AS I SEE IT


be performed in an HOPD can’t be per- formed in an ASC. For several years, ASCA has urged CMS to begin pro- viding specific reasons why individual procedures, such as laminectomies and several urologic procedures, are not ap- proved for Medicare beneficiaries in the ASC setting. CMS, however, has not provided specific guidance. The general rea- sons that CMS uses to exclude a pro- cedure from Medicare’s ASC list are: ■


Generally results in extensive blood loss;


■


Requires major or prolonged inva- sion of body cavities;


■ Directly involves major blood vessels; ■


■ ■


Is generally emergent or life-threat- ening in nature;


Commonly requires systemic throm- bolytic therapy; and


Typically requires active medical monitoring and care at midnight fol- lowing the procedure. Clinical experts from the ASC set-


ting believe that many of the 366 proce- dures that ASCs cannot currently per- form for Medicare beneficiaries would not violate any of these exclusionary criteria. But, given CMS’ failure to provide the specific reasons why these procedures are not approved for Medi- care beneficiaries in the ASC setting, ASCA is unable to provide additional information in response. ASCA is pro- posing that the process be reformed to allow ASCs to perform all procedures that are allowed in the HOPD setting except those for which CMS specifi- cally identifies one or more of the six criteria to trigger exclusion.


ASCA is also suggesting that CMS


provide evidence to support the determi- nations it makes. That kind of transpar- ency would allow the industry to provide meaningful comments and data to CMS as the agency continues to consider which procedures ASCs can and cannot perform for Medicare beneficiaries.


Looking Ahead


At the same time that we work to re- solve issues of special concern to ASCs, ASCA will continue to promote the interests of ASCs and their patients in policy arenas that affect more global concerns. In 2013, some of those issues


Moving Device-Intensive Procedures to ASCs


Medicare would spend far less if many procedures that have costly devices as- sociated with them moved from the HOPD setting to the lower cost ASC set- ting. Currently, ASCs regularly perform 66 procedures that Medicare considers to be device-intensive, which means that the cost of the device represents 50 percent of the reimbursed amount to perform the procedure in the HOPD. There are, however, approximately 270 additional procedures that could qualify as device-intensive procedures


are likely to be drug shortages, federal budget issues, a meaningful response to the 2012 meningitis outbreak, phy- sician payment updates, quality report- ing and future developments tied to health care reform. As always, we need your support to continue our work on Capitol Hill and with the various regulatory bodies that help determine how your ASC is run. I urge you to make certain that you have renewed your ASCA membership for 2013 and to attend our annual meeting in Boston (April 17–20). There, you can learn more about the policy challenges


Illogical policies like these that favor HOPDs over ASCs limit patient choice, unfairly restrict competition and increase costs.”


—Nap Gary, Regent Surgical Health


if a slightly modified definition for that term were adopted. The definition that ASCA is proposing is “procedures for which the cost of the device represents 50 percent of the reimbursed amount to perform the procedure in the ASC.” In 2010, ASCs performed 150,000 the approximately 270 types


of of


procedures that would be reclassified as device-intensive procedures under ASCA’s proposed definition. Mean- while, HOPDs performed more than 1.5 million of these procedures at a much higher cost to the Medicare pro- gram and its beneficiaries. By paying ASCs a reasonable amount for these procedures, Medicare could realize substantial savings as these procedures move to the less costly ASC setting.


that ASCs are facing and the ways you can be involved. You can also get infor- mation that won’t be available anywhere else about improving your ASC’s bottom line, clinical improvements you can in- troduce at your ASC and ways for ensur- ing the future viability of your center. I also encourage you to participate in the fly-ins to Washington, DC, that ASCA will organize this year to educate Con- gress, to write letters to your members of Congress when we ask and to invite your elected officials into your ASC to learn firsthand why ASCs need and deserve their support.


When it comes to promoting pa- tient access to the care that ASCs provide, your participation is crucial to our collective success. Please get involved, stay involved and let ASCA know whenever we can help.


Nap Gary is the president of ASCA’s Board of Directors and chief operat- ing officer of Regent Surgical Health in Westchester, Illinois.


ASC FOCUS JANUARY 2013 9


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