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CMS Makes Changes to ASCQR Program

What this means for your ASC

BY KARA NEWBURY | JANUARY 2019

The Centers for Medicare & Medicaid Services (CMS) made significant changes to the ASC Quality Reporting (ASCQR) Program for 2019 and beyond, including the suspension of four outcomes measures that have been part of the ASCQR Program since its inception in 2012. Facilities that have been collecting and reporting data on Medicare claims forms are no longer required to do so for 2019. Even though facilities no longer have to report on patient burns (ASC-1), falls (ASC-2), wrong events (ASC-3) or hospital transfers (ASC-4) on fee-for-service (FFS) Medicare claims, it is a good idea to continue collecting this data, as the measures have been suspended only instead of removed and the information can be useful for benchmarking and quality assessment and performance improvement.

What exactly did CMS say about ASC-1 through ASC-4 in the 2019 payment rule cycle?

In the 2019 ASC proposed payment rule, CMS indicated that ASC-1 through ASC-4 had “topped out,” meaning the outcomes being reported by facilities were very high. CMS proposed to eliminate these measures from the ASCQR Program, as the agency felt the data had limited value. Instead of removing the measures from the ASCQR Program, however, in the 2019 final payment rule CMS chose to suspend the measures, indicating they could be reinstated in future years. CMS noted in the final rule that since these adverse events were only being collected as Quality Data Codes (QDCs) on FFS Medicare claims, adverse events that occur outside of the FFS Medicare population were not reported. CMS indicates that while it is suspending these measures, as the agency develops “future revisions for the data collected for these measures,” it will “take into consideration other data submission methods that may allow for the reporting of adverse events across payers and will consider commenters’ feedback toward the future updates to the measures.”

CMS also believes that reporting through a web-based mechanism such as QualityNet, the portal used for other ASCQR Program measures, errors could more easily be corrected by facilities. When submitting on claims, ASCs that identify an erroneous or missing QDC code are unable to correct or add a QDC code if the claim has already been submitted to Medicare. In the final rule, CMS states that “revising the data submission method for the measures, such as via QualityNet, would address this issue and allow facilities to correct any data submissions errors, resulting in more complete and accurate data.” The agency is sensitive to administrative burden on facilities, however, stating that it is “committed to work with stakeholders to ensure the ASCQR Program measure set does not place an inappropriate amount of burden on facilities while addressing and providing information about these types of patient safety, adverse, rare events to patients and other consumers.”

What does all of this mean to my facility?

ASCs do not need to put QDCs on their FFS Medicare claims for 2019. Period. However, as indicated in the final rule text cited above, CMS is evaluating whether this data should be collected in the future, if it should be expanded to all payers and through what mechanism it would be reported in the future. The earliest this reporting could be mandated for ASCs would be 2020, and we will see in July whether it is proposed in the 2020 payment rule. Considering it would take the agency some time to evaluate the burden associated with implementing data reporting for all patients under a web-based portal such as QualityNet, it might be 2021 or beyond before we see these measures mandated again.

So why should we collect it?

For the same reason you should still be using a safe surgical checklist, even though you no longer need to report on its usage under the ASCQR Program. It is important information for the facility to have, to be able to address issues as they arise and benchmark against other facilities.

If I choose to continue reporting, where can I do that?

As with many other data points that facilities are collecting on their own that are not required by state or federal government, ASCs can choose to continue collecting through excel spreadsheets, their electronic health records or paper records. If you want to report this information to benchmark against other facilities, there are a couple of options.

Benchmarking programs

If you participate in ASCA’s Clinical & Operational Benchmarking Survey, you will continue to collect and report on these adverse events in order to provide your ASC data in which to use for benchmarking. Beginning January 1, 2019, ASCA has updated its quality section of the Clinical & Operational Benchmarking Survey to include three tabs—Suspended by Medicare, Reported to Medicare, and Not Reported to Medicare—to provide your ASC with even more information about adverse events that were suspended by Medicare.

For ASC-1 and ASC-2, there are nine additional “drilled down” questions added to each of these questions. The “drilled down” questions will ask the area of the ASC in which the fall/burn occurred, the impact of the fall/burn on the patient, and the intervention taken by the ASC for the fall/burn.

The facility will indicate whether the fall/burn occurred in the preop area, intra-op area or postop area. For each of the areas, there will be an option for the facility to identify if there was no impact to the patient (interventions: no monitoring, no actions taken, no medications administered, no dressing applied, etc.), minimal impact (interventions: medication administered, dressing applied, etc.) or major impact (interventions: transfer to hospital for significant loss of blood, fracture, etc.).

This will provide more valuable information as to the harm caused to the patient and will allow ASCs to better benchmark their facility against other facilities and determine the progress made at that facility over time.

Other benchmarking programs, such as those run by state associations or other specialty organizations, might also include the collection of this data.

National Health Safety Network (NSHN)

In addition to benchmarking programs, the Centers for Disease Control and Prevention’s (CDC) NHSN portal also provides facilities with the opportunity to report on these measures through its new Outpatient Procedure Component Surveillance for Same Day Outcome Measures (OPC-SDOM) module. This reporting is voluntary. If ASCs choose to participate, they would fill out the Outpatient Procedure Component (OPC) Monthly Reporting Plan form (CDC 57.401). Participating facilities must indicate if they want data entered into NHSN to be used for “in-plan” or “off-plan” surveillance. Only in-plan data would be included in NHSN annual reports or other publications. Off-plan surveillance means the facility has decided to track a particular event solely for the facility’s internal use. A plan must be completed for every month that data is entered into NHSN, although a facility may choose “No NHSN Outpatient Reporting this month” as an option.

In addition to the monthly report, the ASC must complete an OPC Annual Facility Survey (CDC 57.400) which is used by CDC to “classify facilities for appropriate comparisons in aggregate data analyses and to learn more about common practices among ASCs.” Participating facilities must complete the annual facility survey at the time they enroll or activate the OPC and, subsequently, at the beginning of each calendar year.

The OPC-SDOM surveillance protocols, training materials, data collection forms, instructions and other supporting materials are provided on the Outpatient Procedure Component website.

For more information, visit ASCA's Quality Reporting page and How to Meet Medicare’s 2019 ASC Quality Reporting Requirements page.