surgery center ownership

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DYK343

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Any experience with surgery center ownership/buy in? I am considering it as I do a lot of cases that would be surgery center appropriate and reimbursement for foot surgery is pretty low around here.

I have seen surgery centers close and lose major cash. I have seen surgery centers be very profitable.

Anyone have personal experience and advice?

There is a white coat investor podcast about it. I didnt think it was that helpful.

How does one prevent themselves from violating Stark law with ownership of a surgery center and bringing cases there?

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Any experience with surgery center ownership/buy in? I am considering it as I do a lot of cases that would be surgery center appropriate and reimbursement for foot surgery is pretty low around here.

I have seen surgery centers close and lose major cash. I have seen surgery centers be very profitable.

Anyone have personal experience and advice?

There is a white coat investor podcast about it. I didnt think it was that helpful.

How does one prevent themselves from violating Stark law with ownership of a surgery center and bringing cases there?
So I did in-office ASC from scratch. If allowable in your state it is extremely profitable but you have several factors that you need to consider that I'll rattle off in no particular order:

1. What scope of cases do you wish to start out with? The cost/investment for minor (dermal/epidermal) vs major surgery (osseous) has to be determined. You need to pull out your CPT book and see what codes are ASC allowable and commit to doing them there.

2. Are you comfortable doing cases under local? I did no cases in residency under straight local and it was a disservice. There is so much of podiatry that can be done under local and skip all the hospital/surg center paperwork as a result. In-office ASC under local means no PCP workup/bloodwork/CXR/EKG.

3. Hiring will require an RN to circulate. Look into hourly rates and will need 2-3 nurses you can pool from so you can call in an instance and "book a case." This is great when you can use the OR at your disposal.

4. Start-up money is so variable as you can get basic stuff or pay for the premium stuff.

5. What instrumentation will you need to get the job done? I think a used c-arm is invaluable for instance. You can even use it on non-OR days to do stress x-rays if you see any trauma or want to do fluoro-guided injections. Are you comfortable sourcing things off ebay because whats wrong with a used dull senn retractor?

6. This will need to be a new entity and you will have to post disclosures that you own the surgery center. Stark laws for this are not as much of a concern.

7. Reimbursement: you can get an idea what a case reimburses off CMS. Typically $1200 for a bunion is common, then add your physician reimbursement and you're just under $2k to be in your office. You have complete control of the entire operation and no hospital administrator breathing down your neck or wait to get into the room because the ex-lap before you is "going longer than anticipated."
 
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I hope this turns into a great thread as I will also be looking into an ASC within a year or so with ortho and some others.

Totally agree with how many things we can do under local only. I now do a lot and am always pushing.

I would argue there are nealry zero cases that can't be done at an ASC unless you are using expensive hardware that you want the hospital to eat.
 
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Any experience with surgery center ownership/buy in? I am considering it as I do a lot of cases that would be surgery center appropriate and reimbursement for foot surgery is pretty low around here.

I have seen surgery centers close and lose major cash. I have seen surgery centers be very profitable.

Anyone have personal experience and advice?

There is a white coat investor podcast about it. I didnt think it was that helpful.

How does one prevent themselves from violating Stark law with ownership of a surgery center and bringing cases there?
How can you do cases at an ASC if you are hospital employed? I would love to go other hospitals and/or ASCs to do cases but then I wouldn't get the RVUs for the work because the hospital wants it facility fee.
 
How can you do cases at an ASC if you are hospital employed? I would love to go other hospitals and/or ASCs to do cases but then I wouldn't get the RVUs for the work because the hospital wants it facility fee.
MSG employed without a surgery center in the MSG group.
 
So I did in-office ASC from scratch. If allowable in your state it is extremely profitable but you have several factors that you need to consider that I'll rattle off in no particular order:

1. What scope of cases do you wish to start out with? The cost/investment for minor (dermal/epidermal) vs major surgery (osseous) has to be determined. You need to pull out your CPT book and see what codes are ASC allowable and commit to doing them there.

2. Are you comfortable doing cases under local? I did no cases in residency under straight local and it was a disservice. There is so much of podiatry that can be done under local and skip all the hospital/surg center paperwork as a result. In-office ASC under local means no PCP workup/bloodwork/CXR/EKG.

