ASCQR Program Participation Remains High Among ASCs

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ASCQR Program Participation Remains High Among ASCs

Submit reconsideration request for the CY 2025 APU payment determination by March 17, 2025

BY KARA NEWBURY | DECEMBER 20, 2024

The Centers for Medicare & Medicaid Services (CMS) released the calendar year (CY) 2025 Ambulatory Surgical Center Quality Reporting (ASCQR) Program payment determination lists earlier this month. Of the 6,012 ASCs included in the release, 5,714 facilities will receive the full annual payment update (APU) for 2025. The other 298 ASCs required to participate did not meet all requirements for a full APU. That 298 number is down from 341 in 2024. ASCs that failed to submit data in 2024 are subject to a 2 percent penalty to their 2025 APU.

The ASCQR Program is a pay-for-participation program, not a pay-for-performance program. In other words, facilities are penalized for failure to report; they are not penalized based on any of the data that is reported.

Data Available

CMS now releases four different documents in PDF and Excel formats (number of ASCs per category in parentheses):

  1. ASCs required to participate meeting all requirements for full APU (3,973)
  2. ASCs required to participate not meeting all requirements for full APU (298)
  3. ASCs that reported even though they were not required to participate (319)
  4. ASCs that did not report and were not required to participate (1,422)

Participation Exemptions

ASCs with fewer than 240 Medicare fee-for-service (FFS) claims—Medicare primary and secondary payer—per year during an annual reporting period for a payment determination year are not required to participate in the ASCQR Program for the subsequent annual reporting period for that subsequent payment determination year. Consequently, their APU is not impacted.

In addition, ASCs newly designated as open are not required to participate. Newly designated as open means that the facility is open for four months prior to January 1 of the data collection period. For example, if an ASC was newly designated as open as of October 17, 2023, the ASC would begin collecting data in CY 2025 for the CY 2027 payment determination.

By the Numbers

CMS included 6,012 facilities in its data release, 4,271 of which were required to submit data in 2024 for 2025 payment determinations. The other 1,741 ASCs were not required to participate in the ASCQR Program for 2025 payment determinations. This is up from 1,340 that were exempt for 2024 payment determinations. Further analysis needs to be performed, but this could potentially be due to increases in the percentage of Medicare beneficiaries who are on Medicare Advantage plans instead of fee-for-service Medicare.

Of the facilities that were exempt from participation, 319 decided to participate anyway. ASCA will monitor this data to see if this number declines in future years due to the additional burden of new measures added to the program, such as ASC-15 a–e: Outpatient and Ambulatory Surgery Consumer Assessment of Healthcare Providers and Systems (OAS CAHPS) Survey, which requires use of an outside vendor for compliance.

All required ASCs participated in eight states—Alaska, Delaware, Iowa, Kentucky, Maine, New Hampshire, Rhode Island and Vermont—and the District of Columbia. In nine additional states, all but one required ASC participated. Besides the eight above with perfect participation, Massachusetts had the next highest participation rate, as 51 of 52 required ASCs submitted data in 2024 (98 percent).

Reconsideration Requests

A reconsideration request for the CY 2025 APU payment determination decision can be submitted if an ASC elects to appeal an adverse APU determination. Information on the process for requesting a reconsideration and access to the reconsideration request form are on the QualityNet website. The deadline to submit a reconsideration request to CMS is March 17, 2025.

For 2024, CMS initially announced that 361 facilities would be penalized. However, the APU documents updated in May 2024, after the reconsideration deadline, show that only 341 facilities were subject to penalties, indicating that 20 reconsideration requests were successful this year. More information on the ASCQR Program can be found on ASCA’s ASCQR Program page.

Write Kara Newbury for more information.