In the 2016 proposed payment rule for ambulatory surgery centers (ASCs) and hospital outpatient departments (HOPDs), the Centers for Medicare & Medicaid Services (CMS) is proposing a 1.1% effective rate update for ASCs.
“If the proposed rule were to be finalized as drafted, ASCs would see an effective update of 1.1% — a combination of a 1.7% inflation update based on CMS’s estimation of the change in Consumer Price Index for All Urban Consumers (CPI-U) and a productivity reduction mandated by the Affordable Care Act of 0.6 percentage points,” the ASC Association (ASCA) said in a statement. “However, CMS does not take into account sequestration in its proposed rule. This statutory 2% reduction remains in effect until at least 2024 unless Congress acts.”
ASCA CEO Bill Prentice said, “Unfortunately, the proposed rule and continued use of the CPI-U to update ASC reimbursements offers more evidence of CMS’ unwillingness to recognize that the agency must do more to actively promote ASCs as a high quality, efficient provider of outpatient care for America’s seniors if we are to survive and thrive in the future.”
For HOPDs, the effective rate update would be 1.9%, ASCA said. Under the rule, there would be a net decrease in outpatient prospective payment system (OPPS) payments of 0.2%, according to the American Hospital Association (AHA). “This net decrease largely results from a proposed 2.0 percentage point cut intended to account for CMS’s overestimation of the amount of packaged laboratory payments under the OPPS for laboratory tests that were previously paid under the Clinical Laboratory Fee Schedule,” the AHA said.
AHA Executive Vice President Rick Pollack expressed disappointment with the negative update and said the AHA was “dismayed that miscalculations by the actuaries are resulting in penalties to hospitals and the patients they care for.” He urged CMS to reevaluate the actuaries’ estimates.
The conversion factor would be $44.605 for ASCs and $73.929 for HOPDs.
In addition, CMS proposes to alter its two-midnight policy so that certain hospital inpatient services that do not cross two midnights might be appropriate for payment under Medicare Part A if a physician determines and documents in the patient’s medical record that the patient requires reasonable and necessary admission to the hospital as an inpatient, the AHA says. A fact sheet about the two-midnight rule can be downloaded at http://go.cms.gov/1R5vlhF.
Pollack called the proposals a “good first step” and said hospitals “appreciate today’s proposal to maintain the certainty that patient stays of two midnights or longer are appropriate as inpatient cases.” However, he expressed dismay that CMS did not propose to withdraw the 0.2% cut, and he urged the agency to extend the partial enforcement delay beyond Sept. 30.
CMS has proposed that all web-based measures in the ASC Quality Reporting Program be reported by May 15 each year. Currently, the deadline for ASC-8 (Influenza Vaccination Coverage among Healthcare Personnel) is May 15, although the deadline was extended only for 2015. (See “ASC-8 reporting deadline moved,” Same-Day Surgery, August 2015.)
According to CMS, aligning the dates “would allow for earlier public reporting of measure data and reduce the administrative burden for ASCs associated with tracking multiple submission deadlines for these measures.”
The deadline for the following quality measures this year is Sept. 30, based on information from ASCA:
- ASC-6, Safe Surgery Checklist Use;
- ASC-7, ASC Facility Volume Data on Selected ASC Surgical Procedures;
- ASC-9, Endoscopy/Poly Surveillance: Appropriate Follow-Up Interval for Normal Colonoscopy in Average Risk Patients;
- ASC-10, Endoscopy/Poly Surveillance: Colonoscopy Interval for Patients with a History of Adenomatous Polyps – Avoidance of Inappropriate Use.
For more information on the extension, go to http://bit.ly/1g5LgvJ.
CMS is not proposing to add any new measures to the ASC Quality Reporting Program for the coming year.
The agency is proposing to use Quality Improvement Organizations to conduct first-line medical reviews of most patient status claims rather than Medicare administrative contractors or recovery audit contractors, which would focus only on those hospitals with consistently high denial rates. “However, CMS does not propose to reverse the 0.2% payment cut associated with the two-midnight policy,” the AHA said.
To access the rule, go to http://bit.ly/1H0tZx1. Comments will be accepted until 5 p.m. ET on Aug. 31, 2015.
Download a fact sheet at http://go.cms.gov/1R5EHde.