the last three years. Do you have any insights to share on that? PRENTICE: This seems to be a new approach to the statutory oversight that CMS already performs in all sites of service. Right now, they are proposing to review 38 procedures (spine, vascu- lar and gynecologic) that were added to the ASC payment list in CYs 2015, 2016 and 2017. In the future, they will continue to use this three-year win- dow; so, if the new cardiac codes con- tained in this rule are adopted, we would expect to see them reviewed in this same way in CYs 2019, 2020 and 2021. We agree that there can be clin- ical differences between the Medicare and non-Medicare populations, so this kind of review of newly added pro- cedures to a site of service—whether from hospital inpatient to outpatient, HOPD to ASC or ASC to the physi- cian office—makes sense, and we sup- port this oversight.

Could you speak to the proposed provision that addresses payment for non-opioid pain management therapy? PRENTICE: As you know, Presi- dent Trump has made responding to the opioid epidemic in America a pri- ority. This provision is a result of that endeavor and an idea we brought to the Administration’s attention. Current payment policy serves as an impediment to using non-opioids for post-surgical pain, so this provi- sion addresses our concerns by allow- ing ASCs to get paid for non-opioid pain relief drugs when used in a sur- gical procedure. Currently, Exparel is the only drug that CMS has identified in the rule that qualifies. We will be interested to hear from the ASC com- munity as to whether there are other alternatives being used for which CMS should apply this new policy.

The proposed rule would remove eight measures from Medicare’s

ASC Quality Reporting (ASCQR) Program over a two-year period: ■■

ASC-1: Patient Burn; ■■ ASC-2: Patient Fall; ■■

■■ ■■ ■■

ASC-3: Wrong Site, Wrong Side, Wrong Patient, Wrong Procedure, Wrong Implant;

ASC-4: All-Cause Hospital Transfer/ Admission;

ASC-8: Influenza Vaccination Cover- age Among Healthcare Personnel;

ASC-9: Endoscopy/Polyp Surveillance Follow-up Interval for Normal Colo- noscopy in Average Risk Patients;


ASC-10: Endoscopy/Polyp Surveil- lance: Colonoscopy Interval for Patients with a History of Adeno- matous Polyps—Avoidance of Inap- propriate Use; and

ASC-11 (voluntary measure): Cata- racts—Improvement in Patient’s Visual Function within 90 Days Fol- lowing Cataract Surgery. Please discuss some of the details related to these changes. PRENTICE: Importantly, the ratio- nale that CMS is using to justify elim- ination of ASC-1, 2, 3 and 4 is that the results have “topped out,” which is the term used to indicate that positive per- formance on these measures is so con- sistently high that CMS sees almost no room for improvement and no reason to continue measuring them. For the other measures, we


are grateful that CMS has agreed with the concerns that ASCA and the ASC community expressed originally about them, i.e., that those measures were not really related to quality and, therefore, not appropriate for a quality reporting program.

While we are grateful for these changes, we continue to believe that patients deserve more information about the quality of care they receive in all settings and look forward to working with CMS staff to develop more mean- ingful measures that provide actionable data for patients, providers and regula- tors about outpatient procedures.

Okay. Last question on the quality reporting measures: When can ASCs stop reporting the ones that are being removed? PRENTICE: If this provision is adopted in the final rule, ASCs can stop reporting anything on Medicare claims beginning January 1, 2019. They can also stop reporting ASC-8 immediately and stop collecting data on ASC-9 and 10 on January 1, 2019. To qualify for their full payment update in 2020, how- ever, facilities still need to report the data they collect this year on measures ASC-9 and 10 in 2019. Reporting on ASC-11 is already voluntary, so there are no additional reporting require- ments tied to that measure. Beginning in 2019, ASCs will also

need to report information they began collecting this year on two new mea- sures—ASC-13: Normothermia and ASC-14: Unplanned Anterior Vitrec- tomy.

These reporting requirements were not changed in the proposed rule.

A few years ago, CMS proposed instituting a lengthy patient experience of care survey in ASCs and HOPDS that it called the Consumer Assessment of Healthcare Providers and Systems Outpatient and Ambulatory Surgery Survey (OAS CAHPS). Based on comments it received on the complexity of the reporting process, CMS decided last year to delay implementation of the survey until further notice. Does this proposed rule reveal when that survey might begin? PRENTICE: In this proposal, CMS indicates that the OAS CAHPS survey remains on hold but makes clear that it continues to plan to require ASCs and HOPDs to use a version of that survey in the future. ASCA continues to have strong concerns about the length of the survey and the lack of an email option, but we remain hopeful that those con- cerns will be addressed before CMS begins to require use of that survey.

Go to page 28 for related article. ASC FOCUS OCTOBER 2018 | 9

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