Medicare Certification Resources

Obtaining Medicare certification for an ASC involves the following four steps. It is a fairly involved process that should be started as soon as practical to assure that it is completed in a timely manner.

1. Obtaining a National Provider Identifier

The first step in Medicare certification is to obtain a National Provider Identifier (NPI) from the National Plan and Provider Enumeration System (NPPES). The fastest way to receive a NPI is to apply via NPPES’s online system.

2. Enrolling in Medicare

The next step is enrolling in Medicare which can either be completed online via the Provider Enrollment, Chain and Ownership System (PECOS) or by completing the paper 855b form and mailing it to the Medicare Administrative Contractor (MAC) that serves your state. CMS requires that ASCs revalidate their enrollment every five years. ASCs will be contacted by their state's Medicare contractor and asked to revalidate. ASCs do not need to do anything until they are asked to revalidate.

3. Complying with Medicare’s Conditions for Coverage (CFCs)

CMS establishes requirements, called Conditions for Coverage that ASCs must meet in order to be certified. The requirements cover all aspects of an ASC from operational organization to facility design and patient care. It is important to note that the CFCs must be met for all patients and not just Medicare patients.

CMS also produces a State Operations Manual which includes guidance for surveyors, often referred to as the Interpretive Guidelines. The guidance specific to ASCs can be found in Appendix L: Interpretive Guidelines for ASCs. In addition to reiterating the text of the Conditions for Coverage, this document provides guidance on the meaning of the rules and further advice on how ASCs should comply.

It is important to note, however, that two other appendices also apply to ASCs. ASCs are required to comply with Appendix I: Survey Procedures and Interpretive Guidelines for Life Safety Code Surveys, which addresses the Life Safety Code, and Appendix Q: Guidelines for Determining Immediate Jeopardy.

ASCs are also required to maintain a compliant emergency preparedness (EP) plan, which must be reviewed and updated at least every other year. CMS eliminated the requirement that ASCs maintain a written transfer agreement with a local hospital, as well as the requirement that each patient have a medical history and physical (H&P) assessment prior to surgery. Additional information on the regulatory changes is available on the 2019 Omnibus Burden Reduction Rule webpage.

4. Compliance Survey

CMS has granted four private organizations - the Accreditation Association for Ambulatory Health Care (AAAHC), The Joint Commission, the Accreditation Commission for Health Care (ACHC) and QUAD A (formerly the American Association for the Accreditation of Ambulatory Surgery Facilities) — the authority to determine whether or not ASCs are in compliance with Medicare’s CFCs. In addition each of these organizations provides accreditation for ASCs. While there is no federal requirement that an ASC be accredited some states and private payers require it. Contact these organizations.

Alternatively, ASCs may be surveyed by their state’s Medicare agency, though in practice this choice may not be viable due to limited state resources. It should be kept in mind that the state Medicare agency may survey an ASC after it is open.

Additional Medicare Compliance Resources

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