Medicare’s Quality Reporting for Ambulatory Surgical Centers

1. Medicare’s Quality Reporting for Ambulatory Surgical Centers Putting the Pieces Together Anita J. Bhatia, PhD, MPH Program Lead, ASC Quality Reporting Program Centers for Medicare and Medicaid Services September, 2012

2. Objectives Present the Program Pieces Discuss the Program Connect the Program Pieces Provide sources of information and assistance Check on the Pieces

3. Pieces Program Participants Reporting Requirements Reporting Mechanisms Validation Extension, Waiver, & Reconsideration Requests Questions & Answers Online Assistance References

4. Program Quality measure data reporting for ASCs – promotes quality through measurement and publication ASCs that do not meet program requirements face a 2% reduction in their Medicare annual payment update Initial implementation: CY 2012 to affect CY 2014 payment Pay for Reporting; No performance thresholds

5. Participants : ASCs An ASC for Medicare purposes is a distinct entity that operates exclusively for the purpose of furnishing outpatient surgical services to patients. The ASC must have in effect an agreement with CMS obtained in accordance with 42 CFR 416 subpart B (General Conditions and Requirements). An ASC is either independent (i.e. not a part of a provider of services or any other facility), or operated by a hospital (i.e. under the common ownership, licensure or control of a hospital). A hospital operated facility has the option of being considered by Medicare either to be an ASC or to be a provider-based department of the hospital as defined in 42 CFR 413.65

6. Program Requirements Administrative Requirements • QualityNet Account & Administrator • Participation Status Requirements Regarding Form, Manner, & Timing for Claims-based Measures • ASCs are to report quality measure data to CMS beginning with October 1, 2012 services • Minimum case thresholds Validation

7. Administrative Requirements: Quality Net Account and Administrator • In May 2013, ASCs can register with QualityNet • https://www.qualitynet.org/dcs/ContentServer?c=Page&pagename=QnetPublic%2FPage%2FQnetTier1&cid=1138115987249 • Recommend two (2) active Security Administrators per facility Participation Status • An ASC is considered as participating by submitting claims with QDCs • To withdraw from the ASC program, an ASC must submit on online participation form indicating the desire to withdraw from the program • An ASC can withdraw for the program anytime up to August 31, 2013 for the CY 2014 payment determination

8. Form, Manner, Timing Requirements for Claims-based Measures • ASCs are to report quality measure data to CMS beginning with October 1, 2012 services • Minimum case thresholds • CY 2014 payment; finalized a 50% completeness threshold in the FY 2013 IPPS/LTCH final rule • CY 2015 payment; proposed a 50% completeness threshold in the CY 2013 OPPS/ASC proposed rule

9. Reporting Mechanisms Claims Using Quality Data Codes • Patient Burn • Patient Fall • Wrong Site, Wrong Side, Wrong Patient, Wrong Procedure, Wrong Implant • Hospital Admission/Transfer • Prophylactic IV Antibiotic Timing Web-based tool • Safe Surgery Check List Use • ASC Facility Volume Data on Selected ASC Surgical Procedures National Health Care Safety Network • Influenza Vaccination Coverage Among Health Care Workers

10. Quality Data Codes (QDC) Submit on the CMS-1500 • These codes will populate fields 24D and 24F on the Form CMS-1500 • Submitted charge field cannot be blank, a line item charge should be the numeral “0” • If the system does not accept a “0” then a nominal amount can be submitted, the beneficiary is not responsible to this amount QDCs can be found in the ASC Specifications Manual https://www.qualitynet.org/dcs/ContentServer?c=Page&pagename=QnetPublic%2FPage%2FQnetBasic&cid=1228772323772 Only required to apply to claim forms where Medicare is the primary payer thru December 31, 2012 services Required for services January 1, 2013 onward for claims where Medicare is the primary OR secondary payer; may submit for services beginning April 2012

11. Measures

12. Validation As stated in the FY 2013 IPPS/LTCH final rule No requirement for validation of structural measures No requirement for validation of the current claims-based measures As experience gained with the program, CMS will reassess whether a data validation process is needed

13. Extension, Waiver, & Reconsideration Requests Extraordinary Circumstances extension and waivers are available on the QualityNet Web site • Must submit 45 days from when the extraordinary circumstance occurred • Must provide evidence of the circumstance incident Reconsideration Process • For failure of meeting ASC Quality Reporting Program Requirements • Submit a reconsideration request form available on the QualityNet • Must be submitted by March 17th of the affected payment year

14. Questions & Answers Accessible via link on www.qualitynet.org or directly https://cms-ocsq.custhelp.com/ Found on Website on QualityNet Outpatient Questions and Answers Specific Questions and Answers related to ASCs Must sign-in and create an account with password to ask a question https://cms-ocsq.custhelp.com/

15. Assistance ASC Quality Reporting Web page www.qualitynet.org ASC Quality Reporting section www.cms.hhs.gov Listserv https://www.qualitynet.org/dcs/ContentServer?pagename=QnetPublic/ListServe/Register Direct Support • Telephone (toll-free) 1-866-800-8756, Monday-Friday 7:00 am to 6:00 pm Eastern Time • Email http://www.hospitaloqr@fmqai.com

16. Public Reporting Per statute, data collected under the ASC Quality Reporting Program is to be made publicly available Finalized in the FY 2013 IPPS/LTCH final rule that any and all data collected could be made available Earliest publication would be in 2014

17. References: Rules CY 2012 OPPS/ASC final rule (published) • http://www.gpo.gov/fdsys/pkg/FR-2012-07-30/pdf/2012-16813.pdf FY 2013 IPPS/LTCH Final Rule Home Page (display) • http://www.ofr.gov/OFRUpload/OFRData/2012-19079_PI.pdf CY 2013 OPPS/ASC proposed rule (published) • http://www.gpo.gov/fdsys/pkg/FR-2012-07-30/pdf/2012-16813.pdf

18. Additional References Ambulatory Surgical Centers Center http://www.cms.gov/Center/Provider-Type/Ambulatory-Surgical-Centers-ASC-Center.html • Transmittal 2425 • CY 2012 OPPS/ASC final rule • HHS Report to Congress (ASC Value Based Purchasing)

19. Checking the Pieces What can be improved? What do you like? Do you like anything? What don’t you like? What do you think? Thank you! anita.bhatia@cms.hhs.gov