CMS Hospital Surgery, Anesthesia, and PACU, Standards

Why Should You Attend:

Deep sedation is considered anesthesia, so these standards can affect the care provided in places like the emergency department, radiology, GI lab, pain clinic or any other place deep sedation is provided. This includes the use of Propofol. The number of deficiencies for the anesthesia tag numbers will be discussed in this webinar.

This program will cover the CMS standards on pre-anesthesia evaluations, post-anesthesia evaluation, and anesthesia services. Hospitals are required to have many policies including one on specific clinical situations involving anesthesia or analgesia. This section also addresses what anesthesia policies are required and what must be documented by the anesthesia provider during surgery.

Come to this program and learn all about the CMS anesthesia guidelines and how your hospital can ensure compliance. The hospital must demonstrate the acceptable standard of care and this should be referenced in the policy and procedure. Do you know what four things CMS defines as anesthesia and the four things defined in the pain bucket? What do you need to do if your emergency department physicians and GI doctors want to do deep sedation to ensure compliance?

A two-page FAQ on anesthesia by CMS will also be discussed. This includes interpretive guidelines on moderate sedation and deep sedation. It impacts moderate and deep sedation done in other places like the emergency department and GI lab and patients who have ECTs.

Come hear about the CMS anesthesia standards from a speaker who wrote the book on how to comply with these standards.

CMS said that hospitals are expected to develop policies and procedures that address the clinical circumstances under which medications that fall along the analgesia-anesthesia are considered anesthesia and to specify the qualifications of the practitioners who can administer analgesia. This seminar will explain each of the past four changes and when and why the changes were made.

These also impact issues related to CRNAs and the provision of analgesia during labor and delivery. The regulations discuss who can administer anesthesia and supervision requirements of CRNAs and anesthesiology assistants. The guidance also covers what types of anesthesia services are subject to the requirements governing the administration of anesthesia including deep sedation. Hospitals will need to make sure their policies and procedures and credentialing and privileging policies reflect these requirements. A good change was made regarding the previous requirement that all outpatients who have had anesthesia must have a postanesthesia assessment before they left the hospital as long as it is done and documented within 48 hours. (except CAH)

Learning Objectives:

• Recall that CMS requires a number of policies and procedures related to anesthesia services
• Describe that CMS has a list of things that must be documented in the intra-operative record by the anesthesia provider
• Discuss that CMS has specific requirements that must be documented in the post-anesthesia evaluation
• Recall that CRNAs can be supervised by an anesthesiologists and/or operating surgeon unless a state exemption is obtained
• Discuss that there are requirements for the pre-anesthetic assessment and that it must be done within 48 hours of the time the first drug is given to induce anesthesia
• Understand that the postanesthesia assessment must be done within 48 hours of the time the patient is sent to recovery (CAH must be done before the patient leaves the hospital)

Areas Covered in the Webinar:

• Must comply if hospital does any type of anesthesia
• Director of Anesthesia Services
• Number of deficiencies from CMS
• Anesthesia verses analgesia
• Anesthesia as a continuum
• Anesthesia services subject to requirements
• General, regional, MAC, deep sedation, topical, minimal sedation, local, moderate sedation definitions
• Rescue capacity
• Following nationally recognized guidelines
• Determining if sedation provided in the ED involves anesthesia or analgesia
• Supervision of those who administer anesthesia for each category
• Medical staff bylaws regarding granting privileges
• Assignment of nursing personnel
• Training on IV administration
• Policies and procedures must be periodically reviewed
• Review of adverse events and medication errors
• OR, Radiology, OC, ED, Clinics, Psychiatry and other sites where anesthesia is provided
• QAPI
• Director of Anesthesia responsibilities
• Who can administer anesthesia
• Scope of practice for CRNA and Anesthesia Assistants
• CRNA state exemption
• Anesthesia Policies required
• Criteria for privileges
• Board of Directors responsibilities
• Preanesthesia assessment and 48 hour requirement continues
o Some elements may be collected within 30 days
• Post-anesthesia evaluations
• Consent, infection control, documentation, safety policies required
• Documentation requirements
• Intraoperative anesthesia record requirements
• 48 hour post-anesthesia assessment for inpatients
• CAH must be done prior to discharge-tag 323
• New outpatient assessment guideline
• FAQs for revisions to anesthesia services

Who Will Benefit:

• Chief of Anesthesia
• Anesthesiologists
• CRNAs
• Anesthesia Assistants
• Director of the OR and OR nurses
• PACU Nurse Manager
• Medical Credentialing Staff
• Patient Safety Officer
• Risk Manager
• Chief Nursing Officer (CNO)
• Chief Medical Officer (CMO)
• Chief Operating Officer (COO)
• Chief Executive Officer (CEO)
• OB Nurses and Nurse Director
• Quality Improvement Director
• Regulation and Accreditation Director
• ED Directors and ED physicians
• Nurse Educator
• PI Director
• Compliance Director
• GI Department Directors and GI physicians
• Board Members
• Medical staff
• Legal counsel
• Anyone who is involved in assisting with cases of anesthesia and moderate sedation or who is involved in ensuring compliance with the CMS CoPs

Sue Dill Calloway
chief learning officer, Emergency Medicine Patient Safety Foundation

Sue Dill Calloway is a nurse attorney, a medical legal consultant and the past chief learning officer for the Emergency Medicine Patient Safety Foundation. She is the immediate past director of Hospital Patient Safety and Risk Management for The Doctors Company. She is currently president of Patient Safety and Health Care Education and Consulting. She was a medical malpractice defense attorney for many years and a past director of risk management for the Ohio Hospital Association. She was in-house legal counsel for a hospital in addition to being the privacy officer and compliance officer. She has done many educational programs for nurses, physicians, and other health care providers. She has authored over 102 books and numerous articles. She is a frequent speaker and is well known across the country in the area of healthcare law, risk management, and patient safety. She has taught many educational programs and written many articles on compliance with the CMS and Joint Commission restraint standards.

Topic Background:

The changes affected PPS hospitals and not CAH although critical access hospitals have many similar requirements in their CoP. It may be helpful for CAH to listen even though they are governed by appendix W. The specific CAH requirements will be discussed. Tag 322 requires that a postanesthesia assessment be done before the patient leaves the hospital.

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