The AHA addressed the issue as part of its comments on CMS-1504-P, which includes the proposed changes to the HOPD and ASC payment systems and rates.
Here are the comments from AHA on issues pertaining to ASCs:
Quality data reporting
“The AHA supports the implementation of a value-based purchasing program for ASCs, including appropriate quality and efficiency reporting measures as a critical part of the system. All providers that perform the same services should be held to the same accountability standards with respect to the quality of the care they deliver. Likewise, patients deserve the same transparency about the quality of care from all facilities where they may seek a particular service. It is a disservice to patients that they have access to surgical quality information from hospital outpatient departments, but the same level of transparency from ASCs is nonexistent.”
Cost reporting
“The AHA continues to urge CMS to require ASCs to begin to routinely report cost data to allow for future validation of the relative appropriateness of ASC payment weights and rates. This could be accomplished through implementing an ASC cost-reporting system or through the periodic collection of ASC cost data at the procedure level.”
Updating the ASC conversion factor and the incorporation of productivity
“…in the Medicare physician fee schedule proposed rule, CMS provides no details on the data and calculations that it used in making these estimates, instead referring readers to the Bureau of Labor Statistics, which only provides historical data. This level of information is insufficient for public comment. Before implementing these adjustments, which will cut billions of dollars from providers, CMS should fully disclose the methods and data sources used for this estimate for public comment.
The AHA is further concerned that current economic conditions are distorting the factor used for the productivity adjustment, potentially leading to unintended consequences. The original intent of the productivity adjustment was to hold providers to a standard of productivity improvement achieved by the rest of the economy. However, when productivity gains are driven by undesirable trends in the economy, this adjustment could lead to excessive cuts. The current “jobless recovery” is inflating productivity as output increases but a key input – employment – continues to stagnate. Cutting providers by this inflated figure could hurt hospitals and other health care providers that have been one of the few sources of continued job growth in this economy.”
Read the AHA’s letter to CMS which includes comments on ASC cost data reporting (pdf). Note: Comments on ASC issues begin on p. 27.
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