Florida Chapter
American College of Surgeons

Critical Action Required for Office Surgery in Florida by 12/31/2019

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Critical Action Required for Office Surgery in Florida by 12/31/2019
The Law
Allopathic and osteopathic physicians who hold an active Florida license and perform Level II surgical procedures in Florida with a maximum planned duration of five (5) minutes or longer or any Level III office surgery, as fully defined in 64B8-9.009, must register with the Board of Medicine by 12/31/2019. See below for information on the levels of surgery.
Your Reality
Surgeons performing office surgery must submit their application by 12/31/2019 or face fines up to $5,000 per day for not registering. Click here to download the new registration application, which is also available on the Florida Department of Health website. To ensure timely and efficient customer service, please submit your application or questions to PMC_OSR@flhealth.gov.
What are the different levels of office surgery (per the Florida Department of Health)?
Level I office surgery includes, but is not limited to, the following:
  • Minor procedures such as excision of skin lesions, moles, warts, cysts, lipomas and repair of lacerations or surgery limited to the skin and subcutaneous tissue performed under topical or local anesthesia not involving drug-induced alteration of consciousness other than minimal pre-operative tranquilization of the patient.
  • Liposuction involving the removal of less than 4000cc supernatant fat is permitted.
  • Incision and drainage of superficial abscesses, limited endoscopies such as proctoscopies, skin biopsies, arthrocentesis, thoracentesis, paracentesis, dilation of urethra, cysto-scopic procedures, and closed reduction of simple fractures or small joint dislocations (i.e. finger and toe joints).
  • Pre-operative medications not required or used other than minimal pre-operative tranquilization of the patient; anesthesia is local, topical, or none. No drug-induced alteration of consciousness other than minimal pre-operative tranquilization of the patient is permitted in level I Office Surgery.
  • Chances of complication requiring hospitalization are remote.
Level II office surgery is that in which peri-operative medication and sedation are used intravenously, intramuscularly, or rectally, thus making intra and post-operative monitoring necessary. Such procedures shall include, but not be limited to: hemorrhoidectomy, hernia repair, reduction of simple fractures, large joint dislocations, breast biopsies, colonoscopy, and liposuction involving the removal of up to 4000cc supernatant fat. Also, includes any surgery in which the patient is placed in a state which allows the patient to tolerate unpleasant procedures while maintaining adequate cardiorespiratory function and the ability to respond purposefully to verbal command and/or tactile stimulation. Patients whose only response is reflex withdrawal from a painful stimulus are sedated to a greater degree than encompassed by this definition.
Level III office surgery is that surgery which involves, or reasonably should require, the use of a general anesthesia or major conduction anesthesia and pre-operative sedation. This includes, but is not limited to, the use of:
  • Intravenous sedation beyond that defined for Level II office surgery;
  • General Anesthesia: loss of consciousness and loss of vital reflexes with probable requirement of external support of pulmonary or cardiac functions; or
  • Major conduction anesthesia.
Only patients classified under the American Society of Anesthesiologist’s (ASA) risk classification criteria as Class I or, II, are appropriate candidates for Level III office surgery.
Publication Date: 
Wednesday, December 11, 2019 - 3:30pm