FASA applauds the efforts of the OIG to review Medicare's oversight of the quality of medical and surgical care in ambulatory settings. However, by focusing only on one type of ambulatory surgery provider, ambulatory surgery centers (ASCs), the report does a disservice to Medicare beneficiaries by not providing comparative data on Medicare's oversight of quality in hospital outpatient departments and physicians' offices at the same time.

The report deals solely with Medicare's inconsistent oversight of accrediting bodies and Medicare surveyors, not the quality of surgical services provided in ASCs. FASA President Bob Williams noted the "report has few surprises" and expressed his concern that "Medicare beneficiaries and other patients will be misled to believe that surgery in an ASC is unsafe." Nothing could be further from the truth. ASCs offer high quality services, which is not disputed by the OIG report. In fact other statements by the OIG suggest that Medicare beneficiaries benefit from access to ASCs. In 1999, the OIG said "that ASCs can significantly reduce costs for Federal health care programs, while simultaneously benefiting patients." In another section the IG notes, "Our regulatory treatment of ASCs recognizes the Department's historical policy of promoting greater utilization of ASCs because of the substantial cost savings to Federal health care programs when procedures are performed in ASCs rather than in more costly hospital inpatient or outpatient facilities."

This report questions whether government regulatory bodies have done their job well. Moreover, since the same bodies are supervising other providers of ambulatory surgery there is nothing to suggest that other providers are any better or worse.

While this report makes some useful recommendations, there is little in it that examines the real issues affecting Medicare beneficiaries' access to quality health care services. Kathy Bryant, Executive Director of FASA, commented that "the report should focus more on the inconsistency of these surveys among the states. Increasing Medicare's oversight of ASC certification should begin by making these surveys by government regulatory bodies consistent across the country." The report does not address Medicare's neglect of other responsibilities such as updating the ASC list of approved procedure codes and the outdated Medicare cost survey.

FASA continually strives to improve quality in ASCs and the Medicare certification, state licensure and accreditation processes are key components. FASA offers its members the opportunity to participate in a free quarterly outcomes monitoring project. In addition, it offers numerous educational sessions and materials to assure that the industry is informed. We look forward to working with CMS as it evaluates the suggestions of the OIG.