Introduction The proposal for the new ambulatory center creates a challenging set of circumstances for the Board, as it has created controversy regarding potential admitting privileges for competing physicians. The success of the hospital has been contingent upon the formation of a dedicated staff and leadership team with a commitment to the hospital and its practice of providing high quality care and treatment to all of its patients. The proposed ambulatory center is likely to complicate the strategic approach that is already in place and may also contribute to a lack of support from its existing employee base, along with a decreased rate of utilization, which could pose serious financial implications for the organization as a whole. As a result, it is necessary to examine the context of this proposal and to determine if it will achieve the desired end result, using a comprehensive review method that is standardized and appropriate in order to determine the best strategy moving forward.
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The monetary and human capital that is required to support this proposal is substantial and will necessitate the allocation of all necessary resources to secure the project’s inception. Adherence to all required laws and regulations is critical; therefore, a Certificate of Need (CON) is required for this proposal, as it falls under the types of healthcare organizations that mandate this process, particularly since it is an ambulatory surgery center and is considered to be new construction with the need for new types of medical equipment (New York State Department of Health). This is a multi-level process with significant compliance requirements during the application stage so that the proper determination is made regarding the efficacy of this proposal and its overall impact on the organization, its existing employees, and its patient population (New York State Department of Health). A number of forms are required that involve architecture and engineering certification, accompanied by application fees and schedules to support the expansion/conversion of the business with its new entity (New York State Department of Health).
For this submission, it is necessary to provide a number of schedules, including General Information, Personal Qualifying Information, Legal Information, Working Capital Financial Plans, Architecture Plans, Environmental Assessments, and Project Costs, among others (New York State Department of Health). These schedules enable the assessment/evaluation team to make a determination that will support or negate the need for the new facility. This also reflects a need to obtain as much information regarding the project as possible so that an appropriate decision may be made regarding its overall efficacy and its ability to be effective in meeting the needs of the patient population.
A number of factors are necessary in order to determine whether or not those selected to practice in the new facility have the required expertise, particularly those from other areas This includes The Joint Commission for accreditation and the Centers for Medicare and Medicaid Services, both of which possess significant expertise and knowledge of how to operate successful healthcare organizations. For example, The Joint Commission possesses a number of lengthy requirements for accreditation, including an evaluation of the facilities to be used, the appropriate licensure for the desired medical practices, a list of services that are provided, and meets minimum patient volumes as a hospital-based organization (2016). This organization also possesses the capability and the support of the Office of the Inspector General and the Centers for Medicare and Medicaid Services to inspect all facilities to ensure they meet all requirements, including licensure and other factors (The Joint Commission, 2016).
The Centers for Medicare and Medicaid Services will serve as a key decision-maker in determining how to pay for the services that are provided by the new facility, and this is represented by a CMS contractor, who is responsible for determining whether or not the facility has met all requirements to obtain billing privileges as a Medicare Facility (2016). Most importantly, the CMS Regional Office plays an important role in determining the eligibility of the facility for Medicare billing status, using enrollment statistics and programmatic strategies in making these decisions (CMS, 2016). In order to complete these requirements, a Medicare Enrollment Application is required and will serve as the support document in any decision-making regarding the billing eligibility of the facility and its practices moving forward, including the recruitment of physicians from other locations who will seek admitting privileges within the new organization (CMS, 2016).
Conclusion
It is the responsibility of the hospital in question to take any and all required steps in order to meet the state and federally mandated requirements in constructing a new ambulatory facility. This is a complex and lengthy process that requires a number of applications, schedules, justifications, and information that will enable The Joint Commission and the Centers for Medicare and Medicaid Services to make effective and appropriate decisions regarding the future of the new facility. The ability of the organization to obtain the necessary approvals and licensure requires the completion of all required applications, site visits, and licensure regulations so that the organization, upon approval, will be fully operational and will support the needs of its patients. The nature of this process also requires the organization to be evaluated and/or monitored in order to ensure that it remains compliant with all minimum requirements once it is up and running.
- Centers for Medicare and Medicaid Services. Medicare enrollment application. Retrieved from
https://www.cms.gov/Medicare/CMS-Forms/CMS-Forms/downloads/cms855a.pdf - The Joint Commission (2016). Eligibility for hospital accreditation. Retrieved from
http://www.jointcommission.org/accreditation/hospital_seeking_accreditation.aspx - New York State Department of Health (2015). How to determine if CON submission is required. Retrieved from https://www.health.ny.gov/facilities/cons/more_information/
- New York State Department of Health (2015). List of CON schedules. Retrieved from
https://www.health.ny.gov/facilities/cons/more_information/schedules.htm
