What is Temporal Separation in ASC's?

Ambulatory Surgery Centers (ASCs) are required by the Centers for Medicare & Medicaid Services (CMS) to operate as separate and distinct entities from other healthcare facilities. Temporal separation is a practical alternative to physical separation, allowing ASCs to share spaces with other entities while maintaining compliance with these regulations.

Understanding Temporal Separation

Temporal separation refers to the practice of sharing the same physical space between an ASC and another healthcare facility or practice, but only during separate times. For example, an ASC and a physician’s office might share a waiting room or administrative areas, provided these spaces are never used concurrently by both entities. This arrangement ensures compliance with federal and state regulations that mandate ASCs operate exclusively for surgical services. However, ASCs are never permitted to temporally share space with a hospital.

Why Temporal Separation Matters

The importance of temporal separation stems from several key factors:

1. Regulatory Compliance: Federal regulations, such as those outlined in the State Operations Manual and the CMS Conditions for Coverage, require ASCs to function as distinct entities. Temporal separation ensures adherence to these requirements, particularly when physical separation is not feasible.

2. Patient Safety: Temporally distinct operations help minimize cross-contamination and logistical conflicts, maintaining the integrity of infection control protocols and ensuring a sterile environment during surgical hours.

3. Efficient Use of Resources: Sharing non-clinical spaces like waiting rooms or restrooms can optimize resource utilization, especially for smaller facilities, while still maintaining compliance.

4. Administrative Clarity: Temporal separation delineates operational responsibilities and reduces the risk of overlapping services or mismanagement, ensuring smooth workflow transitions between entities.

Implementing Temporal Separation

For an ASC to successfully implement temporal separation, it must:

• Establish Clear Schedules: Operating hours for the ASC and other entities must be distinctly defined, documented, and adhered to, with no overlap.

• Separate Spaces, Secure Records: During non-ASC hours, patient records and clinical areas must be securely inaccessible to non-ASC personnel. Under certain circumstances, separate ASC's may share both clinical and non-clinical space, but both must have their own policies and procedures, and must maintain separate patient records.

• Comply with Fire Safety Codes: Even with shared spaces, ASCs must meet National Fire Protection Association (NFPA) Life Safety Code requirements. For instance, the spaces that constitute the ASC, must be separated from other facilities by one hour fire separations.

Balancing shared space usage while adhering to these protocols can be challenging. State licensure laws may impose additional requirements, making it essential for ASCs to stay updated on both federal and state regulations.

Temporal separation is a beneficial alternative to physically separating facilities. It can provide efficiencies and reduce the cost of building and operating more space. However, this approach limits the amount of time each facility can perform its independent functions, potentially hampering an increase in case loads for the facilities. For architects and healthcare designers, understanding these requirements is pivotal in creating flexible, compliant designs that balance cost savings with operational efficiency.

Contact us at Hardaway|Sziabowski Architects, if you would like to discuss whether temporal separation is a viable option for your ASC.