Medicare’s Regulatory and Quality Measure Reporting Update for ASCs


By Gina Throneberry, RN, MBA, CASC, CNOR, Director of Education and Clinical Affairs, Ambulatory Surgery Center Association

Keeping up with Medicare’s regulatory and reporting requirements for ambulatory surgery centers (ASCs) can be challenging. ASC leaders must be aware of the following finalized regulatory and quality measure reporting requirements.

Regulatory Updates

Emergency Preparedness Updates to Appendix Z (effective Feb. 1, 2019): An important update that the Centers for Medicare & Medicaid Services (CMS) made to this appendix is the addition of emerging infectious diseases to an ASC’s emergency preparedness program. ASCs will now need to identify what emerging infectious diseases could occur in their geographic area and have a plan to respond.

Standard hospitalization: 42 CFR 416.41(b)(3) (effective Nov. 29, 2019): ASCs are no longer required to have a written transfer agreement or hospital admitting privileges for all physicians who practice in the ASC unless required by the state in which the ASC is located or the organization that accredits the ASC. Instead, ASCs can provide written notice periodically to the local hospital of their operation and patient population served. For example, the notice would include details such as hours of operation and the types of procedures performed in the ASC.

Patient admission, assessment, and discharge: § 416.52(a) (effective Nov. 29, 2019): CMS finalized its proposal to eliminate the requirement that each patient have a medical history and physical assessment (H&P) completed by a physician not more than 30 days before the scheduled surgery. This replaced with the requirement for ASCs to develop and maintain a policy that identifies those patients who require a medical H&P examination prior to surgery. The facility’s policy must include the timeframe for the H&P to be completed prior to surgery. The policy must also address, but not be limited to, the following factors: patient age, diagnosis, the type and number of procedures scheduled to be performed on the same surgery date, known comorbidities and the planned anesthesia level. ASCs must check their state regulations and accrediting organization’s standards and follow the stricter regulations/standards.

Emergency Preparedness Condition for Coverage (CfC), §416.54 (effective Nov. 29, 2019): CMS now requires ASCs to review their emergency plan (EP) every two years instead of annually. ASCs will no longer be required to document efforts to contact local, tribal, regional, state and federal EP officials, although they will still need to try to coordinate with those entities. EP training is now required every two years, or when the ASC’s EP is updated significantly, instead of every year. ASCs must now conduct a single testing exercise per year instead of two. Every other year, ASCs must either participate in a community-based, full-scale exercise, if available, or conduct an individual, facility-based functional exercise. In the opposite years, ASCs may conduct a testing exercise of their choice, which may include a community-based full-scale exercise, if available; an individual, facility-based functional exercise; a drill; or a tabletop exercise or workshop that includes a group discussion led by a facilitator. ASCs are exempt from the next required exercise after an event requiring activation of their EP plan.

2020 Medicare Hospital Outpatient Prospective Payment System (OPPS)/ASC Payment Rule (effective Jan. 1, 2020): This rule added eight codes to the ASC-payable list, including total knee arthroplasty, and also moved total hip arthroplasty from the hospital-only list so that this procedure can be performed in the hospital outpatient department setting. According to the final rule, CMS will continue to use the hospital market basket, which measures the inflation of medical costs, such as equipment, supplies and staffing, to update ASC payments for calendar year (CY) 2019 through CY 2023.

2020 Medicare Physician Fee Schedule (effective Jan. 1, 2020): This rule allows certified registered nurse anesthetists (CRNAs) working in ASCs to examine patients before surgery and before discharge. CRNAs that practice in ASCs not located in an opt-out state still must have physician supervision for the actual administration of anesthesia.

CMS ASC Quality Reporting Program

Here is a summary of all the updates to and current requirements for quality reporting under CMS’ ASC Quality Reporting Program.

Reporting is suspended until further rulemaking for the following measures (ASCs presently do not need to report these to CMS, but may need to do so in the future):

ASC-1: Patient burn
ASC-2: Patient fall
ASC-3: Wrong site, wrong side, wrong patient, wrong procedure, wrong implant
ASC-4: All-cause hospital transfer/admission.

