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ASC NEWS |
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ASC Association Government Affairs Report - May 3, 2012 |
Medicare Reduces Lithotripsy Payment Rate
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Due to an error, the Medicare payment rate for CPT 50590 (fragmenting of kidney stone) released in November 2011 was incorrect. The Centers for Medicare & Medicaid Services (CMS) announced that retroactive to January 1, 2012, all claims for this procedure will be paid at the corrected rate, resulting in a 20% reduction in payment for the procedure.
However, ASCA staff has reached out to CMS and has learned that Medicare contractors are not expected to automatically reprocess previously paid claims. If your contractor does, please contact Jonathan Beal at jbeal@ascassociation.org and let him know.
Click here for more information.
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Results from ASCA’s Drug Shortages Survey
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ASCA would like to thank everyone who participated in our recent drug shortages survey.
The survey results found that of the more than 240 respondents, almost 90% are experiencing a drug shortage at least weekly. In addition, more than 80% of respondents were never given advanced notice of the drug shortage.
Early reporting of drug shortages is one of the best ways to help alleviate the problem. If you are experiencing a drug shortage, it is very important that you email the US Food and Drug Administration (FDA) or contact Jack Coleman at jcoleman@ascassociation.org.
The survey results also found that half of respondents had to use an alternative level of sedation and/or alternative medications because of a drug shortage, which many respondents stated led to an increase in patient nausea and vomiting.
In addition, over 10% of facilities responding have had to reschedule a procedure due to a drug shortage.
For more information, contact Jack Coleman at jcoleman@ascassociation.org.
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CMS Releases Quality Reporting Manual |
CMS Releases Quality Reporting Manual
The Centers for Medicare & Medicaid Services (CMS) released its manual for the ASC quality reporting program today (download the manual below). The manual provides detailed information on how ASCs should report information to CMS.
Of note, the manual indicates that ASCs that used a safe surgery checklist based on accepted standards of practice at any time during 2012 can answer “yes” when they report whether they used a safe surgery checklist during the year. Previously, CMS had indicated that ASCs would be able to answer "yes" only if they had a safe surgery checklist in place on January 1, 2012. This change will allow more ASCs to be able to report that they used a checklist in 2012.
Supporting Documents: ASC Quality Reporting Program Manual
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ASC Association Government Affairs Report - April 26, 2012 |
CMS Releases Proposed Quality Reporting Requirements
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The Centers for Medicare & Medicaid Services (CMS) has released proposed guidelines for Medicare’s new ASC quality reporting program (now available on ASCA Connect). The proposal provides information about how the program will work, including compliance measures, deadlines and more. Click here to read ASCA’s initial analysis.
ASCA will submit comments on the proposal and continue to work with CMS as implementation of the new ASC quality reporting program continues. Click here to learn more about the quality reporting program. Also, make certain you are registered for ASCA’s annual meeting in Dallas, Texas, May 9–12. Several sessions at that meeting, including one being presented by CMS quality reporting expert Anita Bhatia, will provide up-to-the minute information and advice about complying with the new program requirements.
For more information, contact Jonathan Beal at jbeal@ascassociation.org.
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ASC Medicare Rates Corrected—Again
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For the second time this month, CMS has made a slight revision to Medicare’s ASC payment rates due to technical errors regarding the rates reported originally. The corrected rates are retroactive to January 1, 2012, but Medicare contractors will not automatically reprocess previously paid claims. They will reprocess claims only upon request for re-adjudication. ASCA’s Rate Calculator, which is available only to ASCA members who log in to ASCA’s web site, has been updated to reflect this correction.
For more information, contact Jonathan Beal at jbeal@ascassociation.org.
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New Cosponsors for ASC Quality and Access Act of 2011
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US Senator Dean Heller (R-NV) and US Representatives Peter King (R-NY), Chris Murphy (D-CT) and Francisco “Quico” Canseco (R-TX) have joined the ASC Quality and Access Act of 2011 as cosponsors.
