Wiki ASC CMS guidleins

midnight1995

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I am curious if any one is billing for an ASC- per the CMS guidelines which is The regulatory definition of an ASC does not allow the ASC and another entity, such as an adjacent physician's office, to mix functions and operations in a common space during concurrent or overlapping hours of operations. CMS does permit two different Medicare-participating ASCs to use the same physical space, so long as they are temporally separated. That is, the two facilities must have entirely separate operations, records, etc., and may not be open at the same time. Trying to find out if 1.) ASC and providers are using the same EMR system if it is provider owned? 2.) if the ASC is billing and the individual providers are documenting in the EMR inside the ASC and than billing out of the providers own system for claims.

If anyone has any insight regarding the above that would be great.

Thank you
 
It appears that would be problematic.

Adjacent physician office: Some ASCs may be adjacent to the office(s) of the physicians who practice in the ASC. Where permitted under State law, CMS permits certain common, non-clinical spaces, such as a reception area, waiting room, or restrooms to be shared between an ASC and another entity, as long as they are never used by more than one of the entities at any given time, and as long as this practice does not conflict with State licensure or other State law requirements. In other words, if a physician owns an ASC that is located adjacent to the physician’s office, the physician’s office may, for example, use the same waiting area, as long as the physician’s office is closed while the ASC is open and vice-versa. The common space may not be used during concurrent or overlapping hours of operation of the ASC and the physician office. Furthermore, care must be taken when such an arrangement is in use to ensure that the ASC’s medical and administrative records are physically separate. During the hours that the ASC is closed, its records must be secure and not accessible by non-ASC personnel.

If the records are using the same space (physical shelving for charts or a software system), then they aren't physically separate and secure and non-accessible by other personnel.

Full regulations here.
 
It appears from that article that they can use the same EMR if the records are indeed secured. I'm guessing the "physically separate" part came in before the widespread use of EMR.
 
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