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Navigating Changes in the CMS 2024 Proposed Payment Rule for ASCs
107 Plays1 year ago
In this week's episode, we are deviating from our regular guest discussions and stories to exclusively dive into the CMS 2024 Proposed Payment Rule. Maura Cash, our VP of Clinical Strategies here at HST Pathways, has examined the extensive 963-page document, extracting the good, the bad, and the mixed proposed rules that directly impact the surgery center industry. Feedback from additional industry experts, such as Bill Prentice and Kara Newbury from ASCA, was also incorporated in the episode.
Helpful Articles to Learn More:
Navigating Changes in the CMS Proposed 2024 Payment Rule for ASCs by Maura Cash
Read ASCA’s Recap on the Proposed Payment Rule
Submit comments to CMS: https://www.regulations.gov/document/CMS-2023-0120-0002
Brought to you by HST Pathways.
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Transcript
Introduction to ASC Industry Resource
00:00:01
Speaker
Welcome to This Week in Surgery Centers. If you're in the ASC industry, then you're in the right place. Every week, we'll start the episode off by sharing an interesting conversation we had with our featured guests, and then we'll close the episode by recapping the latest news impacting surgery centers. We're excited to share with you what we have, so let's get started and see what the industry's been up to.
Focus on CMS 2024 Proposed Payment Rule
00:00:27
Speaker
Hi, everyone. Here's what you can expect on today's episode. In this week's show, we are deviating from our regular guest discussions and stories to exclusively dive into the CMS 2024 proposed payment rule.
Insights on Key Changes in CMS 2024
00:00:42
Speaker
Maura Cash is our VP of clinical strategies here at HST Pathways, and she has examined the extensive 963 page document
00:00:52
Speaker
extracting the good, the bad, and the mixed proposed rules that directly impact the surgery center industry.
00:00:59
Speaker
And of course, in my noble quest to leave no stone unturned here, I also incorporated feedback from additional industry experts such as Bill Prentice and Karen Newberry from ASCA. The potential changes range from payment updates to new additions to the covered procedures list to new quality reporting measures. So there's a lot to unpack here and I'm really excited to share it all with you.
00:01:24
Speaker
I hope everyone enjoys the episode and here's what's going on this week in Surgery Centers. As always, it has been a busy week in healthcare, so let's jump right in.
Draft Proposal and Comment Period
00:01:38
Speaker
Okay, as most of you know, the CMS proposed payment rule is a document released by CMS that outlines the potential changes they are considering for the rules and regulations related to Medicare and Medicaid programs. The proposed rule
00:01:54
Speaker
is a set of ideas and suggestions that the organization puts forward for discussion and feedback from the public and other stakeholders. It's basically like a draft or a plan that they're considering implementing in the future. So after the proposed rule comes out,
00:02:11
Speaker
Said stakeholders have 60 days to respond. And after receiving public comments and considering various factors, CMS will then review and possibly modify the proposed rule before considering it final. And then once finalized, the rule becomes official and will guide how Medicare and Medicaid operate in 2024.
Positive Payment Updates and New Measures
00:02:32
Speaker
Let's start with the good for what they're proposing for 2024. The most important update that's on everyone's mind is always the payment update. And for once, everyone is looking at this as a win for surgery centers.
00:02:48
Speaker
On average, ASEs would see an effective update of 2.8% over all covered procedures. This is a combination of a 3% inflation update based on the hospital market basket and a productivity reduction mandated by the Affordable Care Act of 0.2 percentage points. Now, just a reminder,
00:03:11
Speaker
that some updates might vary significantly by code and specialty. And in this case, that variation is actually a really good thing. Kara Newberry from ASCA shared that
00:03:23
Speaker
For the top 10 codes by volume that actually cover 55% of procedures, which are primarily cataract GI and pain procedures, the payment update will actually be 5.5% instead of that 2.8%. So for once, this update could really work within the industry's favor.
00:03:43
Speaker
Another positive update would be for ASC11 cataracts visual functions. Although the measure will remain voluntary, CMS proposed to specify assessment tools use pre and post surgery. They hope this will promote standardized patient care and improve overall outcomes. They also are proposing to allow the center to administer the assessment tool themselves so they don't have to rely on the physician's office to provide the data.
ASC7 Reintroduction and ASC21 Measure
00:04:13
Speaker
And lastly, falling into the good column, it is proposed that ASC-9 endoscopy polyp surveillance be modified by changing the denominator to 50 to 45 years old to better align with current clinical guidelines as it may improve early detection of colon issues. So ASC should really consider the implications of these changes on their patient population and resources.
00:04:40
Speaker
Okay, switching gears to the mixed. So CMS has proposed reintroducing ASC7, ASC facility volume data with voluntary collection starting in 2025 and mandatory collection in 2026.
