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Comment Now on Medicare’s 2025 Proposed Rule

Use ASCA’s resources to make your voice heard

BY KARA NEWBURY | AUGUST 23, 2024

Submit your comments on the Centers for Medicare & Medicaid Services’ (CMS) 2025 proposed payment rule by September 9. ASCA will once again submit comments raising industry-wide concerns, but it is important that CMS hears from individual centers as well.

CMS released its 2025 proposed payment rule for ASCs and hospital outpatient departments (HOPD) on July 10. Of note, CMS concurred with ASCA’s request and proposed to continue to use the hospital market basket (HMB) to update ASC reimbursement rates, extending the five-year interim period an additional two calendar years (CY) through 2025. Since the HMB also is used to update HOPD reimbursements, its use for ASCs better aligns the ASC and HOPD payment systems. If the proposed rule were to be finalized as drafted, ASCs would see, on average over all covered procedures, an effective update of 2.6 percent, which is a combination of a 3.0 percent inflation update based on the HMB and a productivity reduction mandated by the Affordable Care Act of 0.4 percentage points.

CMS also proposed to add 20 medical and dental surgical procedures to the ASC Covered Procedures List (ASC-CPL) for CY 2025, as shown in Table 82 starting on page 574 in the rule.

Read ASCA's analysis of the proposed rule.

As a special member resource, ASCA staff have created template comment letters that can provide a starting point if you wish to submit comments. You can add your letterhead and customize it to your facility’s needs. Templates currently available can help you advocate for:

• Removal of the secondary rescaling applied to ASCs, a policy that contributes to the growing disparity in reimbursement rates between ASCs and HOPDs
• Additional codes to be added to the ASC Covered Procedures List (ASC-CPL)
• Removal of ASC-20 from the ASC Quality Reporting Program

ASCA’s proposed rule payment resources also include a Proposed Rule Rate Calculator that shows proposed national and local payment rates for 2025. You can select your state and county from the dropdown at the top and the calculator does the rest. ASCA also posted a 2025 Proposed Rule Analysis that identifies and summarizes the provisions of greatest interest to ASCs and a 2025 Proposed Rule Payment Resources document that provides separate worksheets for each group of codes, such as separately payable, office-based and device-intensive. All of ASCA’s Medicare-related resources for the current and previous years can be found on its Medicare Payment Resources webpage.

Write Kara Newbury at knewbury@ascassociation.org if you need help customizing a letter or have any questions. ASCA would like to track the number of its member comments, so please email her if you submit comments.