Digital Debut
CMS Finalizes ASC-24 in 2025 Rulemaking
The agency also adds ASC-22 and ASC-23 to the ASCQR Program
BY KARA NEWBURY | APRIL 18, 2025
Editor's note: On April 11, the Centers for Medicare & Medicaid Services (CMS) released proposed 2026 updates to hospital inpatient payment rates and policies. Notably, CMS proposed immediate removal of several quality measures, including the Hospital Commitment to Health Equity measure, the hospital inpatient counterpart to ASC-24. ASCA expects that a similar proposal will be included in the CY 2026 Hospital Outpatient Prospective Payment System/ASC proposed rule, which will be released in early July 2025. If that does occur, ASCs will not be required to complete the ASC-24 attestation questionnaire.
In its 2025 ASC final payment rule, the Centers for Medicare & Medicaid Services (CMS) finalized three new health equity measures for addition to the ASC Quality Reporting Program. The three measures are ASC-22: Screening for Social Drivers of Health (SDOH), ASC-23: Screen Positive Rate for Social Drivers of Health (SDOH) and ASC-24: Facility Commitment to Health Equity (FCHE). ASC-24 is more time sensitive than the others, as facilities are supposed to work on the measure now for reporting in 2026.
Background
In the inpatient prospective payment system (IPPS) calendar year 2023 final rule, CMS added the new Hospital Commitment to Health Equity (HCHE) measure to the Hospital Inpatient Quality Reporting Program. Hospitals were first required to report on this measure in 2024, impacting 2025 payment determinations.
Without testing the measure in an outpatient setting, CMS swapped out the word “hospital” for “facility,” and added the FCHE measure to the ASCQR Program and the HCHE measure to the Hospital Outpatient Quality Reporting Program. Data is to be collected in 2025 and reported in 2026. Payment determinations for 2027 could be impacted by noncompliance.
Purpose
CMS indicates that ASC-24 “assesses facility commitment to health equity using a suite of equity-focused organizational competencies aimed at achieving health equity for racial and ethnic minority groups, people with disabilities, members of the lesbian, gay, bisexual, transgender, and queer (LGBTQ+) community, individuals with limited English proficiency, rural populations, religious minorities, and people facing socioeconomic challenges.”
The Agency for Healthcare Research and Quality and The Joint Commission identified that healthcare facility leadership “plays an important role in promoting a culture of quality and safety.”
Measure Specifications
Much of ASC-24 relies on the ASC having a strategic plan and incorporating health equity measures into that plan.
Facilities will attest to a commitment to advance health equity across five different domains. Facilities will receive one point for attesting to each of the five domains: equity is a strategic priority, data collection, data analysis, quality improvement and leadership engagement.
A few of the domains have multiple elements. A facility will need to attest affirmatively to all the elements within a domain to receive a point for that domain, which might be difficult for some facilities to achieve. For instance, the second domain, attesting to the facility’s data collection, requires the facility to input “demographic and/or social determinant of health information collected from patients in structured, interoperable data elements using an EHR technology.” Those ASCs without an electronic health record (EHR) technology will be unable to affirmatively attest to this domain.
When reporting, the denominator for each ASC is five, which represents the number of domains. The numerator is the number of domains to which the ASC can affirmatively attest. ASCs will report ASC-24 via the Hospital Quality Reporting portal, where several other ASCQR Program measures are already reported.
The ASCQR Program remains a pay for participation—not pay for performance—program. Therefore, even if your facility must attest “no” to one or more domain, you are not penalized as long as you report on the measure.
More information on the FCHE measure is available on the QualityNet site, including the measure specifications as well as attestation guidance. While ASCA will continue to raise concerns about these measures, the FCHE measure is slated to go into effect for 2025 data collection, so facilities should proceed as if it is required until future rulemaking.
ASCA recently hosted a virtual session titled “ASC-24” as part of its 2025 Regulatory Series. This program—led by ASC Quality Collaboration Assistant Executive Director Becky Ziegler-Otis and Wausau Surgery Center Administrator Carmel Galster—provides simple, actionable steps to help guide you in understanding the various domains of ASC-24. The session is available to watch on demand. It is not eligible for continuing education credits.
ASCA is proactively requesting that all three health equity measures—ASC-22, ASC-23 and ASC-24—be removed from the ASCQR Program or at least suspended until such time that they are tested in the ASC setting. While we will not know for sure if we are successful until the 2026 final rule is released in early November, we are fairly confident that we will make headway on this in 2026 rulemaking due to the Trump administration’s public statements regarding similar initiatives.
Write Kara Newbury at knewbury@ascassociation.org with questions.