No reporting of data to CMS for these measures:
ASC-5: Prophylactic intravenous antibiotic timing
ASC-6: Safe surgery checklist use
ASC-7: ASC facility volume data on selected ASC surgical procedures
ASC-8: Influenza vaccination coverage among healthcare personnel.
ASC-10: Endoscopy/polyp surveillance: Colonoscopy interval for patients with a history of adenomatous polyps–avoidance of inappropriate use

Reporting is still voluntary for ASC-11: Improvement in patient’s visual function within 90 days following cataract surgery.

Implementation is still delayed for ASC-15: Outpatient/Ambulatory Surgery Consumer Assessment of Healthcare Providers and Systems (OAS CAHPS).

Here is a summary of the measures that ASCs need to report to CMS. The reporting dates refer to data collected in CY 2019.

ASC-9: Endoscopy/polyp surveillance: Appropriate follow-up interval for normal colonoscopy in average risk patients

  • Type of measure: Web-based via QualityNet secure portal
  • Measure applies to: Sampling
  • Reporting date: Jan. 1-May 15, 2020
  • Payment determination: CY 2021

ASC-12: Facility seven-day risk standardized hospital visit rate after outpatient colonoscopy

  • Type of measure: Administrative claims-based (CMS pulls data from claims billed by the center, so the ASC does not have to submit the data)
  • Measure applies to: Paid Medicare fee-for-service claims
  • Reporting date: Paid Medicare fee-for-service claims from Jan. 1, 2016-Dec. 31, 2018, and subsequent years
  • Payment determination: CY 2020

ASC-13: Normothermia

  • Type of measure: Web-based via QualityNet secure portal
  • Measure applies to: Sampling that meets the denominator criteria
  • Reporting date: Jan. 1-May 15, 2020
  • Payment determination: CY 2021

ASC-14: Unplanned anterior vitrectomy

  • Type of measure: Web-based via QualityNet secure portal
  • Measure applies to: All patients that meet the denominator criteria
  • Reporting date: Jan. 1-May 15, 2020
  • Payment determination: CY 2021

ASC-17: Facility level seven-day hospital visits after orthopedic ambulatory surgical center procedures hospital visit

  • Type of measure: Administrative claims-based (CMS pulls data from claims billed by the center, so the ASC does not have to submit the data)
  • Measure applies to: Paid Medicare fee-for-service claims
  • Reporting date: Paid Medicare fee-for-service claims from Jan. 1, 2019-Dec. 31, 2020
  • Payment determination: CY 2022

ASC-18: Facility level seven-day hospital visits after urology ambulatory surgical center procedures

  • Type of measure: Administrative claims-based (CMS pulls data from claims billed by the center, so the ASC does not have to submit the data)
  • Measure applies to: Paid Medicare fee-for-service claims
  • Reporting date: Paid Medicare fee-for-service claims from Jan. 1, 2019-Dec. 31, 2020
  • Payment determination: CY 2022

*New Measure– ASC-19: Facility level seven-day hospital visits after general ambulatory surgical center procedures

  • Type of measure: Administrative claims-based (CMS pulls data from claims billed by the center, so the ASC does not have to submit the data)
  • Measure applies to: Paid Medicare fee-for-service claims
  • Reporting date: Paid Medicare fee-for-service claims from Jan. 1, 2021-Dec. 31, 2022
  • Payment determination: CY 2024

Key Points to Remember

There are several key points to remember that will assist ASC leaders in meeting the quality measure reporting requirements:

  • An active security administrator is required to access the QualityNet secure portal (recommend having two individuals)
  • Sign in to QualityNet secure portal frequently (every 60 days) to keep the account active
  • Log into the QualityNet secure portal and enter zero for the numerator and denominators for ASC-9, 13, and 14 if the ASC does not perform these procedures
  • Review the facility-specific confidential reports for ASC-12, 17, 18 and 19 that are uploaded periodically to the QualityNet secure portal


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