Further Clarification on CMS Waiving Separate Waiting Room Requirement for ASCs

The following question pertains to the recent news: "CMS Waives Separate Waiting Room Requirement for ASCs Meeting New Criteria." The answer was provided by Dawn Q. McLane, RN, MSA, CASC, CNOR, chief development officer of Nikitis Resource Group, an ASC development and management firm.

Q: What if the waiting area is located near the patient care areas, although a distinct room, within the firewalls? And can the sign in desk be in the common area? What if the families or friends that come with the patient's do not want to wait in the designated waiting room? What if they want to wait in the common area? Are we supposed to enforce the rule, and to what extent?

Dawn Q. McLane: A copy of the CMS letter in regard to the issue of a separate waiting room for ASCs can be found by clicking here (pdf). Within the text of the letter CMS describes what is required if the Center is not compliant, applies for and is granted a waiver:

"While operating under an approved waiver, the ASC must assure that fire protection for the waiting area is appropriate for the occupancy to which it was designed. In addition, in order for the ASC to be a distinct entity, the ASC's patients and visitors using the waiting area must be separated from other occupants in a shared waiting area by a temporary partition, unless the ASC is "temporally" distinct from the other occupancy. The partition must not block or obstruct visibility of exits, shall be flame resistant in accordance with NFPA 701, and must be located at least 18 inches below sprinkler deflectors in accordance with NFPA 13. In addition, signage must be posted that clearly identifies the distinct separate ASC waiting area."

To my knowledge there is nothing in the Medicare LSC that directly addresses a requirement that the registration area be distinct and located within the firewall of the ASC. I do not know if any state or local building codes would affect this particular decision. The requirement is for the center to provide the waiting area in the manner required. There is no requirement to mandate that visitors/families remain in that space while they are waiting. They may wait there, step outside or even leave the campus, depending upon the rules the center has for the adult who is accompanying the patient to the ASC.

Learn more about Nikitis Resource Group.

Read more insight from Dawn McLane:

- 3 Critical De Novo ASC Mistakes

- Due Diligence, Expert Guidance Required for De Novo ASCs

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Factors Contributing to De Novo ASC Decline

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