1. Ambulatory Surgery Centers NY Metro ASC Symposium October 15, 2015 1

2. In order to participate in Medicare, an ASC must meet all Federal Requirements (489.13) – Civil Rights – Attestation – Enrollment – CMS Form 855 – Conditions for Coverage (CfC) – Survey Medicare Participation 2

3. Providers/Suppliers choose to seek participation in Medicare via state agency certification or “Accreditation with deemed status” through a CMS approved Accreditation Organization. Medicare Participation 3

4. Provides guidance to implement Medicare health & safety standards State Operations Manual – Appendix L Survey & Certification policy memos National Training Provides consultation to RO as appropriate CMS Central Office 4

5. Liaison to state agencies for determination of eligibility Approve, deny, or terminate certification Interpret guidelines, policies & procedures Levy enforcement actions First line of contact for SAs regarding all survey and certification matters CMS Regional Office 5

6. Contract with CMS as per 1864 Agreement Survey for compliance with Medicare requirements – Conditions for Coverage (ASC CfCs) Make certification recommendations to the RO Report certification issues to RO State Agencies 6

7. National organization that accredits provider entities, under a specific program Accredited provider entities under each program are widely located geographically across the United States AO standards and survey processes meet or exceed those used by CMS to determine a health care facility’s compliance with the CfCs Accreditation Organizations 7

8. Currently there are 4 CMS-approved ASC accrediting organizations (AO) AAAHC AAAASF AOA (HFAP) TJC Accreditation Organizations 8

9. Deemed status means that CMS has certified an ASC for Medicare participation, based on the following criteria having been met: The ASC has voluntarily applied for, and received, accreditation from a CMS-approved AO; The AO has recommended the ASC to CMS for Medicare participation; CMS has accepted the AO’s recommendation; and finds that all other participation requirements have been met. What is “Deemed Status”? 9

10. I’m accredited by….. Why is CMS here???? 10

11. Participation in Medicare requires compliance with CfCs Compliance is determined by a Federal survey conducted by the State (non deemed), or Determined by a “deeming” survey conducted by a CMS approved AO Approved AO may offer either “accredited” or “accredited with deemed status” If an ASC is accredited but not deemed: – It is under direct State authority – The AO survey cannot be used to qualify for Medicare or Medicaid payment (participation) “Accredited” or “Accredited with Deemed Status”? 11

12. Are exempt from routine surveys by the SA May receive a “validation” survey by the SA May receive a complaint survey by the SA Deemed Status ASCs 12

13. If CMS determines that an accredited/deemed ASC is out of compliance with a CfC (condition level deficiency) – We remove deemed status The ASC remains “accredited” however, CMS has removed its “deemed status” The ASC is now subject to direct SA authority Removal of “Deemed Status” 13

14. Deemed status will not be returned: Until the SA determines via onsite survey that all CfCs are in compliance Or, if CfCs are determined in compliance, but standard level citations remain, and an acceptable Plan of Correction has been received by the SA Return of Deemed Status 14

15. Surveys are always unannounced Refusal to allow survey is a basis for termination Interfering with a survey is a basis for termination Refusal to allow photocopying is a basis for termination Additional Info 15