00:04:57
Speaker
It will require reporting on the top five procedures in eight different areas. So while this measure can absolutely provide valuable insights into surgical procedure volumes and ASCs, it's important to evaluate this change's implementation and potential reporting burden, which that whole idea of
00:05:17
Speaker
The burden of reporting will just continue to increase as this goes on, but just something to keep in mind that for facility volume data mandatory in 2026, so might want to start preparing soon. Another mixed item, CMS proposed a new measure called ASC21, Risk Standardized Patient Reported Outcome-Based Performance Measure, or shortened to PRO-PM.
00:05:45
Speaker
So, this measure could be seen as mixed, could be seen as bad, it all just depends on how you look at it. But this measure would require surgery centers to collect data from patients 0 to 90 days pre-op and also 300 to 425 days post-op.
00:06:05
Speaker
So it feels a little burdensome, but the positive is that this data could really be valuable and powerful in documenting the quality of care that is offered at ASCs by measuring outcomes. The negative obviously is that it can become extremely burdensome to ASCs, especially those who don't currently invest in data collection and analysis and don't use an outside vendor to help collect those data points.
00:06:33
Speaker
The work involved in the potential cost of implementing this measure along with the mandatory collection of OAS caps and other measures coming down the line really may overburden centers. So the theme in the last couple of years with all these proposed rule and the final payment rules is that CMS wants more and more and more data.
00:06:54
Speaker
And if you don't have a plan in place to collect it easily, consistently, in a reportable and usable way, it's not going to be pretty. So again, strongly recommend because this measure specifically requires you to collect data zero to 90 days pre-op. So you have to have a system in place to be able to hopefully automate this and then also 300 to 425 days post-op as well. So you got to get your systems in place, automate this as much as you possibly can.
Limitations on Procedure Expansion
00:07:23
Speaker
Lastly, if we want to switch to the not so good updates for ASCs. Okay, the most frustrating part of the proposed payment rule is obviously the extremely limited, nearly non-existent addition of procedure codes.
00:07:39
Speaker
So despite several requests from ASCs and ASCA, CMS has only added one of the 63 requested codes and it's G0330 dental rehabilitation. That's the only one that they've added to the list of procedures that can be performed safely in ASCs.
00:08:01
Speaker
So this limited inclusion is obviously a huge disappointment for ASCs as it restricts the ability to offer a broader range of services to patients and, of course, limits revenue and case volume opportunities. And what's most frustrating, as always, is that ASCs have a proven track record of performing these procedures consistently, safely, and successfully, especially when it comes to total knee, total hip, and total shoulder.
00:08:31
Speaker
The other piece of this is that CMS is supposedly building an online process for stakeholders to submit new codes that they would like to see added. And it's supposed to launch January 1st, 2024, so less than six months away. And
00:08:49
Speaker
That online system would allow people to submit, any stakeholders can submit codes they would like to see in the 2025 consideration. So you don't have to wait for this period, the 60-day window. We can get ahead of it and try to get these codes to them as soon as possible. Anyway, there was no mention of this online submission process in the proposed rule at all.
00:09:10
Speaker
So not only did we get cited with this one dental code being added, but they doesn't seem like they're holding true to their word that there will be an online portal available so it will be easier to submit codes in the future. Now, of course, the final rule could come out and they could have a whole section on this online portal. We will definitely keep a close eye on it, but hopefully that will change in the near future.
Ongoing COVID-19 Data Reporting
00:09:37
Speaker
And lastly, CMS has proposed to continue requiring the reporting of ASC20, which is the COVID-19 vaccination coverage among healthcare personnel measurement. So while maintaining this measure obviously showcases CMS's commitment to combating the pandemic, ASCs continue to face challenges in tracking and reporting vaccination data.
00:10:01
Speaker
ASCA has been opposed to this measure from the beginning, but as a compromise, ASCA has recommended this, but CMS can consider a less rigorous timeframe for compliance, such as reducing the reporting requirements to once a year, and that would at least help ease the burden for centers and kind of meet in the middle on this one.
00:10:21
Speaker
So again, it is a 963 page document. Those are just a handful of items that we definitely wanted to bring to your attention.
Public Comments and ASCA Support
00:10:31
Speaker
And the proposed changes certainly fall all over the spectrum of positive to negative. And if you do want to share your thoughts with CMS, and I strongly suggest that you do, ASCA will be providing templates to members to make it super easy for you to do so.
00:10:47
Speaker
And one final reminder that it is essential for people and organizations involved in the industry to review the proposal, provide their opinions, and engage in the public comment process so that we can help shape the future policies that will affect the industry directly.
00:11:04
Speaker
Again, thank you to Maura Cash from HST and Bill Prentice and Karen Newberry from ASCA for making this recap super easy and kind of pulling out the most important proposed changes that we want everybody to be aware of.
Conclusion and Call to Action
00:11:19
Speaker
And that officially wraps up this week's podcast. Thank you as always for spending a few minutes of your week with us. Make sure to subscribe or leave a review on whichever platform you're listening from. I hope you have a great day and we will see you again next week.