Rep. Canseco cosponsored the legislation shortly after meeting with the Texas ASC delegation during the April Capitol Hill Fly-ins. Rep. King is chair of the House Homeland Security Committee. He became a cosponsor after his constituent Robert Nelson of Island Eye Surgicenter, LLC, educated him on the industry and made a grassroots appeal for him to cosponsor the legislation—proof that, sometimes, all you have to do is ask.
The ASC Quality and Access Act of 2011 has 45 sponsors and cosponsors in the US House. There are six sponsors and cosponsors in the US Senate.
Visit ASCA’s ASC Quality and Access Act of 2011 page for more information on the legislation and a list of cosponsors.
For more information, contact Brendan Davis at bdavis@ascassociation.org.
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Advocacy in Action
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April marked another strong month of member advocacy efforts, including the Capitol Fly-In Program and member involvement at the state level. From coast to coast, ASCs welcomed legislators to their centers to educate them about the benefits that ASCs provide to patients and the health care system.
US Congressman Mike Thompson visited Specialty Care & Surgery Center in Kelseyville, CA. Dr. Paula Dhanda conducted the tour and relayed that Congressman Thompson seemed very receptive to what he heard.
US Congressman Joe Pitts visited Berks Center for Digestive Health in Reading, PA. Administrator John Gleason conducted the tour and voiced his opinions about the Patient Protection and Affordable Care Act (PPACA), the Removing Barriers to Colorectal Cancer Screening Act of 2012 (H.R. 4120) and the ASC Quality and Access Act of 2011 (H.R. 2108).
Member involvement has been critically important to ASCA’s advocacy efforts, with more than 85% of the cosponsors for the ASC Quality and Access Act of 2011 signing on as a result of member outreach. The Capitol Fly-In Program will be occurring again June 19-20, 2012. Members from Ohio, Oklahoma, California, Nevada, Massachusetts and Arizona are already scheduled to meet with their legislators in Washington, DC, and advocate on behalf of ASCs.
If a legislator visited your ASC this year, you would like to participate in the Capitol Fly-In Program or you want more information about hosting a congressional tour, please contact Morgan Hanson at mhanson@ascassociation.org.
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Senator Ron Wyden to Be Honored by Oregon State Society
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Senator Ron Wyden (D-OR) will be honored with the inaugural American Eagle Award for Distinguished Leadership by the Oregon Ambulatory Surgery Center Association (OASCA) at its annual meeting.
Senator Wyden, the lead Democratic sponsor of the ASC Quality and Access Act of 2011 (S. 1173), has been a longtime supporter of ASCs and the high-quality care that they provide.
In announcing the award, OASCA President Kecia Rardin stated, “I am truly excited and honored that Senator Ron Wyden has accepted our invitation to be our keynote speaker at our annual education conference on November 8th. He will also be presented with the American Eagle Award for Distinguished Leadership by Richard Edelson, MD, who is vice chair of OASCAPAC. I want to acknowledge Dr. Edelson and our Executive Director Rob Schwartz for building a strong relationship with the Senator and his staff.”
The ASC Quality and Access Act of 2011 (S. 1173/H.R. 2108) currently has six cosponsors in the Senate and 45 cosponsors in the House. To contact your members of Congress to request that they support the legislation, please click here.
For more information, please contact Steve Miller at smiller@ascassociation.org.
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ASC Association Government Affairs Report - April 19, 2012 |
Capitol Hill Takes On Drug Shortages
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Yesterday, the Senate Health, Education, Labor and Pensions (HELP) Committee led by Chairman Tom Harkin (D-IA) and Ranking Member Mike Enzi (R-WY) introduced the US Food and Drug Administration’s (FDA) Prescription Drug User Fee Reauthorization Act, which includes a section on preventing and mitigating drug shortages (click here to access the legislation. The drug shortages provision would require manufacturers to notify the FDA at least 6 months in advance of discounting or interrupting the manufacturing of a drug. The provision also requires distribution of information to stakeholders in the physician community so they can plan and adjust care accordingly.
