The Centers for Medicare and Medicaid Services' quality reporting program for ambulatory surgery centers is in full swing and will continue to evolve in the upcoming year.
Since Oct. 1, ASCs should have begun including G-codes for quality reporting on claim forms with Medicare as the primary payor. Centers will be required to have started and maintained at least 50 percent program compliance to avoid incurring reimbursement penalties in the 2014 calendar year.
Three experts who work closely with quality reporting in ASCs are Jessica Nantz, Sandra Jones and Anne Dean. Ms. Nantz is the president of Outpatient Healthcare Strategies, Ms. Jones is the executive vice president and chief operating officer for ASD Management and Ms. Dean is the chief executive officer of The ADA Group.
Here are their seven points that ASCs should know for full compliance.
1. Know what to track. Quality reporting G-codes are required to measure the instances of five ASC incidents — patient burns, falls, wrong site or side patient procedures or implants, hospital admissions or transfers and prophylactic intravenous antibiotic timing.
Codes need to be applied to claims when these issues occur, as well as when no adverse events occur. The code G-8907 should be applied to claims for patients with no issues. Eleven codes from G-8908 to 8918 can be selected for when adverse events do take place.
Only ASCs without Medicare certification or Medicare patients are exempt from reporting the occurrence or lack of occurrence of the five issues.
2. Be aware of the implementation timeline. Beginning Jan. 1, 2013, ASCs will also have to assign G-codes to claims for which Medicare is the primary or secondary payor. In May 2013, ASCs will be able to register for the CMS QualityNet website, where they should create an account and designate two account administrators to be responsible for reporting the required data and other specified logins during 2013.
QualityNet.org will be the mechanism for surgery centers to report their 2012 use of safe surgery checklists and 2012 surgical volume for specific procedures on all Medicare and non-Medicare patients, Ms. Nantz says.
ASC account administrators will then have from July 1 to Aug. 15, 2013, to go on the QualityNet.org site and report their total surgical care volumes for selected groups of procedures — including certain eye, GI, genitourinary, musculoskeletal, nervous system and skin healthcare common procedure codes — and whether or not a safe surgery checklist was used any time during 2012. This reporting will include data on all patients, not just Medicare patients.
Finally, influenza vaccination coverage among healthcare personnel will need to be reported from Oct. 1, 2014, to March 31, 2015.
3. Keep detailed risk management logs. ASCs with detailed risk management trending logs will be better equipped to comply with current quality reporting measures, as well as any future quality reporting that may be required by CMS. Some states require such logs for adverse occurrences, but even ASCs in states without requirements should keep them, Ms. Dean says.
"The only way they can do this effectively is to have logs," she says. "You have to start somewhere. Our [ASCs] starts with an incident report and go to a trending log."
In addition to serving as an internal benchmarking tool, risk management logs can be used to double check that G-codes were correctly applied to Medicare claims.
"We've asked that if a code is selected, let's look back and make sure that's really the right code and that someone didn't input an error. If the event occurs, we make sure it gets on the claim and is verified," Ms. Jones says.
4. Determine your lines of communication. ASC managers should be aware that quality reporting creates an additional layer of communication, which could increase the potential for mistakes, Ms. Dean says.
"In the past, [if incidents occurred], risk managers tracked the occurrences and reported them to a quality improvement committee," she says. "Now they have put in another step. Those areas have to be reported as they occur to our coding people. That has added an increased time element."
Determine which system works best for your ASC to track incidents and report them to coders. The surgery centers Ms. Jones works with have a coding sheet that follows each patient from pre-op to discharge. If any adverse events occur, they are circled on the form, and forms are given to coders at the end of the day. An absence of events is also recorded to be coded.
"Find someone responsible for making sure that the correct code gets to the biller, whether that's the last nurse who works with patient who reviews their chart to look at timely antibiotics or if it's a person in the operating room who just fills it out," Ms. Jones says. "Determine where in your patient process which caregiver is responsible for this step."
Problems occur when the lines of communication are not well defined.
5. Improve patient safety. Many ASCs have been tracking incidents, such as patient burns and falls, for several years. The quality reporting requirement can be viewed as a more formal way to improve patient safety at your center as instances occur.
"If a patient should have a fall, we've been looking to see if there's anything we could have done to prevent it," Ms. Jones says. "Could we assign someone to help them dress? What did we do about making sure side rails were up?"
Submitting G-codes to CMS will create national benchmarking statistics for centers to compare themselves to with the goal of increasing overall patient safety. Centers will now have a wider base to compare themselves to, she says. ASCs can look at their percentage of patient falls or hospital transfers and see how they compare to centers nationwide.
Experts hope quality reporting will bring attention to infection control and safety at ASCs nationwide and hold centers accountable for patient outcomes.
6. Be aware of penalty periods. Surgery centers that fail to assign quality data G-codes to at least 50 percent of Medicare claims in 2012, will have their ASC conversion factor for all Medicare payments reduced by 2 percent, beginning in 2014.
Failure to report in subsequent years will continue to affect future payments, Ms. Nantz says, but the penalties will not be cumulative.
"An ASC that fails to report in 2012 but successfully reports in 2013 will receive the full payment update in 2015," she says.
Penalties for the July 1, 2013, safe surgery checklist and volume reporting to QualityNet will begin in 2015.
7. Strive for 100 percent compliance. While as of now only 50 percent compliance is required to avoid Medicare payment penalties, ASCs should strive for 100 percent compliance to maintain integrity and trust, Ms. Nantz says.
"ASCs should know CMS is going to make these data reports available to the public. The public may form a negative perception of ASCs that do not report data or that report poor performance on the quality measures," she says. "ASCs are encouraged to focus not only on reporting successfully, but also on achieving high levels of performance on each measure."
