Countries
United Kingdom and Ireland
Malaysia
South Korea

Per John Hopkins 222,643 confirmed cases worldwide 9,415 confirmed cases in the United States.

ASCA:

The ASC Association has published a variety of excellent resources on their website:https://www.ascassociation.org/asca/resourcecenter/latestnewsresourcecenter/covid-19This information includes:

Guidance on Elective Surgery
Updates on ASCA 2020 (It is still on)
State Specific Guidance
General Resources about the Virus and Links to the National LInks
Human Resource links
Infection Control Links
Links to the CDC Recorded Webinars

PALS, ACLS and BLS Recertification:

As hopefully everyone knows, PALS, ACLS, BLS training needs to be “hands on”. We contacted the American Heart Association today and they have verbally told us that all PALS, ACLS and BLS certifications will be extended for 60 days. They recommend that you contact a trainer to let them know about your future needs and prepare for a need to get this training after the expiration.

Post Operative Phone Calls:

More now than ever, your post operative telephone calls are a critical part of your continuity of care. Make sure that you ask your patients about any COVID-19 symptoms and document in the medical records. We highly recommend that you do an additional followup calls after the patient has left. This isn’t so much for post surgical complications, but determining if the patient has COVID-19.

Here is a form that you can use:

https://www.dropbox.com/s/2br8oi8r9yu3k9j/Patient%20Wellness%20Form.docx?dl=0

What Can We Do From Home?

We are expecting that almost all ASCs will have a period of time where they will either be isolated at home, or have no patients in the surgery center. We have developed (and will continue to update) a list of some things that you and your staff can do during the downtime. Tackling these tasks will help you to be ready to move quickly to open up – and be prepared for the surge in volume:

Here is a link to this resource:

https://www.dropbox.com/s/gxbztv0mt6wen5y/Ideas%20for%20Using%20Staffing.docx?dl=0

Federal Paid Sick Leave:

https://www.fisherphillips.com/resources-alerts-congress-finalizes-covid-19-coronavirus-response-act

CMS Recommendations:

https://www.cms.gov/newsroom/press-releases/cms-releases-recommendations-adult-elective-surgeries-non-essential-medical-surgical-and-dental

https://www.cms.gov/files/document/31820-cms-adult-elective-surgery-and-procedures-recommendations.pdf

Beckers’s Article about ASC’s being used as screening sites;

https://www.beckersasc.com/asc-quality-infection-control/ascs-used-as-screening-stations-for-covid-19-3-things-to-know.html

Recommendations from Arnold and Porter regarding Employees:

https://www.arnoldporter.com/en/perspectives/publications/2020/03/pandemic-coronavirus-practical-and-legal

Resources for Specific States (State where we have clients):

NYS Sick Leave Bill signed into law:

https://www.governor.ny.gov/news/governor-cuomo-signs-bill-guarantee-paid-leave-new-yorkers-under-mandatory-or-precautionary

Information about applying for Unemployment in NYS:

https://applications.labor.ny.gov/IndividualReg/

NYS is waiving the 7-Day waiting period for Unemployment Insurance benefits for people who are out of work due to Coronavirus (COVID-19) closures or quarantines. The day you should file is based on the first letter of your last name. For last names starting with A – F, file on Monday. For last names starting with G – N, file on Tuesday. For last names starting with O – Z, file on Wednesday. If you missed your filing day, file on Thursday or Friday. Filing later in the week will not delay your payments or affect the date of your claim; all claims are effective on the Monday of the week in which they are filed.

