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REGULATORY REVIEW


not perform colonoscopies, for both ASC-9 and ASC-10 you will enter “0” in the numerator and the denominator. The percentage of patients receiving appropriate recommendation for follow- up screening colonoscopy, as captured with ASC-9, declined from 80.98 per- cent in 2015 to 77.78 percent in 2016. On the webinar discussing reporting issues, CMS contractors indicated that facilities had problems with: appropri- ate documentation of a medical reason for exclusion; exclusion regarding the age of the patient; and lack of documen- tation regarding the follow-up interval. The Specifications Manual was updated to provide clarity on some of these points; that documentation of medical reason(s) for not recommend- ing at least a 10-year follow-up inter- val could include cases of inadequate prep, familial or personal history of colonic polyps, patients with no ade- noma and age greater than 66 years old or life expectancy of less than 10 years. Medical reason(s) are at the dis- cretion of the physician. Documenta- tion indicating no follow-up colonos- copy is needed or recommended is only acceptable if the patient’s age is documented as at least 66 years old or life expectancy is less than 10 years. The percentage of patients with his-


tory of polyps receiving follow-up colo- noscopy in the appropriate timeframe, data publicly reported as ASC-10, also went in the wrong direction, from 79.90 percent in 2015 to 73.21 percent in 2016. The primary issues with reporting have been: confusion about documenta- tion of the last colonoscopy—which is particularly difficult if the patient did not have the prior colonoscopy per- formed in that facility—and proper documentation of medical reasons. ASC-12: Facility Seven-Day Risk-


Standardized Hospital Visit Rate after Outpatient Colonoscopy data also is made public as a mandatory measure in the ASCQR Program, but there is no reporting requirement on the facility as the data will be pulled from claims pre-


viously submitted by the hospital that the patient visits within seven days of the colonoscopy.


As with all measures in the ASCQR


Program, ASCs are given access to preview their ASC-12 data before it is made public. Since ASC-12 is a mea- sure that captures all-cause, unplanned hospital visits, there certainly could be some patients counted who have noth- ing to do with the services your facility provides. It is recommended that facil- ities review their reports to determine how many of the hospital visits could be tied to the performance of the colo- noscopy within their facilities. In addition to the measures above


which ASCs are currently reporting, there are two new measures on which ASCs are collecting data in 2018 for reporting beginning in 2019. ASC-13: Normothermia is used to assess the percentage of patients having surgical procedures under general or neuraxial anesthesia of 60 minutes or more in duration who are normothermic within 15 minutes of arrival in the post-anesthesia care unit (PACU). CMS has added some tools to help ASCs with this measure. These are available at www.qualityreporting center.com/asc/resources. Each ASC should identify surgical patients with general or neuraxial— epidural or spinal—anesthesia equal to


Track the Latest Regulatory and Legislative News for ASCs


Visit ASCA’s website 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


or greater than 60 minutes in duration. That number will be the denominator. Cases with strictly sedation or local anesthesia should not be included. Next, the ASC should determine the start time of anesthesia. If there is no start time, that patient should not be included in the denominator. Likewise, if there is no end time, that patient should not be included in the denomi- nator either. Next, the facility should determine the numerator by calculating how many patients in the denominator population had the required body temperature— greater than or equal to 96.8 degrees Fahrenheit—within 15 minutes of arriv- ing in the PACU.


The data that is reported to CMS will be based on a sampling of eligible cases, “the denominator.” If the pop- ulation of eligible cases is 63–900, a sample of 63 may be used. If the popu- lation of eligible cases is greater than or equal to 901, a sample of at least 96 should be used. If the population is fewer than 63 cases, the total popula- tion of cases is required. ASC-14: Unplanned Anterior Vit-


rectomy is used to assess the percentage of cataract surgery patients who have an unplanned anterior vitrectomy. It is a straight-forward measure: the numera- tor is the total number of patients who had an unplanned anterior vitrectomy, and the denominator is all cataract sur- gery patients. There are no exclusions for this measure. Visit ASCA’s 2018 Quality Report- ing Requirements web page, www.asc association.org/asca/federalregulations /qualityreporting/reportingrequirements, for more information, including the cur- rent Ambulatory Surgical Center Qual- ity Reporting Specifications Manual, https://www.qualitynet.org/dcs/Content Server?c=Page&pagename=QnetPublic %2FPage%2FQnetTier2&cid=12287 72475754.


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


ASC FOCUS JUNE/JULY 2018 |www.ascfocus.org 25


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