This Week in Surgery Centers: Navigating Changes in the CMS 2024 Proposed Payment Rule for ASCs

Here’s what to expect on this week’s episode. 🎙️

The CMS 2024 Proposed Payment Rule was officially released a few weeks ago. The 963-page document outlines the potential changes CMS is considering for 2024, and stakeholders have 60 days to respond and comment on the proposal. Once finalized, the rule will become official and will guide how Medicare and Medicaid operate in 2024. Here are a few highlights:

💰 On average, surgery centers would see an effective update of 2.8% over all covered procedures. For some procedures, including cataracts, GI, and pain, the payment update is closer to 5.5% (variations will occur).

🔢 ASC Quality Reporting Program
• ASC-7: ASC Facility Volume Data – voluntary collection will start in 2025 and mandatory collection in 2026.
• ASC-9: Endoscopy/Polyp Surveillance – will be modified by changing the denominator from 50 to 45 years old.
• ASC-11: Cataracts Visual Functions – will remain voluntary.
• ASC-20: COVID-19 Vaccination Coverage Among Health Care Personnel – will continue to be required.
• ASC-21: Risk-Standardized Patient-Reported Outcome-Based Performance Measure (PRO-PM) – will be a new measure.

😡 Despite several requests from ASCs and ASCA, CMS has added only one of the sixty-three requested codes, G0330 Dental Rehabilitation, to the Covered Procedures List.

🗣 All members of the surgery center industry are strongly encouraged to submit feedback to the Centers for Medicare & Medicaid Services by September 11, 2023, to help shape future policies that will affect the industry directly.

Thank you to Maura Cash, William Prentice, Kara Newbury, and the Ambulatory Surgery Center Association for their industry expertise and guidance!

Submit comments to CMS: https://www.regulations.gov/document/CMS-2023-0120-0002

Find the full episode on Apple Podcasts, Spotify, or YouTube to hear all the details.