3. Hiring will require an RN to circulate. Look into hourly rates and will need 2-3 nurses you can pool from so you can call in an instance and "book a case." This is great when you can use the OR at your disposal.

4. Start-up money is so variable as you can get basic stuff or pay for the premium stuff.

5. What instrumentation will you need to get the job done? I think a used c-arm is invaluable for instance. You can even use it on non-OR days to do stress x-rays if you see any trauma or want to do fluoro-guided injections. Are you comfortable sourcing things off ebay because whats wrong with a used dull senn retractor?

6. This will need to be a new entity and you will have to post disclosures that you own the surgery center. Stark laws for this are not as much of a concern.

7. Reimbursement: you can get an idea what a case reimburses off CMS. Typically $1200 for a bunion is common, then add your physician reimbursement and you're just under $2k to be in your office. You have complete control of the entire operation and no hospital administrator breathing down your neck or wait to get into the room because the ex-lap before you is "going longer than anticipated."
Great post. Appreciate your insight.

I cant do in office ASC because I am an associate of a MSG group. There are only a few surgeons in the MSG and we do not have a surgery center. I am free to take my cases anywhere I like. If I did have an in office ASC I would not collect as much $ because I would not have ownership.

I have done Austin bunions under local. I commonly do 5th toe arthroplasty procedures under local (hospital gets mad at me when I schedule those).

2k for an Austin sounds amazing. Im pulling in about $500-600 around here pretax. If I do an Akin its more but still the reimbursement is low IMO especially with a 90 day global and lost time sitting in the surgeon lounge waiting for the next case to start.

Do you find your in office ASC is profitable given the start up costs and maintenance costs/staff salary?
 
Stark laws dictate that a patient must know (usually by signing a form) that you own shares of the ASC. Your income from the ASC can NOT be based on your case volume but is based on your % ownership of the total income.

Most ASCs get killed by expensive hardware sets and usually don’t allow systems such as the Lapiplasty system due to cost. They rarely allow any bone or soft tissue enhancement products due to cost.

Everyone needs to get prepared for the new “norm”. Insurers are going to only allow many elective cases if they are done is ASCs due to cost savings.

So you must be proficient in using the basics and not all the new fangled and costly sets.

I am offered hired as a liaison by the insurance companies when a doctor is required to do a case at an ASC but the ASC won’t allow the doctor to use a specific set.

This is happening more and more with the Lapiplasty set. Many docs are only comfortable performing a Lapidus with the set and not free hand. I am well aware of the “3D” correction and there are now competitors in that space.

But try to convince an insurance exec or supply person at the ASC that the Lapiplasty set is unique for it’s reproducibility and 3D correction.

All they care about is the bottom line.

Want to use implants for a digital arthrodesis at 2 grand a pop? If you do your ASC will go out of business.

You may have to learn how to say and spell K wire!!
 
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Thanks for Stark law clarification. I dont do lapiplasty. I did enough lapidus in residency I dont really need it. But I do use an interfrag screw w plate over cross screws for fixation which adds to cost. I am aware of the restrictions at surgery centers but it seems some are more leniant on hardware than others which is likely contracts they have with the hardware companies. I have heard that we are going to be more or less forced into surgery centers in the near future which will be interesting. That also may mean it would be a good time to consider opening one up and have it up and running when that time comes.

I dont implants for hammertoes. I have seen zero benefit over K wire minus select instances.

Edit: So a percentage ownership you pay yourself but still get the physician reimbursement fees? Correct?
 
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Why do surgery centers fail other than obvious overspending on hardware, too many staff, too few surgeons bringing cases?

I've seen ASCs close their doors and others appear to be a cash cow.
 
I am offered hired as a liaison by the insurance companies when a doctor is required to do a case at an ASC but the ASC won’t allow the doctor to use a specific set.
Also not to side rail but how did you get into this line of work with the insurance companies? I am going to assume once you start small more and more insurance consults come about
 
Your income from the ASC can NOT be based on your case volume but is based on your % ownership of the total income.

