12-669-008RCS CONSULTING GROUP, INC.
2685 N.W. 48th Street Boca Raton, FL 33434
Phone: 561- 443 -0453 Fax: 561 -443 -0428
Email: RCSConsult@aol.com
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August 7, 2012
Ref: Process # M2012008609
Miami Dade County Building Dept.
7330 SW 62 "d Place
Suite 200
Miami, Fl 33143
To Whom It May Concern:
I understand that there may be some confusion regarding the status of Dr. Serure's office. Please
allow me to take this opportunity to clarify the difference between a licensed ambulatory surgery
center (ASC) and a state - registered office based surgical (OBS) facility. In state - registered office
based surgical facilities (which will be the case for Dr. Serure), physicians perform limited
procedures on patients who must be relatively healthy. There will only be one patient having a
procedure at any given time in Dr. Serure's office. These offices are more like oral surgery
offices than ambulatory surgery centers. OBS is under a different regulatory mechanism than an
ASC, and physicians must be registered at OBS facilities. Physicians are not required to be
registered at ASCs or hospitals; instead the facility performs its own credentialing process.
If the goal is to obtain reimbursement for facility fees from Medicare /insurance companies, the
facility must be a licensed ASC. This means that the facility must meet stringent Federal
(Medicare) and State /local building requirements including Life Safety fire regulations (59A -5
Florida Administrative Code and 395 Florida Statutes). Licensure for ASCs and hospitals is
granted by the Agency for Health Care Administration (AHCA), which is a subdivision of the
Florida Department of Health. If the facility is accredited then additional standards apply.
If reimbursement is not a consideration, as is the case in purely cosmetic procedures such as
those performed by Dr. Serure, then the facility can go with the lesser requirements of an office
based surgical facility. These facilities are regulated by the Department of Health's Board of
Medicine (64138 -9.009 Florida Administrative Code) and have no specific physical facility
requirements. State inspection or accreditation by a state approved agency (Joint Commission,
AAAASF or AAAHC) is required for this facility and if accredited, the facility must comply
with the state regulations and then the additional accreditation standards. These accreditation
standards are specifically geared for office based facilities and not ambulatory surgical centers,
as those centers are accredited under different and more complex standards.