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Since Oct. 1, ASCs should have begun including G-codes for quality reporting on claim forms with Medicare as the primary payor. Centers will be required to have started and maintained at least 50 percent program compliance to avoid incurring reimbursement penalties in the 2014 calendar year.
Three experts who work closely with quality reporting in ASCs are Jessica Nantz, Sandra Jones and Anne Dean. Ms. Nantz is the president of Outpatient Healthcare Strategies, Ms. Jones is the executive vice president and chief operating officer for ASD Management and Ms. Dean is the chief executive officer of The ADA Group.
Here are their seven points that ASCs should know for full compliance.
1. Know what to track. Quality reporting G-codes are required to measure the instances of five ASC incidents — patient burns, falls, wrong site or side patient procedures or implants, hospital admissions or transfers and prophylactic intravenous antibiotic timing.
Codes need to be applied to claims when these issues occur, as well as when no adverse events occur. The code G-8907 should be applied to claims for patients with no issues. Eleven codes from G-8908 to 8918 can be selected for when adverse events do take place.
Only ASCs without Medicare certification or Medicare patients are exempt from reporting the occurrence or lack of occurrence of the five issues.
2. Be aware of the implementation timeline. Beginning Jan. 1, 2013, ASCs will also have to assign G-codes to claims for which Medicare is the primary or secondary payor. In May 2013, ASCs will be able to register for the CMS QualityNet website, where they should create an account and designate two account administrators to be responsible for reporting the required data and other specified logins during 2013.
QualityNet.org will be the mechanism for surgery centers to report their 2012 use of safe surgery checklists and 2012 surgical volume for specific procedures on all Medicare and non-Medicare patients, Ms. Nantz says.
ASC account administrators will then have from July 1 to Aug. 15, 2013, to go on the QualityNet.org site and report their total surgical care volumes for selected groups of procedures — including certain eye, GI, genitourinary, musculoskeletal, nervous system and skin healthcare common procedure codes — and whether or not a safe surgery checklist was used any time during 2012. This reporting will include data on all patients, not just Medicare patients.
Finally, influenza vaccination coverage among healthcare personnel will need to be reported from Oct. 1, 2014, to March 31, 2015.
3. Keep detailed risk management logs. ASCs with detailed risk management trending logs will be better equipped to comply with current quality reporting measures, as well as any future quality reporting that may be required by CMS. Some states require such logs for adverse occurrences, but even ASCs in states without requirements should keep them, Ms. Dean says.
"The only way they can do this effectively is to have logs," she says. "You have to start somewhere. Our [ASCs] starts with an incident report and go to a trending log."
In addition to serving as an internal benchmarking tool, risk management logs can be used to double check that G-codes were correctly applied to Medicare claims.
"We've asked that if a code is selected, let's look back and make sure that's really the right code and that someone didn't input an error. If the event occurs, we make sure it gets on the claim and is verified," Ms. Jones says.
4. Determine your lines of communication. ASC managers should be aware that quality reporting creates an additional layer of communication, which could increase the potential for mistakes, Ms. Dean says.
"In the past, [if incidents occurred], risk managers tracked the occurrences and reported them to a quality improvement committee," she says. "Now they have put in another step. Those areas have to be reported as they occur to our coding people. That has added an increased time element."
Determine which system works best for your ASC to track incidents and report them to coders. The surgery centers Ms. Jones works with have a coding sheet that follows each patient from pre-op to discharge. If any adverse events occur, they are circled on the form, and forms are given to coders at the end of the day. An absence of events is also recorded to be coded.
"Find someone responsible for making sure that the correct code gets to the biller, whether that's the last nurse who works with patient who reviews their chart to look at timely antibiotics or if it's a person in the operating room who just fills it out," Ms. Jones says. "Determine where in your patient process which caregiver is responsible for this step."
Problems occur when the lines of communication are not well defined.
5. Improve patient safety. Many ASCs have been tracking incidents, such as patient burns and falls, for several years. The quality reporting requirement can be viewed as a more formal way to improve patient safety at your center as instances occur.
"If a patient should have a fall, we've been looking to see if there's anything we could have done to prevent it," Ms. Jones says. "Could we assign someone to help them dress? What did we do about making sure side rails were up?"
Submitting G-codes to CMS will create national benchmarking statistics for centers to compare themselves to with the goal of increasing overall patient safety. Centers will now have a wider base to compare themselves to, she says. ASCs can look at their percentage of patient falls or hospital transfers and see how they compare to centers nationwide.
Experts hope quality reporting will bring attention to infection control and safety at ASCs nationwide and hold centers accountable for patient outcomes.
6. Be aware of penalty periods. Surgery centers that fail to assign quality data G-codes to at least 50 percent of Medicare claims in 2012, will have their ASC conversion factor for all Medicare payments reduced by 2 percent, beginning in 2014.
Failure to report in subsequent years will continue to affect future payments, Ms. Nantz says, but the penalties will not be cumulative.
"An ASC that fails to report in 2012 but successfully reports in 2013 will receive the full payment update in 2015," she says.
Penalties for the July 1, 2013, safe surgery checklist and volume reporting to QualityNet will begin in 2015.
7. Strive for 100 percent compliance. While as of now only 50 percent compliance is required to avoid Medicare payment penalties, ASCs should strive for 100 percent compliance to maintain integrity and trust, Ms. Nantz says.
"ASCs should know CMS is going to make these data reports available to the public. The public may form a negative perception of ASCs that do not report data or that report poor performance on the quality measures," she says. "ASCs are encouraged to focus not only on reporting successfully, but also on achieving high levels of performance on each measure."
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Study: Cleaning With Hydrogen Peroxide Vapor Linked to Lower C. Diff-Associated Diarrhea Rates
Study: Patient Satisfaction Tied Closely to Readmission Rates
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