Illinois Ambulatory Surgery Center AssociationIASCA

News & Announcements

IASCA Warns of “Troubling Developments” in 2022 Medicare ASC Payment Proposal

posted: November 19, 2021

In September 17, 2021, correspondence with the Centers for Medicare & Medicaid Services, IASCA joined 30 state associations to comment on the calendar year (CY) 2022 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System proposed rule.

The letter acknowledged “some encouraging signs that the Biden Administration is committed to improving the healthcare delivery system,” but warned, “there are also troubling developments that take a step backward in terms of clinical discretion, access to care and adding administrative burden to our facilities without a corresponding quality improvement.”

Key elements of the letter established:

  • We support CMS’ continued use of the hospital market basket as the annual update mechanism for ASC payments.
  • We encourage CMS to discontinue the ASC weight scalar.
  • We oppose the complete reversal of the 2021 changes that added 258 codes to the ASC Covered Procedures List (ASC-CPL) based on revised criteria.
  • We support the nomination process for adding codes to the ASC-CPL.
  • We support CMS’ proposed device intensive policy.
  • We support the resumption of ASC-1 through ASC-4 for the CY 2023 and requests that similar measures be added to the HOPD quality reporting program to allow for better comparisons across sites of service.
  • We have concerns with our facilities’ ability to operationalize the proposed COVID-19 Vaccination Coverage Among Healthcare Personnel (HCP) measure.
  • We oppose ASC-11 as a mandatory measure.
  • The OAS CAHPS survey should be modified to reduce the administrative and financial burden on our facilities.

The letter concluded, “While we appreciate the Biden Administration’s stated desire to encourage competition between high-quality healthcare providers, many of the policies in this proposed rule are misguided and will result in the opposite of this stated desire.”

Read the Full Letter