This is correct ... I own for example 5 shares at a sx center that i frequent ... i get a dividend based on those shares .... i believe the least headache from the avenues i have explored is to be a shareholder at a place that you frequent if they allow it or go somewhere that allows it ... Ill give a real life example after all the BS is worked through, you buy ONE share for 15k and you get a MONTHLY dividend of about 2-3k per share ... you "slow" down in terms of your case volume you can get bought out and you get your 15k back

This is what makes innetwork surgery tolerable... but i have cut down bigtime on innetwork sx and focusing more on out of net sx .. i will never do a bunion for 1k or a flatfoot for 1.5 k ( what a disaster, i got this for an evans, cotton and TAL once ) again... some insurance companies pay 500 for othrotics and 800$ for an AFO ...its insane

as an FYI you get about 30 percent more when you do a case in your office

Also the quicker and the least expensive the case is the more love you get from the sx center


So a percentage ownership you pay yourself but still get the physician reimbursement fees? Correct?

Correct

Why do surgery centers fail other than obvious overspending on hardware, too many staff, too few surgeons bringing cases?

I've seen ASCs close their doors and others appear to be a cash cow.
I think you know the answer already to that ... its one thing to run a successful PP its a whole other level to run a successful ASC... the path of least headache and resistance for me was to augment what im doing already with another stream of income by getting shares into a sx center ... hopefully that can be an option for you in your area
 
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Do you find your in office ASC is profitable given the start up costs and maintenance costs/staff salary?
Yes. And for exactly what was mentioned above. I know better than to let the "simple stuff" not be booked as an ASC case. 14040 for a simple lobe flap closure when you excise a lesion is a great ASC case. A bunion with one or even two screws is not gonna set you back too much. Your goal is to burn the least amount of supplies in a case also while maximizing labor. There is creativity like sterilizing supplies you use on the regular unsterile gauze and cling in one pack for instance.

My advice is to just start paying attention to what is used in a case from start to finish and how you can be more efficient. Just because the hospital lets you throw away a tourniquet after every case is not a reason to do so in your ASC.
 
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Why do surgery centers fail other than obvious overspending on hardware, too many staff, too few surgeons bringing cases?

most surgery centers aren’t going under because they spend too much on hardware. They typically won’t let docs use hardware that loses money unless that doc has already brought a dozen profitable cases and they believe will continue to do so. Hardware limitations could indirectly cause some surgeons not to bring cases (which could close a place down) but from what I’ve seen it really boils down to surgeon and case mix. No hand? No cash plastics cases? Only one day of scopes (mouth and but, not ortho)? Don’t have a few pain docs on board yet? You won’t survive.
 
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I have heard that we are going to be more or less forced into surgery centers in the near future which will be interesting.
I understand this thought and in theory it seems like it’s what “should” happen. Increase outpatient care. It’s cheaper and more efficient. You think, “of course insurance companies and the gov want to save themselves money.”

So then why have hospital campuses/facilities and large health networks only continued to grow? Why are “surgical hospitals” ( ie ASCs with an attached ED that never gets used so they can bill and get reimbursed at hospital rates instead of true ASC rates) becoming more popular? Why are hospital “campuses” growing and starting to include ASCs that the hospital has bought? And while these more expensive facilities are growing, true stand alone ASCs continue to fail or get purchased by growing health systems.

I’m not sure where the idea of everything being pushed to ASCs, which I’ve also heard before, comes from. I’m missing something. Is it because they think once the gov has near-total control over healthcare delivery that THEN they’ll care about cost or efficiency? Are they seeing some increase in reimbursements for true outpatient facilities/procedures? Are “Off campus” (another hospital trick that gets higher reimbursements and facility fees) Outpatient facilities are becoming more popular in their area while the hospital campuses shrink? Ive only ever really seen the opposite so I’d be curious to hear the reasoning from someone who knows what I’m missing.

Or maybe people are thinking of these hospital owned outpatient centers where larger facility fees can be billed and calling them ASCs ? They aren’t true ASCs. I mean I could see that, but it would be a move away from ASCs. Everything becomes hospital owned, “on campus”, has an unstaffed ED, etc. all in the name of increased facility fees/reimbursements.
 
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... I dont do lapiplasty. I did enough lapidus in residency I dont really need it. But I do use an interfrag screw w plate over cross screws for fixation which adds to cost..
Amen. I thought Lapiplasty and the phantom nail were the most ridiculous things ever. We tend to make things that are so basic and simple way too complex... and also butcher other areas of innocent soft tissues in the process. It is not an easy procedure, but if you can't do a Lapidus with pins and screws and c-arm, there is no business doing it some fancy way. What are you going to do if the jig/implant fails?

