Here are the five key points of the comments:
1. CMS should use the hospital market basket as the annual update for ASC payments, as Medicare volume data has been skewed due to the COVID-19 pandemic.
2. CMS should discontinue the ASC weight scalar. Removing the secondary scaling adjustment is necessary to align the payment systems for ASCs to “capture the value of the conversion factor.”
3. CMS should add the 47 codes ASCA submitted in March to the ASC covered procedures list for 2023 or explain why surgeons are not allowed to perform these procedures.
4. CMS should finalize its plan to provide complexity adjustments for combinations of certain service codes.
5. CMS should finalize its proposal to suspend mandatory implementation of ASC-11 as it is a “little-used clinician measure.”