0:00
welcome to this week in surgery centers
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if you’re in the ASC industry then
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you’re in the right place every week
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we’ll start the episode off by sharing
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an interesting conversation we had with
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our featured guest and then we’ll close
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the episode by recapping the latest news
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impacting surgery centers we’re excited
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to share with you what we have so let’s
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get started and see what the industry’s
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been up to
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[Music]
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hi everyone here’s what you can expect
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on today’s episode in this week’s show
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we are deviating from our regular guest
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discussions and stories to exclusively
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dive into the CMS 2024 proposed payment
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rule more cash is our VP of clinical
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strategies here at HST Pathways and she
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has examined the extensive
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963-page document extracting The Good
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the Bad and the mixed proposed rules
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that directly impact the surgery center
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industry
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and of course in my Noble quest to leave
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no stone unturned here I also
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Incorporated feedback from additional
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industry experts such as Bill Prentice
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and Karen Newberry from ASCA the
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potential changes range from payment
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updates to new additions to the covered
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procedures list to New Quality Reporting
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measures so there’s a lot to unpack here
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and I’m really excited to share it all
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with you
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I hope everyone enjoys the episode and
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here’s what’s going on this week in
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surgery centers
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[Music]
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as always it has been a busy week in
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healthcare so let’s Jump Right In okay
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as most of you know the CMS proposed
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payment rule is a document released by
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CMS that outlines the potential changes
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they are considering for the rules and
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regulations related to Medicare and
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Medicaid programs
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the proposed rule is a set of ideas and
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suggestions that the organization puts
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forward for discussion and feedback from
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the public and other stakeholders
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it’s basically like a draft or a plan
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that they’re considering implementing in
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the future
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so after the proposed rule comes out
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said stakehold stakeholders have 60 days
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to respond and after receiving public
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comments and considering various factors
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CMS will then review and possibly modify
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the proposed rule before considering it
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final and then once finalized the rule
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becomes official and will guide how
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Medicare and Medicaid operate in 2024.
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let’s start with the good for what
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they’re proposing for 2024.
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the most important update that’s on
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everyone’s mind is always the payment
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update and for once everyone is looking
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at this as a win for surgery centers on
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average ASCS would see an effective
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update of 2.8 percent over all covered
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procedures this is a combination of a
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three percent inflation update based on
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the hospital Market Basket and a
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productivity reduction mandated by the
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Affordable Care Act of 0.2 percentage
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points now just a reminder that some
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updates might vary significantly by code
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and Specialty and in this case that
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variation is actually a really good
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thing Cara Newberry from ASCA shared
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that for the top 10 codes by volume that
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actually cover 55 percent of procedures
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which are primarily cataract GI and pain
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procedures the payment update will
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actually be 5.5 percent instead of that
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2.8 percent so for once this update
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could really work within the industry’s
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favor
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another positive update would be for ASC
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11 cataracts visual functions although
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the measure will remain voluntary CMS
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proposed to specify assessment tools use
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pre and post-surgery they hope this will
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promote standardized patient care and
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improve overall outcomes they also are
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proposing to allow the center to
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administer the assessment tool
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themselves and not so they don’t have to
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rely on the physician’s office to
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provide the data
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and lastly falling into the good column
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it is proposed that asc9 endoscopy polyp
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surveillance be modified by changing the
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denominator to 50 to 45 years old to
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better align with current clinical
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guidelines as it may improve early
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detection of colon issues so ASE should
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really consider the implications of
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these changes on their patient
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population and resources
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okay Switching gears to the mixed so CMS
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has proposed reintroducing ASC 7 ASC
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facility volume data with voluntary
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collections starting in 2025 and
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mandatory collection in 2026. it will
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require reporting on the top five
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procedures in eight different areas so
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while this measure can absolutely
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provide valuable insights into a
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surgical procedure volumes in ases it’s
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important to evaluate this changes
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implementation and potential reporting
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burden which that whole idea of
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the burden of reporting will just
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continue to increase as this goes on but
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just something to keep in mind that for
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facility volume data mandatory in 2026
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so might want to start preparing soon
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another mixed item CMS proposed a new
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measure called ASC 21 risk standardized
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patient reported outcome-based
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performance measure or shortened to Pro
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hyphen pm
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so this measure could be seen as mixed
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could be seen as bad it all just depends
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on how you look at it but this measure
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would require surgery centers to collect
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data from patients 0 to 90 days pre-op
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and also 300 to 425 days post-op
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so it feels a little burdensome but the
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positive is that this data could really
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be valuable and Powerful in documenting
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the quality of care that is offered at
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ASCS by measuring outcomes
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the negative obviously is that it can
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become extremely burdensome to ASCS
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especially those who don’t currently
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invest in data collection and Analysis
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and don’t use an outside vendor to help
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collect those data points the work
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involved and the potential cost of
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implementing this measure along with the
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mandatory collection of OAS caps and
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other measures coming down the line
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really May overburden centers so
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the theme in the last couple years with
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all these proposed Rule and the final
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payment rules is that CMS wants more and
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more and more data and if you don’t have
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a plan in place to collect it easily
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consistently in a reportable and usable
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way it’s not going to be pretty so again
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strongly recommend because this measure
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specifically requires you to collect
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data 0 to 90 days pre-op so you have to
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have a system in place to be able to
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hopefully automate this and then also
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300 to 425 days post-op as well so you
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got to get your systems in place
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automate this as much as you possibly
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can
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lastly if we want to switch to the not
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so good updates for ASCS
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okay the most frustrating part of the
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proposed payment rule is obviously the
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extremely limited nearly non-existent
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edition of procedure codes
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so despite several requests from ASCS
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and ask a CMS has only added one of the
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63 requested codes and it’s
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g0330 Dental Rehabilitation that’s the
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only one that they’ve added to the list
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of procedures that can be performed
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safely in ASCS
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so this limited inclusion is obviously a
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huge disappointment for ASCS as it
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restricts the ability to offer a broader
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range of services to patients and of
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course limits revenue and case volume
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opportunities and what’s most
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frustrating as always is that ASCS have
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a proven track record of Performing
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these procedures consistently safely and
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successfully especially when it comes to
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total knee total hip and total shoulder
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the other piece of this is that CMS is
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supposedly building an online process
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for stakeholders to submit new codes
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that they would like to see added and
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it’s supposed to launch January 1st 2024
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so less than six months away and that
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online system would allow people to
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submit any stakeholders can submit codes
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they would like to see in the 2025
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considerations so you don’t have to wait
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for this period the 60-day window we can
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get ahead of it it and try to get these
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codes to them as soon as possible anyway
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there was no mention of this online
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submission process in the proposed rule
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at all so not only did we get cited with
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this one dental code being added but you
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know they doesn’t seem like they’re
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holding true to their word that there
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will be an online portal available so it
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will be easier to submit codes in the
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future now of course the final rule
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could come out and they could have a
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whole section on this online portal we
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will definitely keep a close eye on it
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but hopefully that will change in the
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near future
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and lastly CMS has proposed to continue
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requiring the reporting of ASC 20 which
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is the covid-19 vaccination coverage
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among Healthcare Personnel measurement
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so while maintaining this measure
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obviously showcases cms’s commitment to
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combating the pandemic ase’s continue to
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face challenges in tracking and
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Reporting vaccination data aska has been
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opposed to this measure from the
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beginning but as a compromise you know
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ASCA has recommended this but CMS can
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consider a less rigorous time frame for
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compliance such as reducing the
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reporting requirements to once a year
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and that would at least help ease the
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bird in for centers and kind of meet in
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the middle on this one
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so again it is a 963 page document those
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are just a handful of items that we
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definitely wanted to bring to your
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attention and the proposed changes
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certainly fall all over the spectrum of
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positive to negative
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and if you do want to share your
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thoughts with CMS and I strongly suggest
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that you do aska will be providing
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templates to members to make it super
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easy for you to do so and one final
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reminder that it is essential for people
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in organizations involved in the
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industry to review the proposal provide
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their opinions and engage in the public
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comment process so that we can help
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shape the future policies that will
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affect the industry directly again thank
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you to more cash from HST and Bill
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Prentice and Karen Newberry from ASCA
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for making this recap super easy and
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kind of pulling out the most important
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proposed changes that we want everybody
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to be aware of
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and that officially wraps up this week’s
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podcast thank you as always for spending
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a few minutes of your week with us make
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sure to subscribe or leave a review on
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whichever platform you’re listening from
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I hope you have a great day and we will
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see you again next week
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why are you keeping me
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[Music]