REGULATORY REVIEW


than 40 percent of the total cost of the procedure when performed in the HOPD setting. The previous threshold was 50 percent, and ASCA has consistently advocated for a lower threshold. In 2014, there were at least 150 codes performed in high volumes in the HOPD setting that most ASCs were


not performing because they


were not adequately reimbursed for the devices involved. ASCA requested that CMS lower the threshold to 30 percent, which would have allowed most of these codes to be designated as device-intensive. Even at the 40 percent threshold that was finalized, however, 47 codes with high device costs are now economically feasible for ASCs to perform.


Quality Reporting for ASCs Citing operational concerns with the measure, CMS finalized its proposal to make ASC-11: Cataracts: Improve- ment in Patient’s Visual Function within 90 Days Following Cataract Surgery a voluntary measure in the ASCQR Pro- gram. ASC-11 is a physician-level measure that does not speak to the quality of the services that ASCs pro- vide, and ASCA worked closely with a coalition of ophthalmic specialty orga- nizations to advocate against its inclu- sion in the ASCQR Program. Unfortunately, CMS did finalize proposed quality measure ASC-12: Facility Seven-Day Risk-Standardized Hospital Visit Rate after Outpatient Colonoscopy, despite the objections of stakeholder groups, including ASCA. Although significant problems sur- round the measure’s validity, reliabil- ity and usability, there is no additional reporting burden on ASCs since the data will be pulled from claims sub- mitted by the hospitals for any patients’ visits within seven days of their outpa- tient colonoscopies.


CMS also finalized the May 15, 2015, reporting deadline for ASC- 8: Influenza Vaccination Coverage


22 ASC FOCUS FEBRUARY 2015


tal-owned facility that is not located on the hospital grounds. Reporting of this new modifier will be voluntary for one year (CY 2015) and required begin- ning on January 1, 2016. For professional claims, CMS will


CMS finalized an effective payment update of 1.4 percent for ASCs and an effective payment update of 2.2 percent for HOPDs in 2015.”


—Kara Newbury


among Healthcare Personnel through the National Healthcare Safety Net- work (NHSN), which is managed by the Centers for Disease Control and Prevention (CDC). To report ASC-8 through NHSN, someone from your ASC must enroll with NHSN. This process can take several weeks, so ASCs that have not already enrolled are advised to start the process imme- diately. For instructions, go to www. cdc.gov/nhsn/ambulatory-surgery/ enroll.html.


Off-Campus Provider-Based Departments


CMS also finalized a new data report- ing requirement for services that are furnished in what the agency refers to as “off-campus provider-based depart- ments.” Hospitals will report a mod- ifier on every code for outpatient hospital services furnished in a hospi-


delete current HOPD place of service (POS) code 22 and establish two new POS codes—one to identify outpatient services furnished in on-campus, remote or satellite locations of a hospital and one to identify services furnished in an off-campus HOPD. CMS might be seeking this information to better determine the costs of HOPDs that are attached to inpatient hospitals as compared to those that are off- campus. While not directly applicable to ASCs, this proposal is one to watch as it might impact site neutrality discussions in the future.


HOPD Comprehensive APC Policy CMS’ 2015 Medicare payment rule also finalized a comprehensive APC policy (C-APC) for HOPDs. A C-APC is an APC with a high cost primary service (generally includes device implantation) that accounts for a higher percentage of the total costs of the encounter. C-APCs for which payment for the comprehensive service (primary service and all related items and services) was packaged into a single payment in HOPDs is comparable to the single payment made under the inpatient prospective payment system for a hospital stay. This policy was not mirrored in the ASC portion of the rule but could impact ASC payments in future years since CMS uses HOPD cost data as part of the equation for updating ASC rates.


Kara Newbury is the assistant director of health policy at ASCA. Write her at knewbury@ascassociation.org.


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