Developing a cardiovascular ambulatory surgery center can be a shrewd way for health systems to retain and build market share amidst increased demand for CV outpatient procedures.

But is a CV ASC a smart strategy for your health system? Even if your answer is a resounding ‘yes!’ you must consider many variables as you plot your course. If this project feels a little overwhelming, take heart. Here’s help.

Here are seven questions to jumpstart your analysis and set you on the path towards the CV ASC strategy that is best for your health system.

What are your health system’s goals for a potential CV ASC?

Determine whether your strategy is defensive or offensive. Assess what you want to accomplish by adding a CV ASC to your health system. Do you want to:

• Capture more market share by expanding your health system’s overall ASC footprint?
• Ensure that your health system offers ambulatory CV procedures, which are becoming the standard of care?
• Strengthen your health system’s physician recruitment and alignment efforts?
• Retain employed CV physicians by offering them ASC partnership opportunities?
• Add CV services you don’t currently offer?
• Free up your HOPD cath lab’s bandwidth by moving lower-acuity CV procedures to an ASC?

What do your health system’s revenue plans look like?

Some health systems are wary about going ‘all in’ on a CV ASC strategy because they worry their hospital outpatient department will lose significant revenue in the short term. While case migration could change revenue flows, it also creates robust opportunities to optimize, which we describe in more detail below.

Are your existing cath labs at capacity or near capacity?

A hospital cath lab that is at or near capacity is a good problem to have.

Your caseload and revenue could benefit from decanting lower acuity cardiovascular cases away from the hospital and into a CV ASC. This move creates bandwidth for additional higher acuity cases in your hospital and infuses your fledgling CV ASC with a robust caseload and revenue stream.

What is your health system’s CPT® and ICD-10 data telling you about future case migration?

Generally, you can expect more cardiovascular procedures to move to ASCs, not just for commercially insured patients, but for Medicare beneficiaries as well.

CMS continues to comb through inpatient-only procedure lists looking for technological advancements that make them safe and optimal ambulatory outpatient procedures for many patients. Peripheral vascular procedures were the first CV codes to move to the ASC-covered procedure list (CPL), followed by device implants and diagnostic cardiac catheterizations. In 2020, the agency added low-risk percutaneous coronary intervention (PCI) to the list.

We expect EP ablations, left atrial appendage occlusion (LAAO), transcatheter aortic valve replacement (TAVR) and abdominal aortic aneurism (AAA) repair to join the ASC CPL over the next few years. As CV ASC settings become the standard of care, private payer policies will see similar changes. Often, private payers blaze the CV ASC trail. At the very least, payers tend to follow Medicare's lead.

To forecast what case migration might look like in your health system’s market, compare CV CPT® codes performed in your hospital currently to the codes that have recently moved or are expected to move to the ASC CPL.

Generally, about 50 percent of outpatient CV patients are candidates for CV ASC procedures. This percentage varies depending on the overall health of patients in your market. ICD-10 data can provide the comorbidity insight you need to forecast how many patients in your market are potential candidates for CV ASC procedures.

Where are the cardiovascular physicians in your market performing outpatient procedures now?

Take stock of the physicians currently doing outpatient procedures in your market. Are they aligned with your health system’s HOPD currently? Are they doing procedures in CV ASCs or office-based labs (OBLs) where they have ownership and incentives? How many might your health system expect to retain or recruit with a CV ASC?

Will you need to play the ASC CON game?

Assessing your state’s regulatory environment is crucial, because it’s easier to develop CV ASCs in some states than it is in others. Some states have no certificate of need requirements or health plan legislation restricting CV ASC development. In states with more stringent regulations, CV ASC development is more difficult, but also creates more opportunities for market capture with CON achievement

Change is happening in some states with CON restrictions. Last year, for example, legislators in South Carolina finally agreed to sunset CONs for ASCs that meet certain licensing requirements the new legislation outlines. Other states, such as Montana and North Carolina, have passed legislation to revise CON requirements and encourage ASC development. But the wheels of bureaucracy turn far more slowly than the pace of advancements in cardiovascular medicine, which means that regulations unnecessarily restrict facility development that would benefit CV patients in their states.

If you are thinking, “Our health system shouldn’t even bother with a CV ASC because our state’s CON is draconian,” think again. If you choose a partner with experience navigating ASC regulatory environments, it is possible to develop a CV ASC even in a state with tough restrictions. Compass Surgical Partners has never failed to secure a CON for an application it has filed.  

Recently in Virginia, our team secured the COPNs (‘Certificate of Public Need’) necessary for two new CV ASCs. Even though legislators and regulators in Virgina haven’t kept pace with medical advancements generally, we were able to secure the COPNs ahead of broader, statewide revisions. Now that Compass has successfully navigated the COPN approval requirements, we will develop the state’s first CV ASC in a growing metropolitan market in Virginia. By doing so, we have enabled the partnership to align with physicians who intend to utilize the facility long-term as they begin to out-migrate cases currently performed in hospital cath labs.  

Key Takeaway: Navigating tough CON requirements is achievable. Data is a bedrock for persuading regulators to think progressively about what’s best for CV patients in their state.

How does your outpatient CV plan dovetail with your health system’s real estate portfolio?

Your health system should conduct a feasibility study to determine whether your CV ASC will work best as an HOPD conversion or a de novo ASC.

If you have dead space on your hospital campus that is not being used optimally, locating the ASC on campus could be a good strategy. In most cases, it is not difficult to retrofit that space to create a state-of-the-art CV ASC.

A de novo ASC can be a good strategy if your hospital campus space is limited, or if you want to seize the opportunity to grow your health system’s outpatient footprint in your market by choosing a location that is convenient for CV patients.

As a full-service ASC development partner, we have the skills and experience necessary to empower our health system partners to capture and grow real estate value as part of their CV ASC investment.

You have the data and the goals. We have ASC experience and expertise to execute your CV ASC strategy.

Overall, the Compass Surgical Partners team has developed and managed more than 250 ASCs. If you would like to tap into our ASC experience and expertise, contact us and let’s have a conversation.