REGULATORY REVIEW


to encourage both Medicare and pri- vate payers to allow for the migration of surgical procedures from the hos- pital inpatient and outpatient setting to the ASC setting. The initial group of facilities involved in the project are those that participated in the Innova- tion Center grant application in 2013. Future plans call for an expansion into other facilities performing total joint replacements as well. KNG has worked with a subcon- tractor to develop a real-time data col- lection tool that includes data fields for quality and outcomes measures, patient satisfaction and patient char- acteristics currently being identified by the project’s steering committee. This tool will ensure that data collec- tion is standardized across participat- ing providers and allow for patient profiles to be tracked and updated across multiple visits.


Tool Measures and Assessment Questions ASCA worked with the initial group of participants to make sure the tool col- lects all necessary information without overly burdening facilities with addi- tional reporting requirements.


Measures Currently in Medicare’s ASC Quality Reporting Program Since CMS has already identified out- comes measures such as patient burn, patient fall, wrong site/side/patient/ procedure/implant and prophylactic intravenous (IV) antibiotics timing as those that it believes are indicative of the quality of care being provided in ASCs, the steering committee felt it was important to include those measures in the tool.


Measures on Exclusionary List It is important to refute any exclusion- ary criteria to see movement to the ASC-payable list. As such, the tool will ask if there was a blood transfusion during the procedure, which addresses


the criteria, “generally results in exten- sive blood loss.”


There also are questions that speak to whether the procedure poses a “significant safety risk,” which is another exclusionary criteria. Facilities will report patient admissions to an acute care hospital or an emergency department for any cause within 30 days of the discharge date, as well as patient deaths within 30 days of the discharge date.


Patient-Reported Outcomes Patient-reported information demon- strates whether the surgery was suc- cessful and if it was necessary. This tool asks patients preoperatively to provide activities they are unable to do or have difficulty doing related to the need for surgery. Six months post- discharge, patients will be asked to rate the difficulty of performing the activities, with the hope that there will be marked improvement.


The tool also contains certain


experience of care questions that are included in The Consumer Assessment of Healthcare Providers and Systems Outpatient and Ambulatory Surgery Survey (OAS CAHPS) that became voluntary in 2016. As this magazine goes to press, two


facilities involved in the steering group have completed pilot testing of the tool to determine how well it works. Other facilities also are beginning to use the tool. After the data collection period, KNG will analyze the data and develop a document, most likely in the form of a white paper, that can be used with payers, including Medicare, to encour- age them to reimburse ASCs for total joint procedures.


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


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