The letter, dated Feb. 16, 2010, by Victor Moldovan of McGuireWoods, notes that the GSASC is not opposed to the survey, but says that some information requested in not included under the state’s Survey Statute and the DCH is not authorized to request the information.
The disputed requests include the following:
- Part C: Ownership, Operation and Management (CON survey) — The letter states that sections E and F ask for the management contractor and the management contractor’s parent organization. The GSASC argues that this goes beyond information needed for identification purposes and is not covered under the Survey Statute.
- Part D: Ambulatory Surgery Rooms, Procedures and Patients (both surveys)
- Section 1A: The GSASC says the DCH is not authorized to ask for information regarding the number of procedures or the number of patients in the general population, although the Survey Statute does allow the DCH to ask for the number of patients in the indigent population. The letter asks the DCH to allow ASCs to just provide the number of rooms under this section.
- Sections 2-4 — Each of these sections asks for number of patients admitted to the hospital, number of patients by race/ethnicity and number of patients by gender. The GSASC says that the DCH does not have authority to request this information under the Survey Statute.
- Part E: Ambulatory Surgical Procedures, Licensed Specialty and Services (both surveys) — Section 1 requests the top 10 procedures by CPT Code, which the GSASC says is not authorized under the Survey Statute.
- Part F: Utilization & Review by Payer Source for Ambulatory Surgery Services (both surveys) — Section 1 requests utilization by payer source. While the Survey Statute authorizes requests by gross revenue and categories of gross revenue, the DCH is not authorized to request information by payor for the general population
- Part G: Financial Summary and Indigent and Charity Care Information (both surveys) — Section 4 requests a financial table for ASCs. The GSASC does not object to the financial table as a whole, but questions the authority of the DCH to request expense information.
- Part I: Patient Origin of Ambulatory Surgery Patients in the Surgical Center (both surveys) — Section 1 requests a table of patient origin for all ASC patients. The GSASC is asking the DCH to clarify this table, as county of origin is only authorized under the Survey Statue for indigent patients.
For further information or to follow the developments regarding this issue, please contact the GSASC Executive Office 888-526-9450.
Read the full letter by the GSASC to the Georgia DCH (pdf).