Ohio:

http://jfs.ohio.gov/ouio/CoronavirusAndUI.stm
https://coronavirus.ohio.gov/wps/portal/gov/covid-19/home/local-health-districts-and-providers/lab-testing-for-covid-19Pennsylvania:
https://www.uc.pa.gov/Pages/covid19.aspx
https://www.health.pa.gov/topics/Documents/HAN/2020-PAHAN-488-03-17-ALT%20-Discontinu.pdf
https://www.health.pa.gov/topics/Documents/Diseases%20and%20Conditions/COVID19%20Testing%20Factsheet.pdf
https://www.health.pa.gov/topics/Documents/HAN/2020-PAHAN-486-03-11-ALT%20-%20Infect%20Pr.pdfConnecticut:
http://www.ctdol.state.ct.us/UI-OnLine/index.htm
https://www.ctdol.state.ct.us/DOLCOVIDFAQ.PDF
https://portal.ct.gov/-/media/Coronavirus/20200316-DPH-Important-Information-for-Connecticut-Physicians.pdfFlorida:
http://floridajobs.org/news-center/DEO-Press/2020/03/17/governor-ron-desantis-activates-emergency-bridge-loan-program-for-small-businesses-impacted-by-covid-19
http://www.floridajobs.org/docs/default-source/ra-dua-documentation/dua-faqs-3-17-20-updates.pdf?sfvrsn=805543b0_4New Hampshire:
https://www.dhhs.nh.gov/dphs/cdcs/alerts/documents/covid-19-update9.pdf
https://www.nheconomy.com/covid19
https://www.nhes.nh.gov/Texas:
https://www.dshs.texas.gov/coronavirus/healthprof.aspx
https://twc.texas.gov/news/unemployment-news#ifYourEmploymentHasBeenAffectedByTheCoronavirusCovid1

Live Podcast:

We will have a live podcast at 4:00 pm today. We will send out a link later today. Please email us any questions or issues you would like us to address during the episode to [email protected].

Today we will be broadcasting both on Podbean and Youtube Live. The Youtube live feed is delayed 15 seconds and will not include the ability to text in the app. If you choose Youtube, you will need to email us during the episode. We are also working on a Facebook live feed.

Please note that we will be doing a test of the equipment during the day – ignore any notifications that you might get prior to 4pm (unless you would like a behind the scenes look at our technology challenges!).

AHS and Staff Update:

Thank you for all of your support and patience during this challenging time. All of our staff is safe and hard at work. We respond to client issues as quickly as we can. Please call or text your contact – texting first is highly recommended. Much of our time is taken up with research and updating information our clients need.

Upcoming Events:

We will be continuing our periodic live podcasts which are free. We are also preparing some educational programs that we think will be useful to you as you go into isolation. Some of the things in the planning stages:

Infection Preventionist Training and Updates
Administrator Training
Finance, Accounting, Coding and Billing Training
A “Virtual” Conference (Maybe some state specific)

That’s it for today!

John and the Staff of AHS

—

John J. Goehle, MBA, CASC™, CPA

Mr. Goehle’s books are available on his bookstore website at http://www.reg-books.com or through Amazon and Barnes and Noble (online).

March 18, 2020, 10:42 am

Good Morning to our Clients and Dear Friends,

We hope all of you are doing well. It is our intention to continue doing daily updates for the near future.

It is important for you to visit the following web site which is updated regularly and contains more specific information and forms:

https://ascpodcast.com/coronavirus-covid-19-action-plan

New York City:

There has been NO CHANGE at this time to the Mayor’s order from Monday. The Mayor of NYC issued an executive order yesterday afternoon. We don’t know the exact time the order was issued (if that is important). Facilities have 96 hours to to discontinue “elective” procedures. It leaves it to the doctors to assess which are Elective according to “which procedures can be postponed or cancelled based on patient risk considering the emergency need for redirection of resources to COVID-19 response”.

Given some confusion regarding the timing of the order, the order takes effect as early as 4:00 pm when the press conference occurred or 7:00 pm when the order was posted. This means that NYC facilities must sometime between 4:00 pm to 7:00 pm on this Friday. This affects all New York City Facilities.

Please work closely with the doctors to determine which of your procedures are “Elective” as you have already started to do. All others should be cancelled.

The order is for five days – after which it will have to be renewed It will most likely be extended.

Here is the link to the order:

https://www1.nyc.gov/assets/home/downloads/pdf/executive-orders/2020/eeo-100.pdf

This is likely the beginning of similar orders in other areas of the country.

