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ASCA Submits Comments in Response to IPPS Payment Rule

Monday, June 19, 2017   (0 Comments)
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June 15, ASCA Government Affairs Update

 

ASCA has submitted formal comments in response to the 2018 Inpatient Prospective Payment System (IPPS) proposed rule released in April by the Centers for Medicare & Medicaid Services (CMS). The provisions addressed in the comments include:

 

Electronic Health Record (EHR) Technology Exception for ASC-Based Physicians: Section 16003 of the 21st Century Cures Act, legislation enacted last year, provides that no payment adjustment may be made to physician payments for 2017 and 2018 in the case of an eligible professional (EP) who furnishes substantially all of his or her covered professional services in an ambulatory surgical center (ASC). CMS proposed two possible definitions for an ASC-based EP:

  • An EP who furnishes 75 percent or more of his or her covered professional services in sites of service identified by the codes used in the HIPAA standard transaction as an ASC setting in the calendar year that is two years before the payment adjustment year. The percentage of covered professional services in this proposed definition is the same as the definition of a hospital-based MIPS eligible clinician under the Quality Payment Program (414.1305 and 81 FR 77238 through 77240).
  • An EP who furnishes 90 percent or more of his or her covered professional services in sites of service identified by the codes used in the HIPAA standard transaction as an ASC setting in the calendar year that is two years before the payment adjustment year.

ASCA supported the lower 75 percent threshold, consistent with the hospital-based EP threshold, and recommends CMS finalize this as part of the ASC-based EP definition in the final rule. However, the larger issue for EPs who practice in ASCs has been CMS’ interpretation that ASC encounters are currently being included in the denominator when determining whether an EP is a “meaningful user” of CEHRT. Given that no CEHRT exists for the ASC setting, this means that EPs who do more than 50 percent of outpatient encounters in an ASC could face payment reductions. This impacts a much greater number of eligible providers, and we requested CMS clarify that since there is currently no CEHRT for ASCs, these encounters should not be counted in the denominator of any calculations that determine adequate use of CEHRT products.

 

Publication of Accrediting Organization (AO) Surveys: CMS is proposing to require AOs with CMS-approved accreditation programs to post final accreditation survey reports and acceptable plans of correction (PoCs) on a public facing website designated by the AO.

 

ASCA recommended that CMS withdraw the current proposal and instead bring together accreditation organizations, providers and suppliers, information technology experts, consumer research groups and others with expert knowledge of access to data available in the health care industry to assist CMS with identifying and developing opportunities for providing consumers with the appropriate data to support transparency and decision making.

 


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