The HELP Committee is scheduled to hold a hearing on the legislation later this month. In addition, Sen. Orrin Hatch (R-UT), Ranking Member on the Senate Finance Committee, released his own draft legislation on mitigating shortages by increasing Medicare reimbursement and providing manufacturers with additional years of exclusivity for drugs manufactured in combination with a shortage drug (click here to access a copy of the legislation).
In the House of Representatives, the Energy and Commerce Committee held its final hearing on the Senate version of the FDA’s Prescription Drug User Fee Reauthorization Act, which also includes a section to combat drug shortages. During the hearing, FDA Director Janet Woodcock outlined the steps the FDA currently takes to mitigate shortages. Members on both sides of the aisle were supportive of providing the FDA with additional tools to deal with shortages. The Energy and Commerce Committee’s draft legislation contains provisions similar to the Senate HELP legislation in that it expands notification requirements for manufacturers anticipating a discontinuance or interruption that may lead to a shortage, as well as improving communication and coordination between government agencies and stakeholders to mitigate interruptions in patient treatment.
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ASCs Storm Capitol Hill
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The National Capitol Fly-in program kicked off this week with the first of two events in 2012. ASCA members from six states—Alabama, Florida, New Hampshire, Tennessee, Texas and Washington—travelled to Washington, DC to participate in the event.
Participants gathered for a briefing dinner on Tuesday to learn about the current legislative environment in Washington, review legislation being supported by ASCA and receive advocacy training to help prepare them for the next day.
On Wednesday, participants began their day at an educational breakfast with Members of Congress, and went on to participate in over 60 meetings with their legislators and staff about the ASC Quality and Access Act of 2011, drug shortages and how ASCs are part of the solution to providing low-cost, high-quality health care for Americans.
For more information regarding the fly-in program or other opportunities to advocate for ASCs in Washington, DC or in your district, please contact Morgan Hanson at mhanson@ascassociation.org.
Pictured Above: Congressman David Schweikert (AZ-R) talking to participants of the April 2012 National Capitol Fly-In
Pictured Above: New Hampshire members, Joyce Meisel and Beverly Primeau speaking with Congressman Frank Guinta (NH-R)
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ASCA to CMS: Proposed Overpayment Identification Rule Overly Burdensome
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In comments submitted this week to the Centers for Medicare & Medicaid Services (CMS), ASCA objected to the agency’s burdensome proposal on indentifying and returning overpayments. The proposal would require ASCs and other health care providers to not only return overpayments when they learn of them, but also to investigate evidence of overpayments, such as telephone tips made to a compliance hotline. Those that failed to return overpayments or adequately investigate potential overpayments would face severe penalties under the False Claims Act, including repayment of three times the monetary damages and possible exclusion from the Medicare program.
ASCA commented that the proposal was overly broad and was particularly unfair for ASCs since they represent such a low level of overpayment risk. Noting that the rule as currently written would impose undue burden, ASCA urged CMS to establish a clearer and less onerous obligation to return overpayments.
A copy of ASCA’s comment letter is available here.
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A Doctor in the House at ASCA 2012
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US Representative Michael Burgess, MD, (R-TX) will share his unique insights on current congressional efforts to reform the health care system during a general session at ASCA 2012.
Rep. Burgess’s perspective has been shaped by more than 30 years as a practicing obstetrician–gynecologist in North Texas, followed by his election to the US House of Representatives in 2002. During his years practicing medicine, Rep. Burgess founded and provided care in an ASC.
He currently serves as the vice chair of the powerful House Energy and Commerce Committee’s Subcommittee on Health and is the chairman of the Congressional Health Care Caucus.
