M A R C H 2 0 1 7 O U T P A T I E N TS U R G E R Y. N E T 5 9
1. New versus existing construction. If you remodel, you must follow
the rules for new construction. You might have a 20-year-old building, but if you
decide to renovate a procedure room, everything needs to be done according to
the "new" rules.
2. Initial verification testing. Maintain records of your initial verification
testing on fire alarms, sprinklers, generators and medical gases. Although a con-
tractor might hold onto this documentation, file it away for safekeeping.
3. Blueprints. Likewise, always have a construction project's blueprints on
body determines otherwise, both facilities would be non-compliant and, as a
result, likely necessitate a significant investment to become compliant in accor-
dance with the proper risk category," he says.
What if your facility wants to introduce a new service line? The risk assessment
applies here, too. Mr. Crowley says you'd need to upgrade your facility's systems
and equipment to comply with the higher risk category.
• Seek out experts. The codes are involved and can be confusing. That's why
it's important to partner with a healthcare architect or fire protection engineer
who can help you navigate the new regulations, says Chad Beebe, AIA, FASHE, the
deputy executive director for advocacy for the American Society for Healthcare
Engineering of the American Hospital Association.
• Be proactive. "Act now to identify where you're not in compliance and devel-
op a strategy to meet the missing requirements," says Mr. Beebe. "If you get
surveyed tomorrow, and you haven't done anything, you'll get in more trouble
than if you've outlined a 3-year compliance plan." Mr. Beebe says noncompliant
facilities have 60 days to correct issues that CMS surveyors identify before
Medicare and Medicaid reimbursements are stopped. In some instances, says
Mr. Beebe, CMS could seek to recoup fees it paid to noncompliant facilities
before doling out additional reimbursements.
— Bill Donahue
