REGULATORY REVIEW
Federal SRE Requirements Federal regulations require
ASCs
to document, report and develop strategies to reduce SREs in order to participate in Medicare and receive full reimbursement. Briefly outlined below are specific federal SRE requirements, which ASC clinicians and
administrators have grown
accustomed to reporting, and can be found in Medicare’s Conditions for Coverage (CfC) for ASCs and the Centers for Medicare & Medicaid Services’ (CMS) Ambulatory Surgical Center Quality Reporting Program (ASCQR Program). Under the ASCQR Program, ASCs are required to report qual- ity data or face a 2 percent Medicare payment reduction. The ASCQR Pro- gram’s reporting requirements were first introduced in the Calendar Year
The Specifications Manual for the ASCQR program,
www.ascaconnect.org/ASCQR, and the State Operations Manual Appendix L,
www.ascassociation.org/ StateOperations, are accessible on ASCA’s web site.
2012 Outpatient Prospective Pay- ment System (OPPS)/ASC Final Rule, which adopted five claims-based mea- sures and the way to report them. Four of these are SRE measures: ASC-1: Patient Burn; ASC-2: Patient Fall; ASC-3: Wrong Site, Wrong Side, Wrong
Patient, Wrong Procedure,
Wrong Implant; and ASC-5: Prophy- lactic Intravenous (IV) Antibiotic Tim- ing. The majority of these SREs can be found in both the NQF’s and ASC QC’s measure lists, which illustrates the consistency that has emerged between various SRE measures lists.
The ASCQR Program is updated
annually in the OPPS/ASC Final Rule, and new measures and reporting meth- ods have been added in addition to these SREs. Public reporting of an ASC’s per- formance on these measures has been the most notable change to the ASCQR Program when comparing it to other SRE programs. Public reporting is found in many other federal quality programs, and in almost all state SRE reporting programs. Of the 23 states that require ASCs to report SREs, 20 make that data available to the public. Setting aside other issues with the ASCQR Program, its standardized SRE measures and
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