THis is a policy proposal- The Certificate of Need (CON) office or (Health Planning division of the Mississippi Health Department has recently taken the position that to qualify as a single-specialty Ambulatory Surgical Center (ASC), and therefore not need a CON to operate) an ASC can share space with other single- specialty ASCs but only if the other ASCs are performing the same specialty. For example, a urology group can lease space to perform ASC services, but only if the lessor group is also a urology-pnly practice. I need a memo explaining why this is not consistent with legal requirements and not practical. And if this is the requirement- if separate and distinct provider groups share space( urology and orthopedic group for example) ?-which group is responsible for getting the CON? Organize the paper this way. Talk about how Mississippi defines single and multispecialty ASCs. Then talk about how federal law defines single and multispecialty ASCs. Are there any similarities? differences? Focus on the language that refers to the entities as separate and distinct. Identify and find any commentary in the federal register and OIG opinions that support the argument that single specialty providers that share space should be considered single specialty ASCs even though those different single specialty providers perform different surgical procedures. Find the policy reasons that lead to federal government defining single specialty and multispecialty ASCs. Use those policy reasons to make argument. One argument to address, from a practical standpoint, is if you are requiring for example, ″urology-only″ providers to share space in order to operate an ASC and meet the single specialty requirement, then you are requiring competitors to join together in order to avoid having to go through the process of purchasing a CON. And it′s an impractical way of approaching this because as competitors you′re not gonna create a way for your competitors to make money..Because the vast majority of time a singular provider practice won′t have enough patient volume to have their own facility...Therefore, in order to avoid the impractical position of forcing, for example, every urology provider who lease space to share space with other urology providers, their competitiors, those providers should be allowed to share space with providers of different medical specialties without being having to require a CON to meet the governing multi-specialty requirements. Also, Explore how they came to the conclusion on the safe harbors- Ultimately, I want to show that single specialty, if they are ″separate and distinct″ from other groups that share space; that does not make them a multi-specialty ASC. As a suggestion- to reinnforce a broad approach to organization for the argument- It should in essence take the approach of these are the regulations- you are implementing this regulation in a way that doesn′t make sense from a regulatory standpoint and it doesn′t make sense in practice. This is why... A good place to start the the research might be- going to the regulations (state and federal regulations for ambulatory surgical/surgery centers (state and federal might term it differently) go to the Federal Register which have citations at the bottom of the register..might be quickest way if there aren′t many citations.. Another way may be to go to the Federal register under the Westlaw tab and include the citation itself to the regulations part of your search...you might be able to narrow it down to get to the single specialty vs. multi- specialty discussions and just see what they say..I would imagine there are multiple references to these throughout the regulations.. also look at the commentary in the CFR However, the research does not have to be-and probably won′t be- limited to these resources. - single space and 12 point font - Include any source material to support that ultimate argument. - Also address any material that might be contrary to this position....
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