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ASC Association Government Affairs Report - April 12, 2012 |
New Cosponsor for ASC Quality and Access Act
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US Representative Charles Boustany, MD, (R-LA) has signed on as a cosponsor of the ASC Quality and Access Act of 2011 (H.R. 2108).
Rep. Boustany is a cardiovascular surgeon who is in his fourth term representing southwest Louisiana in Congress. Rep. Boustany has a seat on the influential Ways and Means Committee which has jurisdiction over health care issues. The ASC Quality and Access Act of 2011 now has 42 sponsors and cosponsors in the US House.
Visit ASCA’s ASC Quality and Access Act page for more information on the legislation, a list of cosponsors and to request that your member of Congress co-sponsor the legislation.
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Complete ASCA’s Drug Shortages Survey
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The availability of critical lifesaving medications has become a serious concern across the health care system. ASCA is conducting a brief Drug Shortage Survey to collect information that will help guide ASCA, and government agencies such as the US Food and Drug Administration (FDA), as they respond to these critical shortages. If your center has experienced a shortage within the past year, please take a couple minutes and fill out the survey.
In addition, ASCA has endorsed the Preserving Access to Life-Saving Medications Act (H.R. 2245/S. 296), which seeks to require manufacturers to notify the FDA of an impending shortage, and the Drug Shortage Prevention Act of 2012 (H.R. 3839), which would give the FDA the ability to expedite the review of critical drugs.
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Massachusetts Public Health Council Approves Emergency Regulations
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Emergency regulations to explicitly state that all ASCs in Massachusetts are subject to Determination of Need (DON) oversight were granted final approval by the Massachusetts Public Health Council this week. The council is the body within the state’s Department of Public Health (DPH) which is responsible for approving DON applications.
Massachusetts law was amended in 2008 to extend DON jurisdiction to Medicare-certified ASCs, which were previously exempt from oversight by the DPH. The department agreed to “grandfather” in any ASC, or allow the ASC to operate without a DON, provided no substantial changes were made to the ASC.
The DPH testified that the regulations simply clarify the changes that would subject grandfathered ASCs to DON oversight. Under the approved regulations, an ASC seeking to substantially change its facility, including adding service lines, will be required to receive DON approval, the same standard does not apply to hospitals. Hospital outpatient departments (HOPDs) are exempt from DON review provided the proposed changes cost less than $25 million.
Linda Rahm, president of the Massachusetts Association of Ambulatory Surgery Centers (MAASC), feels the regulations would eventually phase out ASCs. “The hospitals have an unfair advantage which perpetuates an uneven playing field,” according to Rahm. “Hospitals would be able to offer more and more outpatient surgery beds—sometimes in off-site facilities that resemble ASCs—without having to clear the same regulatory hurdles.”
The emergency regulations are now effective, but MAASC will continue to push for a level playing field under the state’s DON program.
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ICD-10 Compliance Deadline Delayed
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The US Department of Health & Human Services (HHS) this week issued a proposed rule that establishes October 1, 2014, as the new compliance date for the ICD-10 diagnostic code set. The new date is a full year later than the original deadline that was announced in 2009.
The new ICD-10 compliance date is part of a 198-page proposed rule that would also:
- adopt a standard for a national unique health plan identifier (HPID) and provisions for implementing that identifier;
- adopt a data element that would serve as an “other entity” identifier (OEID) for use by entities that are not health plans, health care providers or “individuals” that need to be identified in standard transactions; and
- add a national provider identifier (NPI) requirement specifying when covered health care providers must require non-covered health care providers to obtain and disclose an NPI.
Those changes, says HHS, will save the US health care system up to $4.6 billion over 10 years by enabling greater automation of electronic health care transactions.
The American Medical Association campaigned aggressively against the 2013 deadline, meanwhile, the American Health Information Management Association (AHIMA) and numerous health information technology (HIT) firms strongly supported the 2013 deadline.
