I've worked in consulting for over thirty years and worked with over 350 ASC's in that time frame. I've been involved (on average) in about 30 surveys per year. That's probably more than most people in this country! You would think that anyone with this much experience would have 100% confidence of passing any survey. The fact is I NEVER feel that in any survey! Something is wrong with that.
I've spent an entire career perfecting efficiencies for survey compliance, without being able to effect any change related to the survey process we are required to accept.
The compliance system the government has set up for us isn't working. It almost feels like a dictator controlled system. The problem is that those dictators don't have the clinical experience/knowledge or critical thinking skills to assess our surgery centers for compliance. Most surveyors don't have ANY surgical services experience. They've never circulated a case, or run the autoclave, or even written a policy, yet they judge our compliance. What other industry works like this? Would a bridge be judged ready for traffic without the confirmation of an engineer that knows everything about those bridges? It's not about just knowing the written standard, it's the knowledge base of how to implement those standards into our everyday practices.
I've come to the conclusion it's because we let the surveyors dictate how we manage our centers. Based on my experience, ASC RNs' clinical directors have so much more knowledge than most surveyors, yet we are afraid to speak up with support of our decisions. We rarely argue our positions/actions with surveyors when they disagree with us. We don't want to "rock the boat", so we usually take the hit and change the practice, even if we didn't agree with the surveyor's recommended change.
We have to become more informed and practice proactively to meet compliance standards. I believe the clinical director position holds the key to change in our industry. If we keep waiting for the surveyors to guide us (most without ANY operating room or surgical experience) than we can expect to , never feel confident about our survey outcomes.
I retired from consulting in January and will be the clinical director for a new surgery center in Hilo, Hawaii (Hawaii Vision Surgical Suites). It's been over 30 years since I've been able to focus solely on ongoing compliance of a single ASC. My plan is to perfect compliance at this level which will make it difficult for surveyors to question my process. It's time the experienced RN's get involved in making needed changes. We are the ones with the knowledge.