HCFA Clarification Memo:
Double Occupancy Operating Rooms
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Date: March 5, 2001 - DSL-BQA-01-012
To: Ambulatory Surgical Centers ASC 03
From: Otis Woods, Section Chief, Health Services Section
Via: Susan Schroeder, Director, Bureau of Quality Assurance
Attached [below] please find an informational release from HCFA, sent to the Bureau of
Quality Assurance (BQA) as an interpretive memo. BQA is forwarding it to you for your
information.
If you have further questions about double-occupancy operating rooms, you may contact:
DATE: February 6, 2001
FROM: Director, Office of Clinical Standards and Quality
SUBJECT: Double-Occupancy Operating Rooms
TO: Associate Regional Administrator, Division of Health Standards and Quality; Regions
I-X
The purpose of this memorandum is to clarify the Health Care Financing
Administration’s (HCFA’s) policy on the issue of simultaneous surgeries
performed in one operating room.
This issue was brought to our attention by a Medicare-certified Ambulatory Surgical
Center (ASC) seeking approval from HCFA to provide services in this manner. This ASC
defines a double-occupancy operating room as two separate operating rooms within one
physical location. Preparation of the patient before surgery is the same as those
procedures for a single-occupancy operating room. Instruments are not shared. Anesthesia
personnel and the circulation nurse are shared between the two patients.
HCFA explored this issue with the Centers for Disease Control, American College of
Surgeons, and the Association of periOperative Registered Nurses. There was a concurrence
among the groups about concerns related to patient safety, infection control, increased
risk of error, patient privacy, operating room suite size regulations, emergency
scenarios, billing and fraud issues. HCFA must ensure beneficiaries receive the safest,
most effective and current standard of practice in surgical care. Indeed our current
payment rates were established based on single occupancy. Until further research provides
medical evidence of the safety and effectiveness of this practice, HCFA cannot endorse
double-occupancy operating room practice in any healthcare setting.
Please transmit a copy of this memorandum to the State survey agencies in your region.
You may direct any questions to Jacqueline Morgan of my staff at (410) 786-4282.
/s/ Jeffrey L. Kang, MD, MPH
cc: David Eddinger, CMSO
Frank Sokolik, CMSO
Joan Simmons, CMSO
Mike Goldman, CMSO
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