ASCA Comments on CMS’ Proposed Payment Rule I

n early September, ASCA submitted formal comments to the Centers for Medi- care & Medicaid Services (CMS) on Medicare’s proposed 2018 ASC payment

rule. Also known as the 2018 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System proposed rule, it recommends ASC reimbursement rates for the coming year and other payment policies, including Medicare quality reporting requirements. Under CMS’ proposal, ASC rates would receive an across-the-board increase

of 1.9 percent based on the Consumer Price Index for All Urban Consumers (CPI- U). While this is slightly higher than the hospital outpatient departments’ (HOPD) effective increase of 1.75 percent, that uptick occurs only because of a 0.75 percent reduction that is mandated for hospitals under the Affordable Care Act (ACA). The hospital market basket update, on which the HOPD update is based, is 2.9 percent. Along with other payment policy issues impacting ASC payments, such as a secondary rescalar, this year’s proposed payment updates continue the troubling trend of diverging payments. As in previous years, ASCA proposed that CMS align the two update factors to prevent a continuing divergence in payment rates by using the hospital market basket to determine the update factor for ASCs. In addition to the revised rates, the agency proposed to add three new procedures

to the ASC list of payable procedures for 2018. While ASCA appreciates that CMS has acknowledged that these procedures are safe and effective when done in the ASC setting, we recommended CMS allow all procedures that are payable in the HOPD setting to also be payable in the ASC setting. There are currently 345 surgi- cal codes which are reimbursable when performed in the HOPD but not the ASC. ASCA further responded to a CMS request for comments by asking that CMS

remove three joint replacement procedures (total knee, partial hip and total hip) from the Medicare inpatient-only list. ASCA believes that these procedures fully meet CMS’ criteria for performance in an outpatient setting and supports giving patients and surgeons the greatest flexibility in determining the appropriate site of service. Finally, CMS proposed to indefinitely delay mandatory implementation of

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the Consumer Assessment of Healthcare Providers and Systems Outpatient and Ambulatory Surgery (OAS CAHPS) survey. While ASCA supports the prolifera- tion of quality measures that demonstrate the excellence of care in ASCs, we have strong concerns regarding the efficacy of the OAS CAHPS survey in its current format and appreciate CMS reconsidering its January 1, 2018, mandatory imple- mentation date. ASCA requested that the survey be shortened and that an elec- tronic survey mode be made available. To review a complete copy of ASCA’s comments on the proposed rule, go to CMS’ final rule is due out November 1. ASCA will notify its members when it is released and provide analysis as available. Please make sure that we have your email address on file. If you are not already receiving emails from ASCA, write For more information about Medicare’s proposed and final payment rules, write Kara Newbury at

Bill Prentice Chief Executive Officer


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