Ambulatory surgical centers (ASCs) are in for more challenges in the coming months as well as a new windfall from CMS, all of which will serve to create more challenges (and headaches for billing staff) in 2019 and beyond.
With the emphasis by CMS to implement site-neutral policies to incentivize lower-cost settings, three major outcomes can be predicted, according to Linda R. O’Neill, the Health Industry Distributors Association (HIDA) Vice President of Government Affairs.
- These resulting lower costs are making ASCs much more attractive to potential buyers, such as hospitals looking for mergers and acquisitions in facilities favored by the latest CMS ASC rulings.
- Nearly a fifth of the healthcare executives who responded to HIDA’s survey reported that they are interested in acquiring surgical centers.
- On the other hand, over 70 percent of ASC decision makers don’t anticipate any mergers or acquisitions within the next two years.
Then there is the revised definition of medical device-intensive procedures, adding over 130 procedures for Medicare beneficiaries in an ASC setting, which will undoubtedly create a surge in income as well as additional billing challenges. Some points to remember:
- The definition of device-intensive procedures has been updated from those procedures where a device accounts for 40 percent of the overall cost to 30 percent of the overall cost for the same procedure in the hospital outpatient department.
- These new definitions of device-intensive would be factors in increasing device-intensive procedures that ASCs would be able to provide for Medicare beneficiaries up from the previous 154 to 285 for 2019, provided that it appears in the final rule.
- According to CMS guidelines, new procedures that require the insertion of an implantable medical device will be assigned an offset device percentage default of at least 31 percent (from a previous minimum of 41 percent), thereby being assigned device-intensive status until more claims data become available. In some less-common situations, CMS may temporarily assign a higher offset percentage if the additional information warrants it.
- The lower threshold is also expected to improve the feasibility of ASCs to offer 131 device-intensive procedures to Medicare beneficiaries for the first time. ASCA’s CEO William Prentice remarked that “This (development) is a policy change we have been advocating over the past several years to encourage the migration of these procedures into ASCs.”
- Several cardiac procedures are among the newly-approved cases, with the proposed payment rule revising the definition of “surgery” for ASC payments to now include “surgery-like” procedures. These will add 12 cardiac catheterization procedures to the growing ASC list of new approvals.
Some key points of the CR11108 New Device Pass-Through Categories Section 1833(t)(6)(B) of the Social Security Act (“the Act”) requires that, under OPPS guidelines, categories of devices be considered eligible for transitional pass-through payments for at least two but no more than three years.
CMS has also been charged with creating additional pass-through categories for transitional payment of new devices not described by either existing or previously existing device categories. Effective January 1, 2019, a new device pass-through category
Changes to the ASC Quality Reporting Program
Although eight measures were that were proposed for removal from the ASC Quality Reporting (ASCQR) Program, only two were actually finalized for removal.
- Starting with CY 2020 payment determination, those measures, ASC-8: Influenza Vaccination Coverage Among Healthcare Personnel, and beginning in the CY 2021 payment determination ASC-10: Endoscopy/Polyp Surveillance: Colonoscopy Interval for Patients with a History of Adenomatus Polyps – Avoidance of Inappropriate Use will also be removed.
- In addition to these, while the following ASC-1: Patient Burn; ASC-2: Patient Fall; ASC-3: Wrong Site, Wrong Side, Wrong Patient, Wrong Procedure, Wrong Implant as well as ASC-4: All-Cause Hospital Transfer/Admission will remain (for the time being) in the ASCQR Program, data collection for these measures will be suspended until further actions take place in revising the rules.
- ASC-9: Endoscopy/Polyp Surveillance Follow-up Interval for Normal Colonoscopy in Average Risk Patients and voluntary measure ASC-11: Cataracts – Improvement in Patient’s Visual Function within 90 Days Following Cataract Surgery are expected to remain in the SCCQR Program.
To the above changes, ASCA CEO Prentice added that “The reduction of measures in the ASC Quality Reporting Program demonstrates the outstanding performance of ASCs in preventing serious adverse events. We look forward to working with CMS staff to identify actionable quality data that can be used by patients, providers and regulators.”
Separate payments for non-opioid pain management therapy
A finalized proposal by CMS will provide separate payment for non-opioid pain management drugs that act as a supply when used in surgical procedures performed in an ASC. The HCPCS code C9290, Exparel, is currently the code that meets the criteria and thus will be paid separately when used in surgical procedures performed in ASCs. CMS recognizes that other drugs may also meet the above criteria at some point in the future and be included in upcoming changes.
Along with the above changes comes the need to update back-office payment and processing services by practices, including many ASCs, whose facilities are experiencing more revenue and billing challenges than before. Some centers experiencing patient payment obstacles are developing and implementing payment technology options, such as web or voice-response to increase revenue.
What does this mean for your billing departments and how can ambulatory surgical centers stay on top of it all?
The benefits to ASCs of partnering with a trusted medical billing company
Since 2002, M-Scribe has worked with practices of all specialties and sizes, including, of course, ASCs. With our state-of-the-art technologies and cloud-based software, we can work with virtually all current platforms. With a comprehensive array of claims management services as well as add-ons, M-Scribe’s experience and commitment to excellence ensures your practice or organization of continued full compliance resulting in better reimbursement and increased revenues.
Contact us at 888-727-4234 or by email to learn more about how partnering with us can help you sort out and use the many changes ahead to your center’s best advantage.