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REGULATORY REVIEW


tation of intentional hypothermia for the procedure performed.


Unplanned Anterior Victrectomy Proposed measure ASC-14: Unplanned Anterior Vitrectomy would require ASCs to report patients who experience an unplanned anterior vitrectomy during their cataract surgeries. An unplanned anterior vitrectomy is performed when vitreous inadvertently prolapses into the anterior segment of the eye during cat- aract surgery. While unplanned anterior vitrectomy rates are relatively low, this procedure complication may result in poor visual outcomes and other compli- cations, including retinal detachment. This measure is based on aggregate


measure data collected via chart-abstrac- tion by the ASC and submitted via Qual- ityNet. The first data collection year would also be calendar year 2018, for payment determinations to be impacted in 2020. The outcome measured in the proposed ASC-14 measure is the per- centage of cataract surgery patients who have an unplanned anterior vitrectomy. The numerator is all cataract surgery patients who had an unplanned anterior vitrectomy, and the denominator is all cataract surgery patients. ASCA supports both ASC-13 and


ASC-14.


Consumer Assessment of Healthcare Providers and Systems Outpatient and Ambulatory Surgery Survey (OAS CAHPS) Five proposed measures are based on the use of the Outpatient and Ambu- latory Surgery Consumer Assessment of Healthcare Providers and Systems (OAS CAHPS). They are: 1. ASC-15a: OAS CAHPS— About Facilities and Staff;


2. ASC-15b: OAS CAHPS— Communication About Procedure;


3. ASC-15c: OAS CAHPS— Preparation for Discharge and Recovery;


4. ASC-15d: OAS CAHPS— Overall Rating of Facility; and


20 ASC FOCUS SEPTEMBER 2016


The one major change CMS proposed to the current measure set is the reporting deadline for ASC-6, ASC-7, ASC-9 and ASC-10, which are all web-based measures submitted via QualityNet.”


—Kara Newbury, ASCA


5. ASC-15e: OAS CAHPS— Recommendation of Facility. While many ASCs conduct their own patient satisfaction surveys, there is cur- rently no single instrument that assesses patient experiences in outpatient surgi- cal settings. CMS is proposing the adop- tion of the OAS CAHPS, which would measure patients’ experience of care within ASCs. CMS is proposing to make this survey mandatory for both ASCs and hospital outpatient departments (HOPDs) beginning in 2018. The OAS CAHPS instrument con- tains questions about the patient’s overall rating of the outpatient surgery facility, experience with the check-in process, facility environment, commu- nication with administrative staff and clinical providers, attention to com- fort, pain control, provision of pre-and post-surgery care information, overall experience and patient characteristics. If this measure is finalized, all facili- ties will be required to select and con- tract with a CMS-approved, third-party vendor who will collect the data and


Track the Latest Regulatory and Legislative News for ASCs


Visit ASCA’s web site every week to stay up to date on the latest government affairs news affecting the ASC industry. Every week, ASCA’s Government Affairs Update newsletter is posted online for ASCA members to read. The weekly newsletter tracks and analyzes the latest legislative and regulatory developments concerning ASCs.


www.ascassociation.org/ GovtAffairsUpdate


submit it to CMS to avoid any appar- ent bias of facility-facilitated surveys. The data may be collected by mail sur- vey, telephone survey or mixed mode (mail survey with telephone follow-up of non-respondents). ASCA has several concerns with this proposed measure, including the length of the survey (37 questions the proposed number of completed sur- veys for successful reporting (300 completed surveys) and the lack of an electronic option. Due to the depth of information included in the payment rule on this survey, ASCA will devote next month’s Regulatory Review col- umn solely to the OAS CAHPS section of the proposed rule.


Toxic Anterior Segment Syndrome (TASS) In addition to the seven new proposed measures, CMS also has requested more information on a toxic anterior segment syndrome (TASS) measure, another ophthalmic measure. TASS, an acute, noninfectious inflammation of the anterior segment of the eye, is a complication of anterior segment eye surgery that typically develops within 24 hours after surgery. The ASC Qual- ity Collaboration has also been work- ing on this measure, and ASCA is sup- portive of its inclusion in the ASC Quality Reporting Program. When the 2017 final rule is released in late October or early November, we will update members as to which of the new quality reporting policies were finalized. If you have other questions or need


more information, contact Kara Newbury at knewbury@ascassociation.org.


Kara Newbury is ASCA’s regulatory counsel. Write her at knewbury@ascassociation.org.


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