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MedPAC advises Congress to make ASC cost reporting mandatory — 8 takeaways

The Medicare Payment Advisory Commission made two ASC-specific recommendations to Congress in its March 2018 report: that Medicare payment rates remain the same in 2019 and cost reporting be mandatory for participation in the Medicare program.

Here are eight takeaways.

1. Based on evaluation of beneficiaries' access to care, providers' access to capital and changes in ASC revenue from the Medicare program, MedPAC concluded Congress shouldn't change ASCs Medicare payment rates for 2019.

The commission's analysis determined "the number of ASCs has increased, beneficiaries' use of ASCs has been stable, and access to capital has been adequate."

2. The commission suggested more ASC staff should be receiving flu shots and more patients should be monitored following colonoscopies, but despite that Otherwise, ASC Quality Reporting program data showed "modest increases in performance."

3. The commission said CMS should improve the ASCQR Program and "move toward more CMS-calculated claims-based outcome measures that apply to all ASCs." It cited two concerns about the ASCQR program:

  • The relatively high amount of missing data
  • A lack of ASC quality measures that apply either to all ASCs or to all the common ASC specialities

4. The commission advised Congress to develop two new quality assessment measures: the number of Medicare beneficiaries discharged from ASCs who had a subsequent unplanned hospital visit and the rate of surgical site infections at ASCs.

5. MedPAC also advised Congress to make cost reporting mandatory for ASCs for participation in the Medicare program. It said cost data would aid in examining ASC costs over time and analyzing the adequacy of Medicare payments relative to the cost of efficient providers.

6. Despite their generally small size and limited resources, ASCs can feasibly submit cost data because, "such businesses typically keep records of their costs for filing taxes and other purposes, and other facility providers that are typically small, such as home health agencies and hospices, furnish cost data to CMS," the commission said.

7. MedPAC said CMS should develop a streamlined process for ASCs to track and submit a limited amount of cost data with minimal administrative burden. The commission suggested CMS could:

  • Annually conduct a survey of a random sample of ASCs, with mandatory response
  • Annually collect a set of cost variables from all ASCs that is more limited than what is collected through formal cost reports
  • Require ASCs to submit cost data from their existing cost accounting systems, provided their reported cost variables definitions are consistent with CMS's definitions

8. The Commission would like ASCs to submit the following information:

  • Total facility costs
  • Medicare unallowable costs, such as entertainment, promotion and bad debt
  • The costs of clinical staff who bill Medicare separately, such as anesthesiologists and clinical nurse anesthetists
  • Total charges across all payers and charges for Medicare patients
  • Total Medicare payments
  • Data on the share of costs related to employee compensation, medical supplies, medical equipment, building expenses and other professional expenses (such as legal, accounting and billing services)

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