Mandatory State Reporting of a Shutdown

If you discontinue operations, you may be required to report that action to your state. For example, in NYS – a shutdown of any nature that is not related to normal business operations is a New York State Reportable event under NYPORTS. You will need to report your actions as soon as possible to the NYPORTS system. If you need assistance, please contact us for assistance.

For individuals in other states, please review your state regulations or contact us.

Guidance Regarding “Elective” Procedures:

Please see American College of Surgeons’ COVID-19: Guidance for Triage of Non-Emergent Surgical Procedures:

https://www.facs.org/about-acs/covid-19/information-for-surgeons/triage

Please see ASCA’s COVID-19: Guidance for ASCs on Necessary Surgeries:

https://www.ascassociation.org/asca/resourcecenter/latestnewsresourcecenter/covid-19/covid-19-guidance

Facilities that are Limiting Procedures to Non-Elective:

If you are under orders to limit procedures to “non-elective” procedures, you will need to take some emergency board actions and document the rationale for your decision making. This will take two forms; (1) Emergency Board Meeting Minutes, and (2) Executing a form for each procedure performed indicating that it is non-elective.

The following are example Emergency Board Meeting Minutes if you are under NYC Orders:

https://www.dropbox.com/s/yp9tcqhyemym6gh/Example%20Emergency%20Board%20of%20Directors%20Meeting%20%28NYC%29.docx?dl=0

The following are example Emergency Board Meeting Minutes for any situation where you limit the types of procedures:

https://www.dropbox.com/s/evy3tq073bhctwe/Example%20Emergency%20Board%20of%20Directors%20Meeting%20%28Generic%29.docx?dl=0

The following are example Emergency Board Meeting Minutes for facilities in Ohio under their Order:

https://www.dropbox.com/s/xqizzoze5e41azv/Example%20Emergency%20Board%20of%20Directors%20Meeting%20%28Ohio%29.docx?dl=0

The following is a form to use to document the decision to perform a non-elective procedure:

https://www.dropbox.com/s/ab9mifueq5jbpoq/Not-Elective%20Procedure%20Form.docx?dl=0

Monitoring Patients and Staff :

Upon arrival at the center all employees and staff should be screened.

It is recommended that temperatures be taken on all staff and patients upon arrival at the center. CDC defines the temperature of over 100.4 F as a fever, however, for Healthcare Workers, a temperature over 100.0 Fis considered a fever. Individuals with that temperature or higher should be sent home (NOT to an emergency room, urgent care center, etc.). Direct them to contact their health care provider and to contact the center with the instructions that they are given. If the staff member or the patient has a fever and other indicators (eg. traveled to an affected area or have been in close contact with and affected individual) you should also contact your local health department for advice as to how to proceed.
If you are in NYC – There is a new guidance for Healthcare Worker Self-Monitoring and Work Restriction In the Presence of Sustained Community Transmission of Coronavirus Disease 2019 (COVID-19)
- See: https://www1.nyc.gov/assets/doh/downloads/pdf/han/alert/2020/covid-19-healthcare-worker-monitoring-restrictions.pdf
In addition, screen your staff and the patients as follows:
- Do you or anyone in your household have symptoms such as fever, cough, sore throat, and/or shortness of breath (flu-like symptoms)?
- Have you or anyone in your household travelled internationally or travelled on cruise ships within the past 2 weeks. If yes, where?
- Have you had close or proximate contact with a suspected or laboratory-confirmed COVID-19 patient in the past 2 weeks?
- Close contact is defined as “being within 6 ft of a person displaying symptoms of COVID-19 or someone who has tested positive of COVID-19”
- Proximate contact is defined as “being in the same enclosed environment such as a classroom, office, or gatherings but greater than 6 ft from a person displaying symptoms of COVID-19 or someone who has tested positive for COVID-19”
Please note – we have no firm guidance on this issue – this is purely our advice based on the best information currently available. Please use your best judgement and don’t take unnecessary risks.
Here are some links to the guidance:
- https://www.health.ny.gov/diseases/communicable/coronavirus/docs/contacts_of_contacts_guidance.pdf
- https://www.health.ny.gov/diseases/communicable/coronavirus/docs/testing_guidance.pdf

