Article

Compliance

Practice vs. ASC

A compliance comparison shows that requirements differ for these entities.

I am often asked about required education and compliance training for practices and ambulatory surgery centers (ASCs). The bottom line is that while there are similarities, the compliance requirements are not the same for both entities.

No single specific resource clearly defines the compliance or regulatory training an ophthalmic practice is required to provide, but federal law and regulations require employee training on certain topics.

I find some practices that own or are affiliated with an ASC provide specific training as part of the regulatory compliance needed for ASC licensure or accreditation — while not realizing the same training is not needed (or applicable) in the physician’s office.

Tale of the tape

Table 1 breaks down training and compliance for practices and ASCs. ASCs are regulated by the federal and state governments due to licensing and credentialing maintained by surgery centers for the nature of the work performed: anesthesia, surgery, and level of care. Practices are not held to the same standards.

Table 1. Physician practice compliance vs. ASC compliance
PHYSICIAN PRACTICE COMPLIANCE ASC COMPLIANCE
Training and compliance elements Required Best practice/recommended Required
HIPAA, including security risk analysis
OSHA: Bloodborne pathogen/hazard communication
Fraud, waste, and abuse
EEOC Title VII (15 or more employees) and ADA
FMLA (50 or more employees)
Compliance plan
Risk analysis — Security Risk Assessment (HIPAA; HITECH)
CPR — Basic life support
Infection control and hand hygiene
Workplace violence
Disaster plan and drills 1
Fire safety training and drills 2
Laser safety, if applicable
ALS — Advanced life support
Patients’ rights
Mock code (cardiac arrest or related)
Malignant hyperthermia, if applicable
1. Preparedness and two drills per year required. 2. Quarterly drills required.

Discussion

It is never “wrong” to provide extra training and education, but providing unnecessary training is costly and may confuse a non-medical employee who is attempting to learn about ophthalmology. A consistent, comprehensive employee training program should be tailored to fit the practice and the needs of patients. Also, it is acceptable and encouraged to include customer service or other training specific to the office’s needs and the type of patients served.

Programs, content for developing internal presentations, and materials to use as training tools/resources can be easily found online. But, these resources may need to be tailored to fit the specific, individual needs of the practice. Also, several ophthalmic companies offer online courses. OP