Vice President of Clinical Strategies
CMS released their Proposed Payment Rule for 2023 last month. As you can imagine, the 886 page document is complex to say the least, and includes some good, bad, and unexpected updates for the ASC industry. Here are a few highlights.
The Good.
ASCs remain in the hospital basket for rate increase evaluation.
As expected, ASCs remain in the hospital basket for rate increase evaluation. The payment rates under the ASC payment system will be raised by 2.7 percent for ASCs that meet the quality reporting requirements under the ASCQR Program. Although we may have made out better due to inflation this year, we are still best served grouped with the hospitals.
The quality measure “ASC-11: Improvement in Patient’s Visual Function within 90 Days Following Cataract Surgery” will be changed from mandatory to voluntary.
We breathe a sigh of relief as the quality measure ASC-11: Improvement in Patient’s Visual Function within 90 Days Following Cataract Surgery will be changed from mandatory to voluntary. It will continue to be a voluntary measure moving forward. All other quality measures for 2023 will remain the same. It would have been exceedingly difficult to obtain that information from patients and provider offices, and there is no consistency in the pre/post surveys taken by cataract patients.
The Bad.
Only one procedure has been added to the ASC CPL: a lymph node biopsy or excision.
Disappointingly, only one procedure has been added to the ASC Covered Procedures List (CPL): a lymph node biopsy or excision. This is a disappointment considering the positive data submitted on behalf of many procedures. Also, the new submission method for adding procedures to the ASC CPL has been delayed until January 2024. The previous method of submission will continue until that time. Unfortunately, many of the procedures recommended this year through the current process have not been approved. The delay may cause a continued slow trickle of new procedures approved for the ASC space.
The Unexpected.
A “Request for Comment” has been made for a potential future specialty-centered approach for the ASCQR.
A Request for Comment has been made for a potential future specialty-centered approach for the ASCQR. Since many centers are single-specialty, this may allow for selective participation and better indicators of quality care in the ASCQR program. Provided these specialty measures are also collected in the HOPD setting, it could provide better benchmarking opportunities.
CMS has requested comments on interoperability initiatives in ASCs which would require EHR adoption.
CMS has requested comments on interoperability initiatives in ASCs (this would require EHR adoption.) Specifically, they would like to know what ASCs perceive as the benefits or risks of implementing interoperability initiatives in their facilities. What improvements might be possible with implementing interoperability initiatives in ASCs, including EHR utilization (reduced delays, efficiencies, ability to benchmark, etc.)? Do ASCs see interoperability initiatives as non-essential or detrimental to their business? ASCs have lagged in adopting EHRs since there are no mandates or incentives. This measure might be the push toward future participation that the industry has been waiting for.
Make Your Voice Heard.
It is essential for ASCs to participate in the feedback by submitting comments on this proposed rule at the link below instructions by September 13, 2022. We cannot complain about the outcome if we do not actively participate in the process! Go to https://www.regulations.gov and follow the “Submit a comment” instructions.
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