Medicare Deemed Status Surveys for ASCs

The federal government continues to look for viable and cost-effective ways to assure quality health care delivery. One way is by recognizing private accrediting organizations (AOs) like AAAHC. AAAHC holds "deemed status" from the Centers for Medicare & Medicaid Services (CMS) to survey ambulatory surgical centers (ASCs) for Medicare.

More Details on Deemed Status

While CMS recognizes many AAAHC Standards as being equivalent to the ASC Conditions for Coverage (CfC), there are also additional Medicare requirements that AAAHC does not require of organizations that do not choose an AAAHC/Medicare Deemed Status Survey.

The AAAHC/Medicare Deemed Status Survey is conducted for ASCs using AAAHC Standards, as well as the additional Medicare requirements identified within the following chapters in the AAAHC Accreditation Handbook for Medicare Deemed Status Surveys. When the AAAHC Standard and a related CMS CfC could be interpreted as requiring differing levels of compliance, the more rigorous of the requirements must be met.

Chapters including CfCs   FAQs about the Chapter
1 Patient Rights and Responsibilities  
2 Governance Recredentialing requirements
3 Administration and Nursing Services  
4 Quality of Care Provided  
5 Quality Management and Improvement  
6 Clinical Records and Health Information  
7 Infection Prevention and Control and Safety  
8 Facilities and Environment  
9 Anesthesia Services  
10 Surgical and Related Services  
11 Pharmaceutical Services  
12 Pathology and Medical Laboratory Services  

The deemed status agreement represents a very positive option for new and existing surgery centers, in that, they now have an option to their state agency review for Medicare certification. Other state licensing obligations, however, may continue to exist for many ASCs.

Medicare Enrollment Process

For information on the enrollment process to obtain Medicare certification, please visit the Centers for Medicare/Medicaid Services at:

Provided below is the 855 Enrollment Process, which describes the sequence of activities that will occur as an organization applies for Medicare certification. It is important to note that an organization that seeks an AAAHC/Medicare Deemed Status Survey must have already completed #6 before AAAHC can schedule a survey.

Initial Medicare Certification Process

A History of AAAHC Deemed Status Surveys

On July 23, 1996, CMS published a proposal to grant deemed status to the Accreditation Association for its accreditation of ASCs. The notice produced overwhelmingly supportive comments.

On December 19, 1996, with CMS's publication of the final notice in the Federal Register of that date, ASCs accredited by the Accreditation Association were officially "deemed" to meet Medicare conditions of coverage (CfC) for ASCs. The deemed status notice became effective immediately. CMS recognizes surgery centers accredited by the Accreditation Association as being deemed to meet the Medicare CfC for ASCs.

Our deemed status has been continuously renewed by CMS, most recently in December 2018 for a period of six years.

Please contact us at if you have any further questions.


S&C Policy Memorandum Notifications

Infection Control Breach Reporting

Life Safety Code exemption rules


Life Safety Code issues are among the most frequent deficiencies cited for ASCs in the Medicare Deemed Status program.

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