This year’s final rule has more changes than usual and all areas of healthcare have been impacted. The ASC changes are listed below along with links for more information.

If you have scheduled into January, check your schedule!

In total 255 procedures will no longer be covered in an ASC setting and in order to be covered must be performed in a hospital environment. Here is a list of the procedures: The 255 ASC surgeries moved off the ASC payable list by CMS (beckersasc.com)

If this change in procedure list impacts your facility, CMS has a nomination and review process in place for adding procedures back. Encourage your providers to reach out to their specialty organizations to push to have those procedures reinstated to the ASC covered procedure list.

According to the CMS Fact Sheet, "CMS is also finalizing the adoption of a nomination process, which will begin in March 2022, to allow an external party to nominate a surgical procedure to be added to the ASC CPL. If CMS determines that a surgical procedure meets the requirements to be added to the ASC CPL, including a surgical procedure nominated by an external party, it would propose to add the surgical procedure to the ASC CPL for January 1, 2023."

Non-Opioid Pain Relief = Potential $ Benefit

The CMS Fact Sheet further states, "CMS is finalizing its proposal that beginning January 1, 2022, a non-opioid pain management drug or biological that functions as a surgical supply in the ASC setting would be eligible for separate payment when such product is FDA approved, FDA indicated for pain management or as an analgesic, and has a per-day cost above the OPPS drug packaging threshold."

Change in Payment Rate

CMS approved a 2% payment increase for ASCs.

Device Intensive Procedure

ASCA's summary of the final ruling states, "CMS has finalized a policy change to calculate the device offset percentage to use ASC rates and not HOPD (Hospital Outpatient) rates as was previous practice. This means that any procedure for which the device cost is 30 percent of the overall ASC procedure rate will receive device-intensive status... Additionally, if a device receives HOPD device-intensive status, the device will also be device-intensive in the ASC setting."

Quality Reporting: New Measure for 2022 collection and a flashback for 2023 collection

There is a new measure being implemented for ASC’s (and other healthcare arenas) related to COVID-19 Vaccination, ASC-20: COVID-19 Vaccination of Health Care Personnel (NQF #0431). This will be submitted to NHSN similar to the influenza vaccination of healthcare personnel already submitted via NHSN. It is “voluntary.” Voluntary if you are willing to not participate in the ASCQR program and forfeit 2% of your Medicare payment. Currently, a threshold percentage is not required, only participation via reporting. This measure covers all employees who work even one day and receive a paycheck as well as volunteers, adult student/trainees and contract workers. To be counted in the numerator, they must have complete vaccination coverage. ASCs will need to collect numerator and denominator data this measure for at least one self-selected week during each month of the reporting quarter.

Flashback! This is for collection in 2023. ASC 1-4 will be back again and mandatory. What changes is the reporting method. They will not be claims based. They will be reported via the HQR system and will be for all patients, not just Medicare patients. In case you forgot, ASC 1-4 listed below:

Patient Satisfaction Surveys - Still not required until 2025...

If you have questions about any of these changes or would like to discuss in more detail with us, don't hesitate to reach out.

Further Reading: