Vice President of Clinical Strategies
The Centers for Medicare & Medicaid Services (CMS) finalized its 2023 payment rule. Here are a few takeaways.
With regards to the Ambulatory Surgical Center Quality Reporting (ASCQR) Program, CMS finalized its proposal to suspend the mandatory adoption of ASC-11: Cataracts: Improvement in Patient’s Visual Function within 90 Days Following Cataract Surgery in the ASCQR Program. ASCA has been strongly advocating for this measure to remain voluntary.
The Good (ish)
- An effective update of 3.8 percent. This is a combination of a 4.1 percent inflation update based on the hospital market basket and a productivity reduction of 0.3 percentage points mandated by the Affordable Care Act. This is an increase of 1.1 percent from the proposed rule. Not the win hoped for but better than expected.
- The rule states CMS will continue to pay separately for Omidria, Exparel, and Xaracoll but not for Zynrelef. Dextenza and Posimir have received separate payment statuses.
- ASCA proposed a list of 47 procedures to CMS to be added to the ASC Covered Procedures List (ASC-CPL). These procedures can all be safely performed on non-Medicare populations in the ASC setting. Despite their detailed submission, CMS added only four of the requested codes:
- 19307 (Mast mod rad)
- 37193 (Rem endovas vena cava filter)
- 38531 (Open bx/exc inguinofem nodes)
- 43774 (Lap rmvl gastr adj all parts)
- They also pushed back the new process for requesting additions to the ASC list, which would have given transparency to the decisions to exclude requested procedures.
CMS sought comment to explore how ASCs are implementing tools in their facilities toward the goal of interoperability. They are considering the usefulness of electronically submitted quality measures (eCQM) in ASCs to aid in delivering effective, safe, efficient, patient-centered, equitable, and timely care. It would also increase alignment across quality reporting programs such as the Hospital OQR Program, which adopted some eCQM in the CY 2022 OPPS/ASC final rule.
CMS was interested in learning about the capabilities for reporting such measures in the future for the ASCQR Program. They sought input on the following:
- Barriers to interoperability in the ASC setting
- The impact of health IT, including health IT certified under the ONC Health IT Certification Program, on the efficiency and quality of health care services furnished in ASCs.
- The ability of ASCs to participate in interoperability or EHR-based quality improvement activities, including the adoption of eCQMs.
- What do ASCs perceive as the benefits or risks of implementing interoperability initiatives in their facilities?
- What improvements might be possible with the implementation of 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 practices?
As you can imagine, there were supporters and detractors. The concern around the financial and administrative burden of implementing an EHR was mentioned, along with the lack of federal financial incentives. Some commenters recommended a gradual, phased approach with potentially a hybrid model of both eCQMs and standard submission. One commenter suggested that CMS conduct an environmental scan to assess the current adoption of EHRs in the ASC setting. A few commenters recommended developing and using health information technology, expanding past EHRs, to create a patient care pathway so that digital data can be shared across all patient care experiences. This would provide access to a complete and comprehensive healthcare record which could improve patient satisfaction, patient outcomes, and affordability of care. One commenter recommended that CMS consider using non-certified EHRs to encourage innovation and provide EHR systems to smaller provider groups that otherwise would be financially and resourcefully burdened. CMS will take all comments under consideration for future rulemaking.
What do we collect in 2023?
The quality measures for collection in 2023 are as expected. ASC 1-4 will now be reported with the other measures and not claims-based as they were previously.
- ASC-1 0263 Patient Burn
- ASC-2 0266 Patient Fall
- ASC-3 0267 Wrong Site, Wrong Side, Wrong Patient, Wrong Procedure, Wrong Implant
- ASC-4 0265 All-Cause Hospital Transfer/Admission
- ASC-9 0658 Endoscopy/Polyp Surveillance: Appropriate Follow-Up Interval for Normal
- Colonoscopy in Average-Risk Patients
- ASC-12 2539 Facility 7-Day Risk-Standardized Hospital Visit Rate after Outpatient Colonoscopy (Data collected via claims)
- ASC-13 Normothermia Outcome
- ASC-14 Unplanned Anterior Vitrectomy
- ASC-17 3470 Hospital Visits after Orthopedic Ambulatory Surgical Center Procedures (Data collected via claims)
- ASC-18 3366 Hospital Visits after Urology Ambulatory Surgical Center Procedures (Data collected via claims)
- ASC-19 3357 Facility-Level 7-Day Hospital Visits after General Surgery Procedures Performed at Ambulatory Surgical Centers (Data collected via claims)
- ASC-20 COVID-19 Vaccination Coverage Among Health Care Personnel
- ASC-11 measure is voluntarily collected, as set forth in the CY 2015 OPPS/ASC final rule (79 FR 66984 through 66985). This measure was previously finalized as mandatory for the CY 2025 program year as set forth in the CY 2022 OPPS/ASC final rule is being finalized as voluntary in this final rule.
- ASC-15a The Consumer Assessment of Healthcare Providers and Systems Outpatient and Ambulatory Surgery Survey (OAS CAHPS)
No real surprises this year. As always, we will keep an eye on what CMS might propose for 2024!
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