Learn more about ICD-10 implementation on Saturday, May 12, during “ICD-10—What Your Staff Should Know and Do Now.” Cristina Bentin, CCS-P, CPC-H, CMA, founder and president of Coding Compliance Management, will present that session at ASCA 2012 in Dallas, Texas.
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ACO Participants Announced
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Earlier this week, the Centers for Medicare & Medicaid Services (CMS) announced the second round of accountable care organization (ACO) participants. The 27 new participating entities, which began operating on April 1, 2012, will serve an estimated 375,000 beneficiaries in 18 states. This brings the total number of organizations participating in Medicare shared savings initiatives to 65. That number includes the 32 early adopters of the Pioneer Model ACOs that were announced last December, and six Physician Group Practice Transition Demonstration organizations that started in January 2011.
Five of the 27 new ACOs will participate in the Advance Payment ACO Model, which is designed to encourage rural and physician-based ACOs. Under this model, each participating ACO will receive advance payments to help cover the costs of establishing the infrastructure needed to coordinate care for the beneficiaries they serve.
More information on Medicare’s ACO announcement, including information on the 27 ACO participants, is available here.
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ASC Association Government Affairs Report - April 5, 2012 |
Senate Letter to CMS Requests Data on ASC Conversions
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This week, 13 US Senators sent a letter to the Centers for Medicare & Medicaid Services (CMS) seeking data on the recent trend of ASCs being purchased and converted to hospital outpatient departments (HOPDs). Click here to read the letter.
The letter was addressed to Marilyn Tavenner, the Acting Administrator of CMS, and sought specific data on the costs to the Medicare system for 65 conversions that have happened since January 1, 2009. The effort to circulate the letter was led by Sen. Mike Crapo (R-ID) and Sen. Ron Wyden (D-OR), the sponsors of S. 1173, the ASC Quality and Access Act of 2011. The conversion data provided to CMS is based on research conducted by ASCA staff.
In the letter, the Senators point out that the inappropriate use of the Consumer Price Index – All Urban Consumers (CPI-U) to update ASC payments has led to a growing disparity in reimbursements between ASCs and HOPDs for similar procedures. The gap between the reimbursements for the two sites has grown from 86% in 2003 to 58% this year, and the letter makes clear that this disparity in payments may be driving the recent conversion trend.
In addition to Senators Wyden and Crapo, the letter was signed by the following Senators: Lamar Alexander (R-TN), Richard Burr (R-NC), Tom Coburn (R-OK), Bob Corker (R-TN), John Cornyn (R-TX), Chuck Grassley (R-IA), Ron Johnson (R-WI), Mary Landrieu (D-LA), Bill Nelson (D-FL), James Risch (R-ID) and David Vitter (R-LA).
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House Letter Seeks Change in Single Use Vial Policy
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A letter signed by 16 Republican House members is seeking modification of a CMS guideline prohibiting multiple uses of vials labeled for single use. The letter was drafted and circulated by Rep. Ed Whitfield (R-KY), a member of the House Energy and Commerce Subcommittee on Health.
In the letter, the House members argue that the policy is misguided and is causing increased costs to the Medicare system without improving the quality of patient care. The letter points out that “there is no data available to suggest that implementation of one vial per patient will improve quality or care or reduce patient harm. Further it may reduce access to many services.” Click here to read the letter.
The members of the House who signed the letter are: Dan Benishek, MD (R-MI), Brian Bilbray (R-CA), Marsha Blackburn (R-TN), Michael Burgess, MD (R-TX), Bill Cassidy, MD (R-LA), Geoff Davis (R-KY), Brett Guthrie (R-KY), Andy Harris, MD (R-MD), Billy Long (R-MO), Cathy McMorris Rodgers (R-WA), Devin Nunes (R-CA), Ron Paul, MD (R-TX), Phil Roe (R-TN), Mike Rogers (R-MI) and David Schweikert (R-AZ).