Use of Cleaning Products:

REMINDER (From Yesterday) The following is a reference to the EPA guidance regarding the use of cleaning products. Anything on this list can be used against COVID-19. Search your products in the table below, by EPA Registration Number which can be found on the product label.

https://www.epa.gov/pesticide-registration/list-n-disinfectants-use-against-sars-cov-2

Institute Emergency Plan (No Change from Yesterday):

At this time, you should be activating your emergency plan (and make sure that it addresses these types of emergencies). If you are a client of AHS, your emergency plan is being revised by our staff. If you are not currently a client, we have provided a recommended policy on the resource page listed above. However, you should be reviewing your emergency plan to assure it fully meets the CMS requirements. If you need assistance – please reach out to me and we are available to assist.

Part of your emergency plan should be to reach out to both your local municipality’s emergency and health department and your local hospital to remind them of your availability.

Here is recommended Letters that you can email or send:

Steps to Prepare for a Shutdown (If Necessary)

Take materials with you to manage board, committee and staff meetings remotely. This can be on paper, or electronic.
If you are a client of AHS, use our “Extranet” to organize your materials for use remotely. The Extranet is HIPAA compliant and has the ability to retrieve deleted documents and provides up to 30 past versions of every document on the Extranet. If we manage your QAPI, Policies, Emergency Plan, Governing Body and Education program – all of that information is already there (though you might not have access to all of it depending on the permissions)
Work with your AHS content to scan or copy any additional documents that you might need when you work remotely. Alex and John (who are the access rights administrators) can lock down specific folders if you only want certain people to access them. Contact Alex if you need help setting up your home computer or laptop to access these files off site. It is ABSOLUTELY critical that any computer you use to access our Extranet be password protected.
For those of you who are not retainer clients of AHS yet – you likely do not have an “Extranet”.

Financial Issues:

No Update today – Sorry. There is activity at the national level but we don’t have clear guidance. We continue to monitor and hope to have an update tomorrow.

Sick Leave (NYS only)

To address the immediate need of employees affected by COVID-19 who are subject to mandatory or precautionary orders of quarantine or isolation, New York State has approved legislation will provide the following:

Employers with 10 or fewer employees and a net income less than $1 million will provide job protection for the duration of the quarantine order and guarantee their workers access to Paid Family Leave and disability benefits (short-term disability) for the period of quarantine including wage replacement for their salaries up to $150,000.
Employers with 11-99 employees and employers with 10 or fewer employees and a net income greater than $1 million will provide at least 5 days of paid sick leave, job protection for the duration of the quarantine order, and guarantee their workers access to Paid Family Leave and disability benefits (short-term disability) for the period of quarantine including wage replacement for their salaries up to $150,000.
Employers with 100 or more employees, as well as all public employers (regardless of number of employees), will provide at least 14 days of paid sick leave and guarantee job protection for the duration of the quarantine order.

It is our interpretation – For most of our centers in New York State, this will not have an impact on your finances UNLESS you don’t currently provide 5 days of paid sick leave OR you don’t provide short-term disability insurance. As stated above, you need to guarantee employees that they have a job to come back to. We will continue to monitor the situation will have more guidance as we go through the information.

Here is a link to the press release:

https://www.governor.ny.gov/news/governor-cuomo-announces-three-way-agreement-legislature-paid-sick-leave-bill-provide-immediate

Resources/ASC Podcast with John Goehle:

Please visit the ASC Podcast with John Goehle “Action Plan” page at: https://ascpodcast.com/coronavirus-covid-19-action-plan/. We are updating this page as frequently as possible to give you the latest updates.

Please listen to the ASC Podcast with John Goehle on your smartphone or on-line at ascpodcast.com. We have four live episodes currently posted. At this time, we don’t expect to do a live podcast today (Wednesday, March 18, 2020).

