ASCAC Provides Recommendations to CMS on ASC Payment and Quality Issues
The Ambulatory Surgery Center Advocacy Committee Delivers Comment Letter to CMS Administrator Berwick on Proposed Changes to the ASC Payment System
Washington, D.C., August 27, 2010 –Today, the Ambulatory Surgery Center Advocacy Committee (ASCAC) delivered a letter to Donald Berwick, MD, Administrator of the Centers for Medicaid and Medicare Services (CMS) with comments on payment and quality issues related to ASCs in response to the agency’s proposed CY 2011 rule for ASC payments.
In the letter, the ASCAC provides several recommendations to Administrator Berwick to halt further divergence in the payment rates for ambulatory surgery centers (ASCs) and hospital outpatient departments (HOPDs). Additionally, the ASCAC urges CMS to include ASCs in conversations to shape the Secretary’s report on a value-based purchasing program (VBP) for ASCs as mandated in the Patient Protection and Affordable Care Act (PPACA).
ASCs are often the lowest price setting for important surgical procedures for patients and payors. In fact, when Medicare beneficiaries chose ASCs for their care, they save on average 50 percent in out-of-pocket costs, and the Medicare program saves approximately 43 percent. However, over the past several years, ASC industry growth has slowed and in 2009, the volume of surgical procedures performed in ASCs declined for many common ASC services.
The proposed CY 2011 payment rule fails to fully align the payment system, which will continue to stymie industry growth. Stunting industry growth jeopardizes patients’ access to vital screening and diagnostic services, such as colonoscopies—a service for which the government advocates increased utilization. Absent appropriate payment policies, capacity in ASCs for these important services will not keep pace with demand, ultimately driving these services to return to less-efficient, higher-priced settings.
“CMS has the authority to make incremental changes to the Medicare program to better align the ASC and HOPD payment systems,” said Andrew Hayek, Chair of the Ambulatory Surgery Center Advocacy Committee and President and CEO of Surgical Care Affiliates. “Such changes will facilitate stability across the industry, improve beneficiary access, and encourage the continued migration of procedures into the least costly, clinically appropriate setting.”
Closing the Payment Gap
In the comment letter, the ASCAC details several recommendations to better align payment systems, including the adoption of the hospital market basket for ASCs, the same factor used to update payments under the outpatient prospective payment system. ASCs remain the only healthcare facilities whose Medicare payment increases are based on the Consumer Price Index for all Urban Consumers (CPI-U), a poor proxy for rising ASC costs, as the CPI-U measures inflation for goods and services purchased by consumers, based largely on prices for energy and housing.
As a result, the payment gap between ASCs and HOPDs continues to diverge, resulting in a system that pays drastically more to HOPDs for identical services. Payments over the last seven years have fallen from 86 to 57 percent. Under the 2011 CMS proposed rule for ASC services, ASC rates will drop below 57 percent of the hospital rate.
Following the Medicare Payment Advisory Commission’s (MedPAC) annual report to Congress earlier this year, which acknowledged the CPI-U as an inaccurate mechanism for updating ASC payments, 23 Senators sent a letter to CMS urging the agency to update ASC payments using the hospital market basket.
Creating a Value-Based Purchasing Program
ASCs support the implementation of a Medicare VBP program that begins with building a reliable, voluntary quality reporting infrastructure for ASCs and ultimately allows for the comparison of patient care data across all health care settings. Such a program would create competition in the health care system based on quality and efficiency, drive improvement in care, and improve transparency across all outpatient surgery providers. Increased transparency of quality and pricing information will also ensure that patients and their providers have access to important information when making decisions on where to receive health care.
“We believe that ASCs provide excellent care, have superior outcomes and extremely low infection rates,” Hayek added. “Creating a VBP program and aligning the payments across ASCs and HOPDs would create competition in the health care system that is based on quality and efficiency, and ensure that ASCs have the resources, including new technologies and enhanced reporting systems, needed to continue providing Americans access to high-quality care.”
Click here to read the full comment letter to Administrator Berwick.
About the Ambulatory Surgery Center Advocacy Committee
Ambulatory Surgery Centers are health care facilities that specialize in providing important surgical and preventive services in an outpatient setting. With approximately 5,300 Medicare-certified facilities throughout the country, ASCs perform more than 25 million surgeries per year. The Ambulatory Surgery Center Advocacy Committee is working on behalf of the industry to raise awareness of the important role that ASCs play in the health care system and the high-quality, cost-effective care that ASCs provide. The ASCAC includes the national and state ASC associations as well as representatives of all types of ASC operators and physicians. For more information about ASCs, visit www.advancingsurgicalcare.com.
Media Contact:
Kay Tucker, ASC
(703) 836-8808
ktucker@ascassociation.org
