ASRS Voices Concern to CMS Regarding Proposed Medicare ASC Reimbursement Changes

Thursday, September 6, 2012

ASRS is strongly advocating on your behalf—most recently regarding proposed changes to Medicare’s ambulatory surgical center (ASC) payment system.

On September 4, the ASRS, along with the American Academy of Ophthalmology, the American Society of Cataract and Refractive Surgery, and the Outpatient Ophthalmic Surgery Society, sent a letter to CMS Acting Administrator Marilyn B. Tavenner regarding CMS-1589-P—Medicare’s proposed changes to the ASC payment system and CY 2013 payment rates.

“At a time when public policymakers are searching for meaningful health care reform—improving quality and access, while reducing costs—ASCs embody the potential to be a significant part of the solution,” the letter stated. “Yet, elements of the proposed regulation, particularly the payment provisions, continue to thwart, rather than enhance the ability of our facilities to continue to serve the nation’s Medicare beneficiaries.”

At issue: The further decreases proposed in Medicare ASC reimbursement rates compared with those for the same procedures performed in a hospital outpatient department (HOPD). “There is a point at which the continued disparity between ASCs and their HOPD counterparts will have negative ramifications for the program and to the Medicare patients for whom it strives to provide quality surgical care,” the letter cautioned.

These proposed Medicare reimbursement changes would have serious repercussions for US retina specialists. Failure to increase payments to ASCs to reflect inflationary pressures cannot help but exacerbate disturbing trends in ASC payment, beneficiary access, program expenditures, and competition between the HOPD and ASC.

Just 8 years ago, aggregate ASC payments were 84% of HOPD rates; when the new system was established in 2008, the percentage had dropped to 65%. Under the proposed 2013 rates, the ASC rate will be further reduced to approximately 57% of the HOPD rate.

This rate change has resulted from applying different inflation updates and an irrational and punitive budget neutrality policy; it is entirely unrelated to the cost of providing services to Medicare patients in the respective outpatient surgical environments.

In comparing 2010 and 2011 Medicare service volume, there appears to be a slight reversal in the historic trend of ophthalmic services being performed in the ASC setting, as allowed services declined by almost 2%.

The Society’s 14-page letter outlined problems with the current ASC payment system and presented detailed recommendations. ASRS will continue to monitor the proposed changes to the ASC payment system and will keep you informed of our advocacy efforts.


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