REGULATORY REVIEW
of the procedure in the HOPD setting. ASCA once again recommended that CMS drop the threshold percent down to 30 percent, allowing for more pro- cedures to migrate to the lower-cost ASC setting. CMS finalized its pro- posal to continue its device-inten- sive procedure policy. CMS acknowl- edged ASCA’s recommendation that the agency lower the threshold per- cent to 30 and noted that lowering the threshold might incentivize procedures to migrate to the ASC setting. ASCA views this as a positive, as it would save Medicare and its beneficiaries money. We will continue to advocate for this change.
Unlisted Codes Unfortunately, CMS is continuing its policy of not reimbursing ASCs for unlisted codes because it believes that it is not “appropriate to provide ASC payment for procedures described by unlisted CPT codes in the surgical range, even if payment may be pro- vided under the OPPS.” Commercial payers commonly allow ASCs to use unlisted CPT codes to report proce- dures, and CMS permits this practice for HOPDs but not for ASCs.
Quality Reporting for ASCs CMS also finalized its proposal to align the reporting deadline for all web-based measures in the ASC Quality Reporting Program. Beginning with data reporting in 2018, all web-based measures must be submitted by May 15. CMS also finalized seven new mea- sures to be added for 2018 data collec- tion. Reporting on these measures will impact 2020 payment determinations. Two measures require data to be submitted directly to CMS via Qual- ityNet: (1) ASC-13: Normothermia Outcome, percentage of patients hav- ing surgical procedures under gen- eral or neuraxial anesthesia of 60 minutes or more in duration who are normothermic within 15 minutes of
Unfortunately, in the final rule, more than 300 codes that are payable when performed in HOPDs are still not designated as payable in the ASC setting.”
—Kara Newbury, ASCA
arrival in the post-anesthesia care unit (PACU), and (2) ASC-14: Unplanned Anterior Vitrectomy, a procedure per- formed when vitreous inadvertently prolapses into the anterior segment of the eye during cataract surgery. Five measures are based on the use of the OAS CAHPS survey. 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 (5) ASC-15e: OAS CAHPS—Rec- ommendation of Facility. As a reminder, for all measures in
the ASC Quality Reporting (ASCQR) Program, facilities are exempt from participation if they bill fewer than 240 Medicare primary and secondary claims in a year. The OAS CAHPS instrument,
which is currently voluntary, contains 37 questions about the patient’s overall rating of the outpatient surgery facility,
experience with the check-in process, facility environment, communication with administrative staff (reception- ists) and clinical providers (doctors and nurses), attention to comfort, pain control, provision of pre-and post-sur- gery care information, overall expe- rience and patient characteristics, as well as demographic information. Each ASC will be required to con- tract with a CMS-approved vendor to collect survey data for eligible patients at the ASC on a monthly basis and report that data to CMS on the ASC’s behalf. Facilities will need 300 com- pleted surveys from patients to meet the reporting requirements. In 2017, ASCA will continue to
advocate for reductions in the length and number of completed surveys required in the 2018 payment rule that will be finalized prior to the full implementation of the OAS CAHPS survey.
Kara Newbury is ASCA’s regulatory counsel. Write her at
knewbury@ascassociation.org.
ASC FOCUS FEBRUARY 2017 21
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