What Would Mandatory Cost Reporting Mean for ASCs?: Q&A With ASCA
We recently asked the Ambulatory Surgery Center Association: "What would a mandatory cost reporting program mean for ASCs?" ASCA's response follows.
Q: What would a mandatory cost reporting mean for ambulatory surgery centers?
ASCA: Since 2009, when the ASC community formally expressed its opposition to a mandatory cost reporting program for ASCs to the Centers for Medicare & Medicaid Services, the concerns about that proposal that the ASC community has raised have included the following:
• the new administrative burden that the program would impose on both ASCs and CMS;
• a lack of necessity given that the ASC payment rates are based on the relative costliness of procedures in the hospital outpatient department setting;
• a belief that ASC updates should track with changes in the hospital Outpatient Prospective Payment System; and
• clear evidence that data collection activities that are not tied to payment have historically resulted in the submission of unreliable data.
Those same concerns remain today.
When CMS implemented its revised payment system in 2008, CMS created a system for determining ASC reimbursements that was intended to reflect the relative costliness of services between the ASC and HOPD settings. To maintain this system, any updates to the ASC and HOPD payments must remain consistent from year to year, which means both systems need to be updated using a single inflation factor. An ASC-specific market basket moves no closer to the full alignment of the parallel payment systems than any other factor except application of the update applied to the OPPS.
Additionally, past efforts by the Medicare Payment Advisory Commission to analyze ASC cost data provided to the Government Accountability Office have demonstrated that there is significant variation in the cost weights among ASCs with different specialties. A single set of cost weights representative of the industry would actually relate to few, if any, actual ASCs since most centers are specialized and would have a cost structure specific to the handful of high-volume procedures they provide.
Further, as CMS and the Medicare Payment Advisory Commission have observed in other sectors, portions of cost reports or other data collection instruments that are not directly tied to the receipt of payment are often populated by data that is unusable. Given the heterogeneity of the ASC sector, CMS should seek to align the ASC update factor with the updates applied to the hospital Outpatient Prospective Payment System.
Learn more about ASCA.
Related Articles on Cost Reporting and Advocacy Issues:
Quality Reporting Start Date Approaches; ASCs Gear Up for Change
MedPAC Calls for Mandatory ASC Cost Reporting
CMS Proposed Changes to Ambulatory Payment Classifications Prompt Comments From AHA, ASCA
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