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Same Day Surgery Clarification
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CMS has issued a letter to its state survey agency directors clarifying that ASCs can provide required notifications to all of their patients on the day of surgery, without exception, as long as the information is provided before the surgery begins.
ASCA had long advocated for this regulatory revision. The clear restatement of the revised rule contained in the letter gives ASCs the support they need to be able to provide timely, patient-focused service to all of their patients and same-day treatment to patients in need.
Although this change became effective on December 23, 2011, CMS did not send an official notification to its state survey agencies at that time. Since the state agencies are responsible for enforcing the standards, some ASCs undergoing Medicare inspections since December 23 have encountered surveyors who were erroneously applying the previous requirement—that ASCs needed to provide this information at least one day before the date of surgery. ASCA worked to ameliorate these situations by providing ASCs with copies of the new regulatory text.
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Wisconsin Governor Signs ASC Legislation
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Governor Scott Walker signed an amended version of SB 297 on Monday, legislation originally drafted to eliminate the current assessment on ASCs in Wisconsin. The amended version was signed at a ceremony attended by industry leaders from the Association of Wisconsin Surgery Centers, Inc (WISCA).
Under current law, the state Department of Revenue (DOR) may impose an assessment on ASCs, and the state Department of Health Services (DHS) allocates any assessment among the ASCs in proportion to their gross patient revenue. The DOR must transfer 99.5 percent of all monies received from an assessment to the Medical Assistance (MA) trust fund, which finances a portion of the state’s Medical Assistance, or Wisconsin’s Medicaid program.
Amended language was necessary due to state budget constraints, and WISCA worked closely with the state legislature on a compromise. The revised legislation maintains the assessment, but provides that if at any time the federal government does not pay the federal share under the Medicaid program for any payment made with ASC assessment revenue, the DHS must refund those payments to the ASC. The amended language that was enacted mirrors how the hospital assessment is treated in the state.
Before making its way to the governor’s desk, the amended version of SB 297 passed both the Senate and Assembly with strong bipartisan support.
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ASCA Urges ASC Participation in CDC’s Annual ASC Survey
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The survey will collect information on the surgeries performed in ASCs and HOPDs in order to publish reports on outpatient surgery in the United States. These reports will be an important source of information for researchers and policy makers as they will show how many patients ASCs are serving each year.
No identifiable information for either ASCs or patients will be displayed and responses will be kept strictly confidential. Only ASCs that are asked to participate will be allowed to submit data.
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Drug Shortage Resources
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Many ASCs have been experiencing shortages of drugs, such as Fentanyl and Versed. While ASCA is working with other affected groups to find a long-term solution to this vexing problem, there are resources currently available where ASCs can help raise awareness of the shortages. The US Food and Drug Administration (FDA) is responsible for tracking shortages and is working with drug manufacturers to respond to the shortages. The FDA needs to be made aware of these shortages, which is where your help is requested. If your ASC is experiencing a problem obtaining necessary drugs, please report the problem to the FDA. You can file a report to the FDA here.
In addition, the American Society of Health-System Pharmacists (ASHP) is tracking which drugs are in short supply, timelines for delivery of drugs and alternatives that can be used in place of hard-to-obtain drugs. You can find this information by clicking here.
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New Workers' Compensation Reimbursement Manual Announced |
December 6, 2011
The Florida Division of Workers’ Compensation has filed the 2011 Workers’ Compensation Reimbursement Manual for Ambulatory Surgery Centers as final. The effective date of the Manual has been set retroactively at November 13, 2011.
The 2011 Manual does not contain any changes to the MRA schedule or reimbursement formulas. The Manual is significantly re-written and re-organized. FSASC encourages every member to review the Manual and to discuss the changes with their carrier representatives. Note that this 2011 Manual will require the use of the 2010 CPT coding Manual.
Features of the new Manual include:
- Significant reorganization of the contents;
- Transition to an electronic update log system;
- Updates to 2010 CPT and HCPCS;
- Numerous changes and expansions to Manual language.