FWIW, I do (steel) lock plates over one lag screw on the vast majority of mine since I want it to definitely withstand early WB as well as to hold up to a fall or noncompliance, but it has been done successfully a million times with 2-3 screws also. Technique over technology should be the rule for any procedure.

...so yeah, if you buy SC shares, use basic solid frag screws for Austins, buried k-wires for hammertoes, common sense stuff, etc etc. I would never compromise on the plate for Lapidus, but you might be able to find a less costly plate? As was said, pick a busy place that you honestly believe in, take cases there awhile before buying in if you want, and then collect the divis.

...This is happening more and more with the Lapiplasty set. Many docs are only comfortable performing a Lapidus with the set and not free hand. I am well aware of the “3D” correction and there are now competitors in that space...
Hmmm, we should make fellowships for this? Fellowships are usually the powe die a tree answer :unsure:
 
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I went to finish off season 5 of peaky blinders and came back to a great thread. Glad I started it. All very insightful. Thanks everyone.

BTW its a decent series. 8/10.
 
Amen. I thought Lapiplasty and the phantom nail were the most ridiculous things ever. We tend to make things that are so basic and simple way too complex... and also butcher other areas of innocent soft tissues in the process. It is not an easy procedure, but if you can't do a Lapidus with pins and screws and c-arm, there is no business doing it some fancy way. What are you going to do if the jig/implant fails?

FWIW, I do (steel) lock plates over one lag screw on the vast majority of mine since I want it to definitely withstand early WB as well as to hold up to a fall or noncompliance, but it has been done successfully a million times with 2-3 screws also. Technique over technology should be the rule for any procedure.

...so yeah, if you buy SC shares, use basic solid frag screws for Austins, buried k-wires for hammertoes, common sense stuff, etc etc. I would never compromise on the plate for Lapidus, but you might be able to find a less costly plate? As was said, pick a busy place that you honestly believe in, take cases there awhile before buying in if you want, and then collect the divis.


Hmmm, we should make fellowships for this? Fellowships are usually the powe die a tree answer :unsure:
Love it.

Lapiplasty looks way more complicated than it needs to be. But then again about 1 in 5 free cut lapidus give me trouble and I have to feather it until I'm satisfied which can get tricky (that damn plantar lateral corner!). Most of them are 45min but every now and then they are 1.5hr try and try again procedures for me. I still dont weightbear mine but I know most of them walk anyways. I think the lag screw/plate is probably sufficient to weightbear on but Im still not on board with verbilizing OK to ambulate (yet).
 
This is correct ... I own for example 5 shares at a sx center that i frequent ... i get a dividend based on those shares .... i believe the least headache from the avenues i have explored is to be a shareholder at a place that you frequent if they allow it or go somewhere that allows it ... Ill give a real life example after all the BS is worked through, you buy ONE share for 15k and you get a MONTHLY dividend of about 2-3k per share ... you "slow" down in terms of your case volume you can get bought out and you get your 15k back

This is what makes innetwork surgery tolerable... but i have cut down bigtime on innetwork sx and focusing more on out of net sx .. i will never do a bunion for 1k or a flatfoot for 1.5 k ( what a disaster, i got this for an evans, cotton and TAL once ) again... some insurance companies pay 500 for othrotics and 800$ for an AFO ...its insane

as an FYI you get about 30 percent more when you do a case in your office

Also the quicker and the least expensive the case is the more love you get from the sx center




Correct


I think you know the answer already to that ... its one thing to run a successful PP its a whole other level to run a successful ASC... the path of least headache and resistance for me was to augment what im doing already with another stream of income by getting shares into a sx center ... hopefully that can be an option for you in your area
Thats a great return on investment. 15k to make 2-3k/month. Robbery. Maybe I should practice in NY!

After taxes I'm making about $350-400 for a simple bunion right now. I can get an Austin done in 20-30min OR time but its still a huge liability (plus see my turnover times so its not actually that great). Its just not worth it. All that whinning and complaining. Ass kissing. People pleasing. ER calls that night due to patient there in pain, 90 day global, etc, etc

I just had one get infected (first post op osteo I've had - very humbling) and it was a nightmare and continues to keep me up at night all for $350-400.
 
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I understand this thought and in theory it seems like it’s what “should” happen. Increase outpatient care. It’s cheaper and more efficient. You think, “of course insurance companies and the gov want to save themselves money.”

