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Measure calls for ASCs to report visual acuity 6 months after cataract surgery
ASC-11 is voluntary due to concerns raised by surgical and ophthalmic advocacy groups.
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ASC-11, a measure for ambulatory surgery centers to report on visual acuity outcomes 6 months after cataract surgery, was implemented on Jan. 1.
The Centers for Medicare and Medicaid Services announced a delay to Jan. 1 in a proposed rule issued in April 2014. In a final rule issued in October 2014, CMS made ASC-11 an optional measure. Both changes were made in response to medical societies’ concerns about logistics and reporting burdens.
Donna McCune
Concerns about ASC-11 center mainly on logistics, according to Donna McCune, CCS-P, COE, CPMA, vice president of Corcoran Consulting Group.
“I think a major concern was logistics — the fact that patients visit an ASC on the day of surgery and the surgery center does not see the patient subsequently,” McCune said. “[ASCs] were being asked to provide data 90 days following cataract surgery. Organized medicine believes this is something that the physicians gather and not the ambulatory surgery center. It would be cumbersome for an ambulatory surgery center to gather this data.”
ASC-11 is included in the Ambulatory Surgical Center Quality Reporting Program, a quality data program administered by CMS. Under the program, ASCs report on standardized quality-of-care measures to receive updates to their annual payments.
The American Academy of Ophthalmology, American Society of Cataract and Refractive Surgery and other groups have called for CMS to withdraw ASC-11 as a reporting measure.
“The AAO encouraged ASCs to refrain from reporting on ASC-11,” McCune said.
“I think AAO and ASCRS believe this information won’t be accurate and, if made public, could be misleading,” she said. “If many ASCs voluntarily decline to report this data, then the data set will be small and not representative.”
ASCs are not subject to payment reductions if they voluntarily report on ASC-11 for 2016, according to an online CMS document.
Societies express concerns
In a letter to former CMS Administrator Marilyn Tavenner, the AAO, ASCRS, Ambulatory Surgery Center Association, American Society of Retina Specialists and other groups expressed concerns about ASC-11.
The societies also made recommendations, such as CMS withdrawing ASC-11 as a voluntary reporting measure and collaborating with the ophthalmology and ASC communities to develop and implement appropriate ophthalmic measures for the ASC community.
“The data required for reporting by facilities should be available within the records of the ambulatory surgical center; facilities should not be required to access and report data that is only available to other providers, such as the physician’s office,” the letter said.
The letter noted that, by regulation, ASCs are administratively and financially separate from physician offices.
“Importantly, medical record keeping must always be maintained separately and exclusively from other operations,” the letter said. “Implementation of this measure in the facility would be extremely burdensome and resource-intensive to the reporting ASC.”
Concern about subjective data
The subjective nature of reportable data is also a concern among ophthalmologists, McCune said.
“[We all know] that you have a patient that can barely see, you do cataract surgery, and if you catch them on a bad day, your survey result might not be particularly favorable, yet your medical record indicates that the patient is seeing a hundred times better than they were prior to surgery. I think that the subjective nature of the reporting is a significant concern for surgeons and ASCs,” she said.
Currently, cataract surgeons report subjective data under the Physician Quality Reporting System (PQRS).
“Cataract surgeons who use the PQRS cataract measure group provide this information to CMS through a registry, like Intelligent Research in Sight (IRIS). Much of this physician data will be gathered through the PQRS program, but that will be on the professional side and not the ambulatory surgery center side,” she said. – by Matt Hasson
References:
CMS delays implementation of ASC-11. Ambulatory Surgery Center Association website. www.ascassociation.org/aboutus/latestnews/newsarchive/2014/april/cmsdelaysimplementationofasc11/. April 2, 2014.Fact sheets: CMS finalizes hospital outpatient and ambulatory surgical centers quality reporting program changes for 2015. Centers for Medicare and Medicaid Services website. www.cms.gov/Newsroom/MediaReleaseDatabase/Fact-sheets/2014-Fact-sheets-items/2014-10-31-2.html. Oct. 31, 2014.
Letter to Marilyn Tavenner, Centers for Medicare and Medicaid Services. gallery.mailchimp.com/7c22b09a4cf43906a0ce9690e/files/ASC_Rule_Comments_9_2_14.pdf. Sept. 2, 2014.
Medicare and Medicaid Programs: Hospital outpatient prospective payment and ambulatory surgical center payment systems and quality reporting programs; Physician-owned hospitals: Data sources for expansion exception; Physician certification of inpatient hospital services; Medicare Advantage organizations and Part D sponsors: CMS-identified overpayments associated with submitted payment data; Final rule. Federal Register. www.gpo.gov/fdsys/pkg/FR-2014-11-10/pdf/2014-26146.pdf. Nov. 10, 2014.
2015 Ambulatory Surgery Center (ASC) Payment System and Quality Reporting (ASCQR) program final rule released. American Society of Cataract and Refractive Surgery website. www.ascrs.org/node/20576.
For more information:
Donna McCune, CCS-P, COE, CPMA, can be reached at Corcoran Consulting Group; 800-399-6565, ext. 201; email: dmccune@corcoranccg.com.Disclosure: McCune is vice president of Corcoran Consulting Group.
Perspective
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Laurie K. Brown, MBA, COMT, COE, OSA, OCS, CPSS
ASC-11 is quite controversial, and our supportive societies are working together in appealing to CMS to have complete removal of the now-voluntary ACS reporting measure. Cataract surgery in the ambulatory surgery center environment has saved our health care system millions of dollars over decades and remains a stepchild to hospital reimbursements, even though the work performed in ASCs meets, to a tee, the CMS overarching goals of providing the highest quality care as efficiently and cost-effectively as possible. To add another reporting layer, especially requiring the reporting of data ASCs do not have access to in the normal production of their work, is in direct conflict with their mission and only creates another layer of administrative hassle for those already successfully working hard to improve how health care procedures are delivered. I am sure all of us in health care would like to see more meaningful measures of quality and make these processes complement good work, not detract from it.
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