To be prepared for listening to future live podcasts, please be sure to download the “Podbean” app from your smartphone, search for the “ASC Podcast with John Goehle” and subscribe. You will be notified when new episodes are available and when we go live. We go live 10 minutes before the episode starts, this gives you warning so that you don’t miss anything.

When we do go live again, we will be experimenting with a live YouTube feed also. The YouTube channel can be found by searching for “John Goehle” on YouTube. You will see most of our old audio episodes of the podcast as well as the two video podcasts. If you subscribe to the YouTube feed, you will be notified of our live episodes when they go live. As with our Podbean live feed, we go live 10 minutes before the episode starts. With YouTube, you can listen to us on a computer and a smartphone without the special Podbean software.

We are working on Facetime live also and will roll that out after we figure out YouTube. Thank you for your patience as we learn to become broadcasters.

Our Staff/Technology:

We are back up to full staffing now that Judie has returned safely home from a “vacation”. Zach is still stuck in Atlanta with family. We have all agreed that it is safer for him to stay there for the near term. We all appear to be healthy and all of our technology is on-line and working as intended.

For all of our clients, we have the ability to help you organize video conferences/committee meetings/board meetings for you and your staff (in addition to meeting with us). Let your contact know if you want to avail yourself of the service.

Puppy Pictures:

During this difficult time, please be safe and take the time to reflect on all of the positive things in your lives. Sue and I are “expecting” – expecting a puppy that is – in 1 1/2 weeks. Last weekend we picked her and she picked us. Here are pictures to brighten your day!

“Talk” to you all tomorrow – and please keep in touch!

The Staff of Ambulatory Healthcare Strategies:

John Goehle
Sue Cronkite
Jenna Alvarez
Alex Bornemann
Judie D’Ambrosio
Laurie Roderiques
Meghan Fitch
Amy D’Urbano

—

John J. Goehle, MBA, CASC™, CPA

Mr. Goehle’s books are available on his bookstore website at http://www.reg-books.com or through Amazon and Barnes and Noble (online).

March 17, 2020, 10:19 am

Good Morning,

Here is the latest update:

Resources:

Please visit the ASC Podcast with John Goehle “Action Plan” page at: https://ascpodcast.com/coronavirus-covid-19-action-plan/. We are updating this page as frequently as possible to give you the latest updates.
Please listen to the podcast on your smartphone or on-line at ascpodcast.com. We have three live episodes currently posted. We are considering another episode sometime today.

Our Staff:

We have ordered all of our staff discontinue travel. Our communications systems are all on line and functioning as intended and we have full teleconferencing capability. Our staff is attempting to send information to affected clients as it happens – but we are struggling to keep up with the rapidly changing situation.

If you need assistance immediately, please call, email or text your contact. If you need to contact me, text or call me at 585-729-8781. Texting first is recommended since I am on the phone almost constantly. I will call back or direct the appropriate person to contact you.

New York City:

The Mayor of NYC issued an executive order yesterday afternoon. We don’t know the exact time the order was issued (if that is important). Facilities have 96 hours to to discontinue “elective” procedures. It leaves it to the doctors to assess which are Elective according to “which procedures can be postponed or cancelled based on patient risk considering the emergency need for redirection of resources to COVID-19 response”.
Given some confusion regarding the timing of the order, the order takes effect as early as 4:00 pm when the press conference occurred or 7:00 pm when the order was posted. This means that NYC facilities must sometime between 4:00 pm to 7:00 pm on this Friday. This affects all New York City Facilities.
Please work closely with the doctors to determine which of your procedures are “Elective” as you have already started to do. All others should be cancelled.
The order is for five days – after which it will have to be renewed It will most likely be extended.
Here is the link to the order:
- https://www1.nyc.gov/assets/home/downloads/pdf/executive-orders/2020/eeo-100.pdf
This is likely the beginning of similar orders in other areas of the country.

Monitoring Patients and Staff:

Upon arrival at the center all employees and staff should be screened.

