REGULATORY REVIEW


on April 1, 2014, and now must report data on those measures between Janu- ary 1 and August 15, 2015, via the CMS QualityNet site. ASCs that fail to file those data reports will have their 2016 Medicare payments reduced by 2 percent. ASC-9 and ASC-10 are both colonoscopy measures that are intended to ensure that physicians are recommending appropriate intervals for follow-up screening colonoscopies. ASC-9 measures if physicians recommend that average- risk patients with no history of polyps return for a follow-up screening every 10 years. ASC-10 collects data on the follow-up recommended for patients with a history of adenomatous polyps as often as every three years. An ASC will need to work with the patient or the patient’s gastroenterologist to ensure that the follow-up interval is properly documented.


Sampling Recognizing that reporting on ASC-9 and ASC-10 might create an adminis- trative burden for ASCs, CMS decided that ASCs should be required to report only on a sample of cases. The sam- ple size for these measures is based on the annual patient population that each ASC is evaluating for each of the measures. ASCs that serve up to 900 patients for a particular measure will be required to report on 63 cases, and ASCs that serve 901 or more patients will be required to report on 96 cases. More information on which patients are included for purposes of these measures can be found in the ASCQR Specifications Manual. The updated ASC Quality Measures Specifications Manual released in December 2014 is available at www. ascassociation.org/QRSpecsManual. More information on the sampling specifications for Medicare’s two new quality measures is included on pages 22–25.


ASCs must now report five additional measures via two different web sites. Three of these measures must be reported for the first time in 2015.”


—Kara Newbury, ASCA


Exemptions for ASCs with Low Medicare Volume In its final 2014 ASC payment rule, CMS finalized a proposal to exempt ASCs that have fewer than 240 annual Medicare primary and secondary claims per year from all of Medi- care’s quality reporting requirements. This exemption was maintained for 2015. The volume of Medicare claims included in this count is based on the year prior to the affected reporting period. For instance, if an ASC sub- mitted only 200 claims to Medicare in 2014, it would not be required to report quality data in 2015.


All Current Measures Although just three new measures were added for the 2015 reporting period, ASCs must continue to report on the other seven measures that they were required to report previously to be considered compliant with all of the requirements of the ASCQR Program. A breakdown of all of the data collection and quality report- ing requirements that affect ASCs in 2015 follows. ■


ASCs must continue to report on measures ASC-1 through ASC-5. All of these measures are entered as G-codes on the CMS-1500 claim form. Successful participation for these measures is achieved if the ASC reports on 50 percent of claims in which Medicare is the primary or secondary payer for the year. CMS has indicated that it might raise this


threshold in the future. For more information on the G-codes, visit: www.ascassociation.org/qualityreporting.


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ASC-6 (safe surgery checklist) and ASC-7 (certain volume data) are web-based measures, which means that these reports need to be filed online. Data that ASCs collect in 2014 will be reported in 2015 via CMS’ QualityNet web site, after a one-year reprieve from data report- ing in 2013. This reprieve allowed CMS to align the reporting periods across all measures on a three-year cycle, i.e., data is collected the first year and reported the second year, and ASC payments are impacted in the third year. The ASCQR Pro- gram’s Specifications Manual has been updated to reflect the codes for which volume data must be reported in 2015.


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ASC-8 data collection began this influenza season, which started Octo- ber 1, 2014, and ran through March 31, 2015. ASCs will be required to submit these data reports by May 15, 2015. Please note that this deadline is earlier than that of the other web- based measures, and remember that the information must be reported via NHSN, not QualityNet.


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For ASC-9 and ASC-10, which are both colonoscopy codes, all Medi- care-certified ASCs must report on these measures via QualityNet in 2015 regardless of their specialties or case mix. If your center does not per- form colonoscopies, for both ASC-9 and ASC-10, you will enter “0” in the numerator and the denominator. More information on the current


reporting requirements is available on ASCA’s Quality Reporting web page, www.ascassociation.org/federal regulations/qualityreporting.


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


ASC FOCUS APRIL 2015 19


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