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REGULATORY REVIEW


Make Compliance Easier Put ASCA’s regulatory resources to work in your ASC BY ALEX TAIRA


With Medicare’s 2018 payment rule in final form and the calendar refresh- ing toward a new year, now is a good time for


ASCA members to consider how to make the most of all the regulatory resources ASCA makes available for their use each year. Navigating the assortment of rules and regulations tied to ASC oversight, payment and accreditation can be a complex propo- sition, even for those with experience. Covered codes and payment rates are updated annually, and the ASC Qual- ity Reporting program continues to change and mature with the industry. At ASCA, we strive to provide up-to- date regulatory information you can use to easily find the answers you need to keep your center compliant and run- ning smoothly. Resources related to the regulatory areas discussed below can be found under the “Federal Regu- lations” tab on ASCA’s website.


Payment Resources Since 2008, Medicare has covered pro- cedures performed in ASCs under a separate payment system tied to hospi- tal outpatient rates. The ASC payment is what is called a facility payment. It covers nursing/technical/administra- tive services, materials, certain devices and drugs, and other ancillary items and services. The list of specific proce- dures covered and reimbursement rates provided is outlined every year in a rule produced by the Centers for Medicare & Medicaid Services (CMS). That rule is released in proposed form during the summer and in final form by Novem- ber 1. After CMS releases one of these proposed rules, ASCA provides: ■■


General analysis: An overview of the rule’s major components, includ- ing high-level rate updates, codes


Resources related to regulatory areas can be found under the ‘Federal Regulations’ tab on ASCA’s website.


added or subtracted from reimburse- ment and other notable proposals.


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Rate Calculator: A proprietary tool ASCA members can use to find the exact proposed national and local payment rates for any code by input- ting their center’s state and county.


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General payment resources: A more granular look at codes on the proposed ASC-payable list, arranged by category.


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Comments and comment tem- plates: ASCA provides comprehen- sive comments to CMS in response to its proposed rule. Although some ASCA members may not know how or when ASCA submits these com- ments, providing them is among the most important services ASCA pro- vides for its members. In addition to payment rates and policies, these comments address topics like which procedures Medicare will reim- burse ASCs for providing, quality reporting requirements, relief from burdensome regulatory require- ments and more. These comments give Medicare officials important insights into the concerns that ASCs face and the support they need to be able to continue to provide the


best in outpatient surgical care to patients. Since many independent insurers look to Medicare as they set their own policies and rates, the comments ASCA submits to CMS affect all ASCs. ASCA also pro- vides its members with comment templates that they can easily use to provide their own feedback to CMS. After the rule is finalized in late fall, ASCA prepares final versions of the first three resources listed above. Addi- tionally, ASCA provides an analysis of the final rule compared to ASCA’s comments on the proposed version. It is worth noting that other Medicare payment rules also affect ASCs. While ASCA dedicates the most time and energy toward the updates to the ASC Payment System, it also provides com- ments, annual updates and light analy- sis of the hospital outpatient (OPPS), Quality Payment Program (under the Medicare Access and CHIP Reauthori- zation Act of 2015 or MACRA statute), and Medicare physician fee schedule (MPFS) rules. Members can find infor- mation on these payment rules and reg- ulations on ASCA’s website, under the “Federal Regulations” tab.


ASC FOCUS NOVEMBER/DECEMBER 2017|www.ascfocus.org 21


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