So then why have hospital campuses/facilities and large health networks only continued to grow? Why are “surgical hospitals” ( ie ASCs with an attached ED that never gets used so they can bill and get reimbursed at hospital rates instead of true ASC rates) becoming more popular? Why are hospital “campuses” growing and starting to include ASCs that the hospital has bought? And while these more expensive facilities are growing, true stand alone ASCs continue to fail or get purchased by growing health systems.

I’m not sure where the idea of everything being pushed to ASCs, which I’ve also heard before, comes from. I’m missing something. Is it because they think once the gov has near-total control over healthcare delivery that THEN they’ll care about cost or efficiency? Are they seeing some increase in reimbursements for true outpatient facilities/procedures? Are “Off campus” (another hospital trick that gets higher reimbursements and facility fees) Outpatient facilities are becoming more popular in their area while the hospital campuses shrink? Ive only ever really seen the opposite so I’d be curious to hear the reasoning from someone who knows what I’m missing.

Or maybe people are thinking of these hospital owned outpatient centers where larger facility fees can be billed and calling them ASCs ? They aren’t true ASCs. I mean I could see that, but it would be a move away from ASCs. Everything becomes hospital owned, “on campus”, has an unstaffed ED, etc. all in the name of increased facility fees/reimbursements.
If there is one thing I know government (medicare/medicaide) is slow to respond but they eventually catch on and things will change. Other insurances will follow as they always follow medicare rules. What tricks work now may not work in 10-15 years.
 
Any success with pooling every DPM in town and starting a surgery center together? Too many hands in the pot equals trouble?
 
This is correct ... I own for example 5 shares at a sx center that i frequent ... i get a dividend based on those shares .... i believe the least headache from the avenues i have explored is to be a shareholder at a place that you frequent if they allow it or go somewhere that allows it ... Ill give a real life example after all the BS is worked through, you buy ONE share for 15k and you get a MONTHLY dividend of about 2-3k per share ... you "slow" down in terms of your case volume you can get bought out and you get your 15k back

This is what makes innetwork surgery tolerable... but i have cut down bigtime on innetwork sx and focusing more on out of net sx .. i will never do a bunion for 1k or a flatfoot for 1.5 k ( what a disaster, i got this for an evans, cotton and TAL once ) again... some insurance companies pay 500 for othrotics and 800$ for an AFO ...its insane

as an FYI you get about 30 percent more when you do a case in your office

Also the quicker and the least expensive the case is the more love you get from the sx center




Correct


I think you know the answer already to that ... its one thing to run a successful PP its a whole other level to run a successful ASC... the path of least headache and resistance for me was to augment what im doing already with another stream of income by getting shares into a sx center ... hopefully that can be an option for you in your area
Sorry, but taking to out of network ASC is a d*** move.
 
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After taxes I'm making about $350-400 for a simple bunion right now. I can get an Austin done in 20-30min OR time but its still a huge liability (plus see my turnover times so its not actually that great). Its just not worth it. All that whinning and complaining. Ass kissing. People pleasing. ER calls that night due to patient there in pain, 90 day global, etc, etc

I just had one get infected (first post op osteo I've had - very humbling) and it was a nightmare and continues to keep me up at night all for $350-
This should be a post it!! ... i appreciate you showing and being honest about the side of surgery that isnt talked about often... this is def the case but it all comes with the territory, what i have seen is that if you are at least getting compensated well for the complexity and risk of what you do then it makes you feel better about all of it at least .... in the last 20 years there has def been a systematic attack on procedures in general which is BS!
 
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in the last 20 years there has def been a systematic attack on procedures in general which is BS!
This is why you have to adapt to the game. It's very simple! Surgery costs insurances a lot of money. So have to force higher deductibles to patients and lower reimbursements to physicians.

If and when socialized medicine (government payor) models strengthen, you'll be already tuned to dealing with slapping in a buried k-wire and reducing OR cost.

In addition, I think a great pivot is all the stuff you may do in your office that should be done in an in-office ASC. 11043/11044 is an ASC reimbursable code when in fact the payors actually want that as the place of service! I am not saying to do these every week in your ASC, but you have to put on your thinking cap and find ways to "build surgical volume" without thinking surgeries are just HT and bunions.

