ASCA has created multiple draft comment letters for the various aspects of the proposed rule that ASCs can customize and submit to CMS, including:
- requesting that CMS remove the secondary rescaling that is applied to ASC, a policy that contributes to the growing disparity in reimbursement rates between ASCs and hospital outpatient departments (HOPDs);
- providing support for CMS’ proposal to add total knee arthroplasty to the ASC-payable list;
- providing support for CMS’ proposal to add more cardiology codes to the ASC-payable list; and
- requesting codes be added to the ASC-payable list.
The most persuasive letters will include your individual details regarding how the proposed changes will impact your center. Letters should also include specific information such as your center's case volume and outcomes data, if available. Please copy and paste the comment letter into your center's own letterhead.
Comments, to be submitted online, are due Friday, September 27 at 11:59 pm ET.
ASCA and its members have made significant progress recently advocating for Medicare policies that benefit ASCs. The Centers for Medicare & Medicaid Services (CMS) has added 58 procedures to the ASC-payable list in the past five years. Last year, after asking for feedback regarding the safety of procedures that were added to the ASC-payable list within the three calendar years prior to the rule-making year 2015–2017, CMS decided to keep these codes on the ASC covered procedure list. The list of codes evaluated included several spine codes being done in ASCs. ASCA and its members provided compelling information showing that these codes could be safely performed in ASCs.
One of ASCA’s most significant wins came last year, when CMS finalized its proposal to align update factors and moved ASCs to the hospital market basket which has long been used to update hospital outpatient department (HOPD) payments. CMS has indicated it will continue to use the hospital market basket to update ASC payments for the five-year period of calendar year (CY) 2019 through CY 2023.
These and many other positive developments would not have been possible without the support and input from ASCA members.
For more information, write Kara Newbury.