MESSAGE FROM THE CEO
2018 Proposed Rule Shows Results of ASCA’s Hard Work T
he Centers for Medicare & Medicaid Services (CMS) released its 2018 proposed payment rule for ASCs and hospital outpatient departments (HOPDs)
in July. While the proposal did not address all of ASCA’s concerns regarding Medicare reimbursement for ASC services, it did show a greater recognition of the evolution in care being provided in ASCs. It also requested input on ways to improve Medicare’s ASC payment system, including suggestions for eliminating inappropriate payment differentials for similar services delivered in the inpatient and outpatient settings.
If the proposed rule were to be finalized as drafted, ASCs would see, on average
for all covered procedures, an effective update of 1.9 percent—a 2.3 percent inflation update based on CMS’ estimation of the change in the Consumer Price Index for All Urban Consumers (CPI-U) minus a productivity reduction mandated by the Affordable Care Act of 0.4 percentage points. While CMS did not propose to align update factors between ASCs and HOPDs—as ASCA has consistently requested—the agency requested feedback on alternatives to the CPI-U that could be used to update ASC payments. In the proposed rule, CMS proposed to add two spine codes, 22856 (Cerv artific
diskectomy) and 22858 (Second level cer diskectomy), and one gynecological code, 58572 (Tlh uterus over 250 g), to the ASC list of payable procedures for 2018. CMS also proposed to remove total knee arthroplasty (TKA) from the inpatient-only list for 2018 and solicited comments on whether partial and total hip replacements should also be removed from the inpatient-only (IPO) list. ASCA has been advocating for CMS to remove TKA from the IPO list and include it on the ASC-payable list. In the 2018 proposed rule, CMS proposed the removal of TKA from the IPO list, acknowledging it has “taken into account the recommendation from the summer 2016 Advisory Panel on Hospital Outpatient Payment (HOP Panel) meeting to remove the TKA procedure from the IPO list.” ASCA staff and members coordinated that successful presentation. Even though CMS is not proposing to move these joint replacement codes to
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the ASC-payable list now, the agency is soliciting comments on whether TKA, partial hip arthroplasty and total hip arthroplasty meet the criteria to be added to the ASC Payable List. Among the many changes proposed for the ASC Quality Reporting Program in the rule, one of the most significant was CMS’ proposal to delay the mandatory implementation of the Consumer Assessment of Healthcare Providers and Systems Outpatient and Ambulatory Surgery (OAS CAHPS) Survey for calendar year (CY) 2018 data collection. Under this proposal, ASCs that would like to continue to administer the survey under the voluntary national implementation may do so in CY 2018. While we strongly support having a patient experience of care survey in both the ASC and hospital outpatient settings, we appreciate that the agency has delayed the implementation of the OAS CAHPS measure until the costs and administrative burdens of the survey are reduced. We look forward to working with the agency to make those improvements as quickly as possible. ASCA will submit comments on this proposal during September. The final rule, which will dictate Medicare’s 2018 payment policies for ASCs, is scheduled for release in early November.
Bill Prentice Chief Executive Officer
ASC FOCUS SEPTEMBER 2017 |
www.ascfocus.org
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