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Comment Now on Medicare’s 2024 Proposed Rule

Use ASCA’s resources to make your voice heard

BY KARA NEWBURY | SEPTEMBER 2023

Submit your comments for the Centers for Medicare & Medicaid Services’ (CMS) 2024 proposed payment rule by September 11. 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 2024 proposed payment rule for ASCs and hospital outpatient departments (HOPD) on July 13. Of note, CMS concurred with ASCA’s request and proposed to continue to align the ASC update factor with the one used to update HOPD payments, extending the five-year interim period an additional two calendar years (CY) through 2025. The agency also proposed: a 2.8 percent update on average over all covered procedures; the addition of 26 dental surgical codes to the ASC Covered Procedures List (ASC-CPL); readoption of ASC-7: ASC Facility Volume Data on Selected ASC Surgical Procedures with modification; adoption of ASC-21: Risk-Standardized Patient Reported Outcome-Based Performance Measure (PRO-PM) Following Elective Primary Total Hip Arthroplasty (THA) and/or Total Knee Arthroplasty (TKA) in the ASC Setting (THA/TKA PRO-PM); and modifications to ASC-11: Cataracts Visual Function.

Read an 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-CPL
• Total shoulder arthroplasty specifically to be added to the 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 2024. You can select your state and county from the dropdown at the top and the calculator does the rest. ASCA also posted a 2024 Proposed Rule Analysis that identifies and briefly summarizes the provisions of greatest interest to ASCs and a 2024 Proposed Rule Payment Resources document that provides separate worksheets for each group of codes, such as separately payable, office-based, device-intensive and more. All of ASCA’s Medicare-related resources for the current and previous years can be found on its Medicare Payment Resources webpage.

We would like to track the number of our member comments, so please email Kara Newbury at knewbury@ascassociation.org if you submit comments.