This year is shaping up to be a momentous one for the ASC community. One important reason for that is the Centers for Medicare & Medicaid Services’ (CMS) proposed 2019 ASC payment rule issued in July. That proposal suggests sweeping changes to Medicare’s ASC policies.

Also of note concerning the ASCQR Program, CMS did not propose to mandate implementation of the Consumer Assessment of Healthcare Providers and Systems Outpatient and Ambulatory Surgery Survey (OAS CAHPS) yet.

Another change that CMS proposed speaks to a change ASCs have been requesting for some time: defining ASC device-intensive procedures as those procedures with a device offset percentage greater than 30 percent based on the standard OPPS APC rate-setting methodology rather than the current 40 percent threshold. ASCA and individual ASC professionals have advocated strongly for a lower threshold in order to migrate these procedures to our setting.

In an unexpected move, CMS proposed to revise its definition of “surgery” in the ASC payment system to account for certain “surgery-like” procedures that are assigned codes outside the Current Procedural Terminology (CPT) surgical range. This revision allowed them to propose adding 12 cardiac catheterization procedures to the ASC covered procedures list.

Also for 2019, CMS proposed to provide separate payment for non-opioid pain management drugs that function as a supply when used in a surgical procedure when the procedure is performed in an ASC. HCPCS code C9290, Exparel, is the only code that CMS identified as meeting the proposed criteria right now.

As we expected, CMS did not propose to add any total joint replacement codes to the ASC-payable list for 2019.

Comments on the proposed rule are due on September 24, 2018, so if you read this before then, we urge you to support ASCA’s advocacy efforts by submitting your own comments.

Bill Prentice
Chief Executive Officer