There are 10 measures eligible Medicare- certified facilities must report to avoid Medicare payment reductions in 2020. As a reminder, ASCs that have fewer than 240 Medicare claims—primary plus secondary payer—per year during a reporting period for a payment determination year are not required to participate in the ASCQR Program for the subsequent reporting period for that subsequent payment determination year. This includes all program requirements, both claims-based measures and measures entered via a web-based tool.
Here is a breakdown, by measure, of what is required.
ASCs must continue to report on measures ASC-1: Patient Burn, ASC-2: Patient Fall, ASC-3: Wrong Site/Side/ Patient/Procedure/Implant and ASC- 4: Hospital Admission/Transfer. These claims-based measures are entered as G-codes on the CMS-1500 claim form. Results are reported as a rate per 1,000 cases. Nationwide, performance on these measures is extremely high, and ASCs even saw improvement for all four measures between 2015 and 2016.
CMS may eventually determine ASCs have “topped out” on these measures, meaning there is little room for improvement. This is why ASC-5: Prophylactic Intravenous (IV) Antibiotic Timing and ASC-6: Safe Surgery Checklist Use were removed from the ASCQR Program.
ASC-8: Influenza Vaccination Coverage among Healthcare Personnel data collection will take place for the influenza season between October 1, 2018, and March 31, 2019, with a reporting deadline of May 15, 2019. To report ASC-8 through the National Healthcare Safety Network (NHSN) as required, someone from your ASC must be registered with NHSN.
Failure to report on this measure continues to be the number one reason facilities do not receive their full payment update. Compliance has improved slightly, up from 74.62 percent in 2014– 2015 to 77.54 percent in 2016–2017. From a CMS perspective, there is still room for improvement. On a recent webinar, CMS contractors indicated that the main issues impacting successful reporting are: facility not enrolled in time; staff turnover; incorrect or missing CMS Certification Number (CCN); and a failure to add a reporting plan for the current flu season.
ASC-9: Endoscopy/Polyp Surveillance: Appropriate Follow-Up Interval for Normal Colonoscopy in Average Risk Patients and ASC-10: Endoscopy/ Polyp Surveillance: Colonoscopy Interval for Patients with a History of Adenomatous Polyps – Avoidance of Inappropriate Use are web-based measures that are reported via QualityNet. This aggregate data must be reported by all Medicare- certified ASCs, regardless of specialty or case mix. If your center does not perform colonoscopies, for both ASC-9 and ASC-10 you will enter “0” in the numerator and the denominator.
The percentage of patients receiving appropriate recommendation for followup screening colonoscopy, as captured with ASC-9, declined from 80.98 percent in 2015 to 77.78 percent in 2016. On the webinar discussing reporting issues, CMS contractors indicated that facilities had problems with: appropriate documentation of a medical reason for exclusion; exclusion regarding the age of the patient; and lack of documentation regarding the follow-up interval.
The Specifications Manual was updated to provide clarity on some of these points; that documentation of medical reason(s) for not recommending at least a 10-year follow-up interval could include cases of inadequate prep, familial or personal history of colonic polyps, patients with no adenoma and age greater than 66 years old or life expectancy of less than 10 years. Medical reason(s) are at the discretion of the physician. Documentation indicating no follow-up colonoscopy is needed or recommended is only acceptable if the patient’s age is documented as at least 66 years old or life expectancy is less than 10 years.