It is recommended that temperatures be taken on all staff and patients upon arrival at the center. CDC defines the temperature of over 100.4 F as a fever. Individuals with that temperature or higher should be sent home (NOT to an emergency room, urgent care center, etc.). Direct them to contact their health care provider and to contact the center with the instructions that they are given. If the staff member or the patient has a fever and other indicators (eg. traveled to an affected area or have been in close contact with and affected individual) you should also contact your local health department for advice as to how to proceed.
In addition, screen your staff and the patients as follows:
- Do you or anyone in your household have symptoms such as fever, cough, sore throat, and/or shortness of breath (flu-like symptoms)?
- Have you or anyone in your household travelled internationally or travelled on cruise ships within the past 2 weeks. If yes, where?
- Have you had close or proximate contact with a suspected or laboratory-confirmed COVID-19 patient in the past 2 weeks?
- Close contact is defined as “being within 6 ft of a person displaying symptoms of COVID-19 or someone who has tested positive of COVID-19”
- Proximate contact is defined as “being in the same enclosed environment such as a classroom, office, or gatherings but greater than 6 ft from a person displaying symptoms of COVID-19 or someone who has tested positive for COVID-19”
If the patient has a temperature AND has any of the additional risk factors mentioned above, please contact your local health department for further guidance (eg. no action, quarantine of staff, closing of center, etc.)
Please note – we have no firm guidance on this issue – this is purely our advice based on the best information currently available. Please use your best judgement and don’t take unnecessary risks.
Here are some links to the guidance:
- https://www.health.ny.gov/diseases/communicable/coronavirus/docs/contacts_of_contacts_guidance.pdf
- https://www.health.ny.gov/diseases/communicable/coronavirus/docs/testing_guidance.pdf

Use of Cleaning Products:

This is the reference to the EPA guidance regarding the use of cleaning products. Anything on this list can be used against COVID-19. Search your products in the table below, by EPA Registration Number which can be found on the product label.
- https://www.epa.gov/pesticide-registration/list-n-disinfectants-use-against-sars-cov-2

California:

We don’t have clients in California at the present time, but certain actions in that state provides us a glimpse of what might happen elsewhere. Several counties in California, including San Francisco have instituted a “shelter in place” order. The order directs residents to stay inside unless absolutely necessary. All businesses considered non-essential – such as bars and gyms – were ordered to close, and its workers to work from home. Grocery stores, pharmacies, restaurants serving take-out, gas stations and other “essential businesses” remain open, while municipal services such as garbage collection will continue.

Institute Emergency Plan:

At this time, you should be activating your emergency plan (and make sure that it addresses these types of emergencies. If you are a client of AHS, your emergency plan is being revised by our staff. If you are not currently a client, we have provided a recommended policy on the resource page listed above. However, you should be reviewing your emergency plan to assure it fully meets the CMS requirements. If you need assistance – please reach out to me and we are available to assist.
Part of your emergency plan should be to reach out to both your local municipality’s emergency and health department and your local hospital to remind them of your availability. Attached are two examples of letters that you can send, email etc.

Financial Issues:

It appears now that it isn’t an issue of “if” our centers will need to limit operations but “when”. Most centers that I have spoken to have indicated that they don’t do enough non-elective procedures to justify staying open even if they are ordered to limit the procedures that they perform. While we might be called on under the 1135 Waiver to provide essential health services (such as triaging or critical care), that also might not be financially viable given other options available to the government and hospitals.
We will continue to monitor any options that become available and work with the ASC Association to remind the government and hospitals that we are here and willing to help.
It is my advice that you start looking into your options if you have to limit service. Please see the website at the beginning of this email for more information. We have tasked some of our staff to start reaching out for more information. At the very least, we would recommend contacting your bank about the availability of short-term lines of credit to cover your overhead, and whatever payroll you will continue during any period of shutdown.

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John J. Goehle, MBA, CASC™, CPA

Mr. Goehle’s books are available on his bookstore website at http://www.reg-books.com or through Amazon and Barnes and Noble (online).