The Centers for Medicare and Medicaid Services (CMS) has released a memorandum clarifying the requirements for Ambulatory Surgical Center waiting areas (ASC), including the prohibition on the sharing of waiting areas with other entities. The clarifications include:

• ASC regulations require that these facilities “be distinct entities, solely providing surgical services, and containing separate areas which meet Life Safety Code (LSC) requirements for Ambulatory Health Care occupancies.
• Waivers will be considered for existing ASCs that share a waiting area with other building occupants when compliance with the LSC requirements is not currently feasible. Interim separation barrier and signage is required.
• New ASCs should not be recommended by State Survey Agencies (SAs) or accreditation organizations (AOs) for waiver approval.

Read the memo and pertinent statutory requirements.  Questions concerning the memorandum may be directed to Martin Casey, [email protected].