To the Editor:
It is with some great concern that I have had an opportunity to review your recent APSF Newsletter, Spring 2000. In this issue there was presented what amounts to a cross walk of the three organizations that can accredit office-based anesthesia (OBA) sites. Much of what was used was apparently gleaned from the material that had been published and distributed by the Florida Society of Anesthesiologists. Following that distribution by that group, I had an opportunity to reply in a several page letter to them pointing out the various inconsistencies and misinterpretations and misunderstandings that had been promulgated by that group in that piece. My basis for even making such judgments is primarily because I have been for several years the Standards Committee Chairman for the American Association for the Accreditation of Ambulatory Surgery Facilities (AAAASF and also known as the “4A’s”) and a member of the Board of Directors for that organization along with being a surveyor for the Accreditation Association for Ambulatory Health Care (AAAHC) for approximately thirteen years. Additionally, recently I have been asked to be part of a panel that had been collected to evaluate a new product by JCAHO relative to office surgical facility regulation and accreditation. This fall at the annual plastic surgery meeting in Los Angeles, I will be giving a cross walk of the three agencies and showing the similarities and differences among these various programs.
Primarily however, I am concerned about two major misinterpretations. All three major organizations do not automatically meet Medicare standards. Each of them has had to add a section to their standards that is specific to Medicare and all three agencies use the same guidelines. They are, for the most part, word for word, similar for the three accrediting agencies that are deemed Medicare accrediting organizations. Therefore, there is no truth to the statement that we have not met the Medicare requirements in our standards. Additionally, all the agencies that are cited require local, county, state and federal laws and regulations to be met primarily. This is clearly stated in the standards for the 4A’s and obviously in all the others. The main issue is that we say that if there is a more stringent requirement, it must be met before we can even apply the standards of the 4A’s. It is noted quite correctly that the 4A’s is the only agency which requires 100% compliance in order for the facility to be accredited. This distinguishes this organization from all others where partial compliance or percentage ratings are permitted. So, looking at the published comparison chart under “State License, Distinct Entity, Review of Patient Satisfaction, etc.,” all these areas should be noted as “Yes” for the AAASF rather than blanks. We also do mention in our Peer Review that patient satisfaction can be considered one of our quality assurance reviews. We do require professional continuing education because we ask that all CME requirements be met. We also very clearly point out that there should be a pre-procedural evaluation by the physician or the anesthesiologist in charge. The table indicated that our documentation requirements are “weak,” but with our demand for 100% compliance, I can not understand how our documentation requirements could possibly be interpreted in such a way. We, by all means, have the most stringent physical plant requirements of all the agencies and have been criticized by a number of people because of these requirements that are so stringent. In terms of confidentiality, we have issued some time ago a confidentiality statement that must be signed by all the physicians who are doing the on-site reviews. We have one of the strongest quality assurance and peer review programs to date. In fact, ours is the only one on-line as a computerized program that can be reached by all the organizations that are accredited.
The corrective material that was previously sent to the Florida Society of Anesthesiologists is available for review and it was more detailed and replied more specifically to the various issues that have been, apparently, simply copied from them. We have taken the time to outline with specifics, including the documented actual standards numerics, the areas where it is incorrectly cited that we as the AAAASF are “weak.” I sincerely hope that concerned officials and practitioners will take the opportunity to review that more detailed corrective letter. Please consider this letter a follow-up review of that for your readers. Thank you.
James A. Yates, MD
Camp Hill, PA