In walks JCAHO.
And forget JCAHO.... when you set up an ASC you're not gonna use them if you dont have to. Look at AAASF https://www.aaaasf.org/docs/default...anual-and-checklist-v14-5-(obs).pdf?sfvrsn=20 or the one most DPMs use, AAPSF Accreditation Association for Podaitric Surgical Facilities: AAPSF Standards.
 
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n fact the payors actually want that as the place of service! I am not saying to do these every week in your ASC, but you have to put on your thinking cap and find ways to "build surgical volume" without thinking surgeries are just HT and bunions.

there you go thats what im talking about .... high ticket items ( quick, low risk, and pays well relative to the previous criteria)
 
Surgery centers LOVE pain management and ophthalmologists.

I used to be “the man” at a local surgery center. Lots of cases each week and I did surgery on most of the nurses and anesthesia staff.

Then pain management showed up. As quick as I am in the OR, (I was in and out of the room for a bunionectomy in well under 30 min) with similar quick times for all cases.

But I used a tourniquet. And I needed a fair amount if instruments. And I needed hardware. And I needed sutures. And I needed Adaptic and sterile dressings. And I sometimes needed casting material. Blah blah blah.

And pain management needs a friggin syringe and C arm. So I’m in there doing 3-5 cases and they book two rooms and bounce across the hall all day long and do 30 cases a day at very little expense to the ASC.

A syringe and band aid is the total cost of the case.
 
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I have more to say, but I want to lead with a joke.

Did a brachymetatarsia case with callus distraction. Orthofix monorail. 4 pins. Met cut, pin in the toe etc.

Me: How much do you think we were paid for this case?
My nurse: $10,000?
Me: (after I stopped laughing) $600.
My nurse: Really? But you've been seeing her like weekly for 2-3 months!?
 
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I have more to say, but I want to lead with a joke.

Did a brachymetatarsia case with callus distraction. Orthofix monorail. 4 pins. Met cut, pin in the toe etc.

Me: How much do you think we were paid for this case?
My nurse: $10,000?
Me: (after I stopped laughing) $600.
My nurse: Really? But you've been seeing her like weekly for 2-3 months!?
$600.... it's not thaaaaat bad, that case pays TAR reimbursement money:rofl:.... 20690 + 28308 is $900-1200 through most payers. Its a 30 minute case and follow-ups at least pay for XR during the global.
 
So I did in-office ASC from scratch. If allowable in your state it is extremely profitable but you have several factors that you need to consider that I'll rattle off in no particular order:

1. What scope of cases do you wish to start out with? The cost/investment for minor (dermal/epidermal) vs major surgery (osseous) has to be determined. You need to pull out your CPT book and see what codes are ASC allowable and commit to doing them there.

2. Are you comfortable doing cases under local? I did no cases in residency under straight local and it was a disservice. There is so much of podiatry that can be done under local and skip all the hospital/surg center paperwork as a result. In-office ASC under local means no PCP workup/bloodwork/CXR/EKG.

3. Hiring will require an RN to circulate. Look into hourly rates and will need 2-3 nurses you can pool from so you can call in an instance and "book a case." This is great when you can use the OR at your disposal.

4. Start-up money is so variable as you can get basic stuff or pay for the premium stuff.

5. What instrumentation will you need to get the job done? I think a used c-arm is invaluable for instance. You can even use it on non-OR days to do stress x-rays if you see any trauma or want to do fluoro-guided injections. Are you comfortable sourcing things off ebay because whats wrong with a used dull senn retractor?

6. This will need to be a new entity and you will have to post disclosures that you own the surgery center. Stark laws for this are not as much of a concern.

7. Reimbursement: you can get an idea what a case reimburses off CMS. Typically $1200 for a bunion is common, then add your physician reimbursement and you're just under $2k to be in your office. You have complete control of the entire operation and no hospital administrator breathing down your neck or wait to get into the room because the ex-lap before you is "going longer than anticipated."
Sorry to necro this thread but I was looking at my states wording (California) and a few others for in office asc and it seemed like to qualify the patient still needs to be under deep or moderate sedation. I would assume local wouldn’t count for that?
 
Sorry to necro this thread but I was looking at my states wording (California) and a few others for in office asc and it seemed like to qualify the patient still needs to be under deep or moderate sedation. I would assume local wouldn’t count for that?
Here are CA guidelines. You just cant put someone at risk doing a surgery in a setting not adequate to handle complications of that procedure. (prolly after joan rivers died)

 
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