ECT meets the general standards for ASC settings in that it does not pose a significant safety risk to Medicare beneficiaries when performed in an ASC, and the beneficiary would not typically be expected to require active medical monitoring and care at midnight following the procedure. [...] In 2019, CMS expanded the eligibility criteria for ASC CPL consideration to include services that are a direct “crosswalk or are clinically similar to procedures in the Category I CPT code surgical range.” While not defined as a surgical procedure (CPT codes 10000 - 69999), ECT is “clinically similar”1 to other procedures routinely performed in an ASC such as colonoscopies and upper endosc [...] The patient flow and sequence of clinical activities that are involved in administering outpatient ECT are very similar to those associated with other brief procedures that are performed in an ASC. [...] The nursing staff prepare the patient, including inserting an intravenous catheter for administering fluids and anesthetic medications. A pre-procedural “time-out” is conducted and monitoring electrodes are placed to assess vital signs, cardiac rhythm, and oxygenation status, as is typical for procedures that require general anesthesia. [...] While the patient is in the recovery area, the psychiatrist remains in the building and immediately available to address any issues that may arise. These most often relate to symptomatic treatment for agitation, nausea, or headache. [...] It is rare for a patient to have a prolonged stay in the recovery area or require admission for medical stabilization. [...] If admission to a psychiatric service were needed, based on the evaluation by the psychiatrist at the time of the ECT, this would be arranged through the typical processes for psychiatric hospitalization of an outpatient and would not require staying in the ASC. [...] The fact that ECT is administered as a series of treatments, typically three treatments weekly for two to four weeks for an acute treatment course and weekly to monthly ECT for maintenance treatment, adds to the travel burdens for patients and friends, family, or other caregivers who must drive them to and from the procedure. [...] In the case of accelerated TMS (0890T, 0891T and 0892T), hospital outpatient settings are well positioned to provide this care, however APC 1522 does not adequately reflect the resources required to perform these services in that setting. [...] The next step in the evolution of measurement would be to measure if those who screen positive are connected to appropriate resources. This will be a tremendous task requiring additional financial resources and technological capabilities but will be an important step towards improving outcomes. This would be particularly challenging for rural emergency departments that may lack the resources r
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