MESSAGE FROM THE CEO


Proposed Rule a Victory for the ASC Community T


his year is shaping up to be a momentous one for the ASC community. One important reason for that is the Centers for Medicare & Medicaid Services’ (CMS) proposed 2019 ASC payment rule issued in July. That proposal suggests sweeping changes to Medicare’s ASC policies. This is, by far, the most significant rule we have gotten in my time here at


ASCA. Throughout, the language and provisions the rule contains demonstrate CMS’ commitment to promoting and protecting patient access to ASCs. We need to remember, though, that this is the proposed rule, meaning we have to see what is finalized in November before drawing any conclusions. Our biggest apparent victory in this rule is the proposal to measure inflation in ASCs by using the hospital market basket instead of the Consumer Price Index for All Urban Consumers (CPI-U) basket. ASCs use the same staff, services and sup- plies as hospital outpatient departments (HOPD), so it only makes sense to apply the same inflation rate for our yearly updates. Years of ASC professionals lobbying to move ASCs from the CPI-U to the hospital marker basket have finally borne fruit. Other proposed changes include: If the proposed rule is finalized as drafted, ASCs will see, on average, over all


covered procedures, an effective update of 2.0 percent—a combination of a 2.8 percent inflation update based on the hospital market basket and a productivity reduction mandated by the Affordable Care Act of 0.8 percentage point. In the ASC Quality Reporting (ASCQR) Program, CMS is proposing to remove a total of eight measures over a two-year period. Contrary to what certain recent media coverage might imply about the quality of care ASCs provide, CMS’ ratio- nale for these changes is that ASC performance on these measures is already so high that meaningful improvements are no longer possible. Also of note concerning the ASCQR Program, CMS did not propose to man- date implementation of the Consumer Assessment of Healthcare Providers and Systems Outpatient and Ambulatory Surgery Survey (OAS CAHPS) yet. Another change that CMS proposed speaks to a change ASCs have been requesting for some time: defining ASC device-intensive procedures as those procedures with a device offset percentage greater than 30 percent based on the standard OPPS APC rate-setting methodology rather than the current 40 percent threshold. ASCA and individual ASC professionals have advocated strongly for a lower threshold in order to migrate these procedures to our setting. In an unexpected move, CMS proposed to revise its definition of “surgery” in


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the ASC payment system to account for certain “surgery-like” procedures that are assigned codes outside the Current Procedural Terminology (CPT) surgical range. This revision allowed them to propose adding 12 cardiac catheterization proce- dures to the ASC covered procedures list. Also for 2019, CMS proposed to provide separate payment for non-opioid pain management drugs that function as a supply when used in a surgical procedure when the procedure is performed in an ASC. HCPCS code C9290, Exparel, is the only code that CMS identified as meeting the proposed criteria right now. As we expected, CMS did not propose to add any total joint replacement codes to the ASC-payable list for 2019.


Comments on the proposed rule are due on September 24, 2018, so if you read this before then, we urge you to support ASCA’s advocacy efforts by submitting your own comments.


Bill Prentice Chief Executive Officer


ASC FOCUS SEPTEMBER 2018 |www.ascfocus.org


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