Please contact us with any questions about the Manual at 850/222-3000 or peter@ascmember.org.
Supporting Documents: Florida ASC 2011 Work Comp Reimbursement Manual
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Medicare Permits Same-Day Surgery Without Exception |
On October 18th, the Centers for Medicare & Medicaid Services (CMS) released a final rule that removes its limitation on ASCs performing procedures on the day they are scheduled. ASCs will now be allowed to provide patient notifications on the day the procedure is performed, clearing the way for same-day surgeries.
The rule:
- Removes the requirement that the notice of patient rights must be provided "in advance of the date of the procedure" and replaces it with the requirement that the notice must be provided "prior to the start of the surgical procedure." This will allow ASCs to determine when they will provide these notices for all their patients as long as they are done prior to the surgical procedure being done. Particularly amends 416.50(a)(1) and other conditions.
- Removes the language of the previous exemption on this subject that provided for "emergency" notices being given on the day of surgery and outlining certain requirements that have to be met for the patient to qualify under the emergency criteria. Amends 416.50(h).
- Revises 416.50(d)(6) to add the patient's representative or the patient's surrogate to the parities that may be given written notice of a grievance decision.
This revision will take effect on December 23, 2011.
To download the complete rule change, click below.
Supporting Documents: CMS Same Day Rule PDF
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Medicaid Updates Florida Rates |
August 29, 2011
The Agency for Healthcare Administration (AHCA) has announced that effective immediately, it has updated the Medicaid reimbursement rates for ASCs. The new rates reflect a transition to Medicare APC pricing while retaining the Medicaid grouper system. The methodology consists in matching the current Medicare reimbursement for each CPT to its closest Medicaid grouper. In certain cases, new groupers were added when the existing Medicaid grouper system did not have a payment that was reflective of Medicare APC pricing.
A number of new procedures are now approved for Medicaid beneficiaries and several obsolete procedures have been removed and are now reimbursed under a more current CPT code. FSASC members should study the attached file to understand all of the changes.
AHCA is also revising the ASC Medicaid Handbook. They hope to hold a rule development workshop in September to hear public comments on the changes they are proposing to the Handbook. No date has been set as yet.
We will keep you posted on these important changes. Please contact us at 850/222-3000 with any questions.
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Updated Version of CMS Guidance for Surveyors: ASCs Released |
Updated Version of CMS Guidance for Surveyors: ASCs Released
CMS has published a new version of the State Operations Manual Appendix L – Guidance for Surveyors: Ambulatory Surgical Centers, which was updated May 13, 2011.
The changes are based on the Survey and Certification Memo issued December 17, 2010, titled “Clarifications to the ASC Interpretive Guidelines – Comprehensive Medical History & Physical (H&P) Assessment.” Among other revisions, a comprehensive H&P and surgery may now be performed on the same day.
Please review the changes in the interpretive guidelines for 416.42(a)(1) (pages 59-60) and 416.52(a)(1) and (2) (pages 157, 158 and 160).
For your reference, the document is being provided with page numbers included.
Supporting Documents: State Operations Manual - Appendix L ASCs 5-13-11
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CMS Issues Clarification on Same Day H&P Assessment |
CMS has released a memo clarifying the use of same day H&P assessments. Below is a summary of the memo.
· Comprehensive H&P and Surgery may be performed on same day: As long as the H&P is performed by qualified personnel, is comprehensive, and is placed in the patient’s ASC medical record prior to surgery, it may be performed on the same day as the surgical procedure, including in the ASC.
· Comprehensive H&P and some elements of the pre-surgical assessments may be conducted as one assessment: If the H&P is conducted in the ASC on the same day as the surgical procedure, then some elements of the required pre-surgical assessments may be incorporated into the H&P.
Click the link below to view the complete memo from CMS.
Supporting Documents: CMS H&P Memo
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