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ASCA Submits Comments on CMS Proposed Payment Rule

Monday, September 11, 2017   (0 Comments)
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September 7, ASCA Government Affairs Update

Today, ASCA submitted its formal comments in response to the Centers for Medicare & Medicaid Services (CMS) 2018 proposed payment rule, which, among other payment policies, proposes the reimbursement rates for the coming year.

Under CMS’ proposal, ASC rates would receive an across-the-board increase of 1.9 percent based on the Consumer Price Index for All Urban Consumers (CPI-U). While this is slightly higher than the hospital outpatient departments (HOPDs) effective increase of 1.75 percent, that is only due to a 0.75 percent reduction that is mandated for hospitals under the Affordable Care Act (ACA). The hospital market basket update, on which the HOPD update is based, is 2.9 percent. Along with other payment policy issues impacting ASC payments, such as a secondary rescalar, this year’s payment updates continue the troubling trend of diverging payments. As in previous years, we proposed that CMS align the two update factors to prevent a continuing divergence in payment rates by using the hospital market basket to determine the update factor for ASCs.

In addition to the revised rates, the agency proposed to add three new procedures to the ASC list of payable procedures for 2018. While ASCA appreciates that CMS has acknowledged that these procedures are safe and effective when done in the ASC setting, we recommended CMS allow all procedures that are payable in the HOPD setting to also be payable in the ASC setting. There are currently 345 surgical codes which are reimbursable when performed in the HOPD but not the ASC.

ASCA further responded to a CMS request for comments by asking that CMS remove three joint replacement procedures (total knee, partial hip and total hip) from the Medicare inpatient-only list. ASCA believes that these procedures fully meet CMS’ criteria for performance in an outpatient setting, and gives patients and surgeons the greatest flexibility in determining the appropriate site of service.

Finally, CMS proposed to indefinitely delay mandatory implementation of the Consumer Assessment of Healthcare Providers and Systems Outpatient and Ambulatory Surgery (OAS CAHPS) survey. While ASCA strongly supports the proliferation of quality measures that demonstrate the excellence of care in ASCs, we have strong concerns regarding the efficacy of the OAS CAHPS survey in its current format and appreciate CMS reconsidering their January 1, 2018, mandatory implementation date. ASCA requested that the survey be shortened and that an electronic survey mode be made available.

For more information, please contact Kara Newbury at

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