surrounding the collection of reliable, usable cost data. For example, in a 1994 Medicare survey, the Centers for Medi- care & Medicaid Services (CMS) found the resource cost information “irretrievably flawed.” Additionally, questions concerning the reliability of the systems ASCs used to collect cost data significantly reduced the number of ASCs that were ultimately included in the study, which was reported in the General Accounting Office study “Pay- ment for Ambulatory Surgical Centers Should Be Based on the Hospital Out- patient Payment System” that was pub- lished in November 2006.


ASCs’ limitations relating to uni- form process in cost data collection and reporting are expected to con- tinue absent material refinement. Key factors that are problematic for ASCs with cost reporting requirements MedPAC recommended recently and that need to be addressed include, but


are not limited to, the following: ■


differentiating ASCs by size and addressing the capabilities of smaller ASCs to report accurate and reliable data;


■


reliability of reporting of cost infor- mation due to variations in ASCs’ data collection systems and staff- ing capabilities to collect the data, accounting for the time and effort associated with overall direction and management of ASCs, which may be provided by physician leadership, management companies, hospitals or other third-party providers;


■ ■


implications of disparities in payer and case mix;


variances in operations and the business of single- versus multi- specialty ASCs;


■


defining a uniform process for collecting and reporting medical device and implant costs, especially since ASCs currently are not to report and bill Medicare separately for medical devices and implants;


■


clarifying the systems and report- ing requirements for ASCs to sub- mit cost data;


As our country continues to search for ways to lower the cost of healthcare and Medicare, it is critical that MedPAC and CMS recognize the value that migration of surgery to the ASC setting offers the Medicare program and its beneficiaries.”


—I. Naya Kehayes, ECG Management Consultants ■


ensuring that the output of cost data collected is used to reward ASCs for efficiency and the ability to migrate surgery to a lower-cost site of ser- vice (where applicable); and


■


accounting for fixed cost and capital expenditures and distribution of costs across all applicable case types. As our country continues to search


for ways to lower the cost of healthcare and Medicare, it is critical that Med- PAC and CMS recognize the value that


migration of surgery to the ASC setting offers the Medicare program and its beneficiaries. The two agencies must also recognize that the migration can be accelerated if further consideration is given to closing the gap between ASC and HOPD reimbursement.


I. Naya Kehayes is a member of ASCA's Cost Reporting Task Force and a principal of ECG Management Consultants in Seattle, Washington. Write her at NKehayes@ecgmc.com.


Opportunity in the Face of Adversity ASCA Government Affairs Committee works to support members through this challenging time BY ANNIE SARIEGO, RN, CASC


With the many changes 2020 presented to the US healthcare system, ASC advocacy was more impor- tant than ever last year


and has set the groundwork for ASCs in 2021. As chair of the Government Affairs Committee (GA) for ASCA, I can confirm that we are continuing to make steady progress toward enhanced support for the ASC community and improved patient access to the care ASCs provide, even amidst a global pandemic. Recently, we adjusted our focus to three main areas.


Election Results


Changes initiated by this past Novem- ber’s election results have presented


new opportunities for ASCs in the year ahead. As we kick off the year adapt- ing to the recent federal elections, our advocacy efforts will focus on the new opportunities presented by the election and changes in Congress.


Importance of Advocacy and the Virtual Tour Program The COVID-19 pandemic has impacted businesses across the country and the entire healthcare industry. Because of the countless challenges the coronavi- rus has presented, it is critical to fed- eral representatives to advocate for and leverage their support as the community strives to move forward while the pan- demic’s challenges continue.


ASC FOCUS JANUARY 2021 | ascfocus.org 15


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