Why ambulatory surgery centers need a compliance plan

According to the National Health Care Anti-Fraud Association (NHCAA), healthcare fraud financial losses are in the tens of billions of dollars each year. A conservative estimate is 3% of total health care expenditures, while some government and law enforcement agencies place the loss as high as 10% of our annual health outlay, which could mean more than $300 billion1.

Beginning in the mid-1990s, many healthcare providers were encouraged to develop and implement compliance plans. While many hospitals and large healthcare systems followed this guidance, many ambulatory surgery centers did not. As a result, those centers may unknowingly be at risk.

But the good news is that it’s never too late to implement a compliance plan. It doesn’t have to be expensive or time-consuming; in fact, there are simple and inexpensive steps that facilities can take to promote compliance and develop strategies2 that will keep your organization safe in the long run.

Choose who will develop the plan.

There are to options for establishing your plan: you can hire a consultant, like Compliance One Group, to develop it for you or you can prepare one yourself. The latter may be appropriate for smaller ASCs that have tighter operating budgets. If you choose to develop the plan yourself, you then have a couple of options: buying a ready-made, off-the-shelf product or starting from scratch. While a pre-developed plan may seem like a good idea at the time, keep in mind that your plan needs to be customized for your facility. Filling in the blanks of an off-the-shelf product will not be effective. 

Perform a facility audit. 

When it comes to audits, there are two that should be conducted: a standards and procedures audit to assess how well you are complying with regulatory requirements and a claims submission audit to examine the claims development and submission process from patient intake through to submission and payment of claims. 

However, these audits are not one-and-done; ASCs should re-audit annually to measure the success of the plan.

Write the plan.

Once you have performed your audits and have a thorough understanding of what your problem areas are, you can begin establishing your compliance plan. 

A standard compliance plan includes:

  • Overview of applicable federal and state laws
  • Duties and responsibilities of the Chief Compliance Officer
  • Acknowledgment form, signed by each owner and employee
  • Code of Conduct, applicable to owners, board members, and employees
  • Corporate compliance checklist
  • HIPAA compliance plan

If you would like to discuss how our team can assist you with effective compliance planning, leave me a message by clicking here.


1 https://www.nhcaa.org/resources/health-care-anti-fraud-resources/the-challenge-of-health-care-fraud/

2 http://www.outpatientsurgery.net/issues/2002/05/why-ascs-need-a-compliance-plan

Margaret Acker
Margaret Acker, RN, MSN, CASC
Surgery Center Expert at

Margaret brings a unique administrative perspective to our healthcare clients.

As a masters prepared registered nurse with a business background, Margaret's expertise in healthcare regulations and applications of standards provide a rich dimension to her team at Compliance One Group. Together, they review and ensure all areas are compliant and updated to best serve the needs of the physical environment as it relates to the safety and security of employees, patients, students, and systems in the healthcare, school, university, and multiple-use construction facilities.

Before joining the Compliance One Group team, Margaret retired as CEO of a large surgery center in the Midwest. She is a former member of the Board of Directors of Michigan Ambulatory Surgery Association (MASA), where she served as the PAC liaison and was formerly Treasurer and Membership Chair. Before her role as CEO, Margaret served as the Administrator of a physician-owned multi-specialty ambulatory surgery center that performed close to 5,000 surgeries per year.