Medicare Quality Reporting FAQs

On November 2, 2018, the Centers for Medicare & Medicaid Services (CMS) released its final 2019 payment rule for ASCs and hospital outpatient departments (HOPD). In addition to 2019 payment rates, that rule contains new requirements for Medicare’s ASC quality reporting program. ASCs that do not meet the reporting requirements could be subject to future reductions in their Medicare payments.

In short, under the new rules, ASCs can stop reporting anything on Medicare claims beginning January 1, 2019. They can also stop reporting ASC-8 immediately and stop collecting data on ASC-10 on January 1, 2019. To qualify for their full payment update in 2020, however, facilities still need to report the data they collected in 2018 on measures ASC-9 and ASC-10 in 2019. Reporting on ASC-11 is already voluntary, so there are no additional reporting requirements tied to that measure.

Beginning in 2019, ASCs will also need to report information they began collecting in 2018 on two new measures—ASC-13: Normothermia and ASC-14: Unplanned Anterior Vitrectomy.

To help ASCs comply with all of Medicare’s 2019 quality reporting requirements, ASCA is making several free resources available to all ASCs. These include:

  • a comprehensive analysis of the changes and new rules introduced in 2019 posted on ASCA’s website (a link to that information will be included here once it is available)
  • a webinar titled “CMS Quality Reporting for ASCs,” which is now available on demand 
  • a short interview with ASCA Chief Executive Officer Bill Prentice that includes information about some of the quality reporting changes and ASCA’s insights into those changes
  • responses to questions ASCA has received on the new rules (see below)

More information on Medicare ASC quality reporting compliance will also be presented at the ASCA 2019 Conference and Expo in Nashville, May 15–18, 2019. A registration fee is required to participate in that event.

ASCA recommends that all ASCs review the comprehensive compliance resources that ASCA provides. Please contact Kara Newbury at knewbury@ascassociation.org with any other questions.

2019 Medicare Quality Reporting FAQs

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When do we stop reporting on ASC-1 (Patient Burn), ASC-2 (Patient Fall), ASC-3 (Wrong Site, Wrong Side, Wrong Patient, Wrong Procedure, Wrong Implant) and ASC-4 (Hospital Transfer/Admission)?

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Continue collecting and reporting the G-codes for ASC 1-4 on each Medicare fee-for-service Part B claim (1500 form) where Medicare is the primary or secondary payer through December 31, 2018. Beginning January 1, 2019, you no longer need to collect or report the G-codes for these measures in the CMS Ambulatory Surgery Center Quality Reporting (ASCQR) Program. However, you can continue to collect and report the data for your internal quality assurance performance improvement program or if your ASC participates in benchmarking surveys.

 

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What is the difference between a measure being removed or suspended?

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A measure that is suspended would remain in the CMS ASCQR Program measure set and could potentially return to the program. Typically, when a measure is removed it no longer remains in the CMS ASCQR Program.

 

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What happens if my center continues to put G-codes on the Medicare fee-for-service Part B claim (1500 form) for ASC-1 (Patient Burn), ASC-2 (Patient Fall), ASC-3 (Wrong Site, Wrong Side, Wrong Patient, Wrong Procedure, Wrong Implant) and ASC-4 (Hospital Transfer/Admission)?

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Claims will continue to be processed with G-codes or Quality Data Codes (QDCs), however, the data will not be used or published.

 

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If there has been incorrect billing for G-codes or Quality Data Codes (QDCs), can this be removed/corrected?

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Once a claim has been submitted, the ASC can’t refile the claim to correct the G-code or QDCs.

 

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Do ASCs still have to report on ASC-5 (Prophylactic IV Antibiotic Timing)?

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ASC-5 was removed from the CMS ASCQR Program starting in January 2018. However, you can continue to collect and report the data for your internal quality assurance performance improvement program or if your ASC participates in benchmarking surveys. This is still considered “best practice.”

 

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Do ASCs still have to report on ASC-6 (Safe Surgery Checklist Use) and ASC-7 (ASC Facility Volume Data on Selected ASC Surgical Procedures)?

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ASC-8 was removed from the ASCQR Program for calendar year (CY) 2020 payment determinations, which means it will not be reported in 2019. For purposes of meeting federal requirements, ASCs are no longer required to collect this information effective immediately.

 

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You say that CMS no longer requires the collection and reporting of data for ASC-8 (Influenza Vaccination Coverage Among Healthcare Personnel) on a federal level, but individual states may still require it. How can I find out if my state requires it?

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It is recommended to contact the entity that licenses ASCs in your state or OSHA (if your state has a state-run program). ASCA members can obtain contact information for their state regulator here: https://www.ascassociation.org/asca/govtadvocacy/stateresourcecenter/statelawdatabase?CLK=1555e331-bf87-4d43-be84-d6bb1730cefd. The Centers for Disease Control and Prevention (CDC) also has more information on state requirements here: https://www.cdc.gov/phlp/publications/topic/menus/acfinfluenza/index.html.

 

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Do we still need to report on ASC-9 (Endoscopy/Polyp Surveillance: Appropriate Follow-Up Interval for Normal Colonoscopy in Average Risk Patients) and ASC-10 (Endoscopy/Polyp Surveillance: Colonoscopy Interval for Patients with a History of Adenomatous Polyps – Avoidance of Inappropriate Use)?

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Data collected in 2018 for both ASC-9 and ASC-10 must be reported by May 15, 2019. Moving forward, ASC-10 has been removed from the ASCQR Program, so only data for ASC-9 must be collected in 2019 and beyond.

 

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How does an ASC correct a discrepancy on the claims detail report for ASC-12 (Facility Seven-Day Risk-Standardized Hospital Visit Rate after Outpatient Colonoscopy) if the hospital visit was not related to the colonoscopy?

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ASCs cannot correct the claims detail report. In addition, this measure is an all cause measure for any unplanned hospital visit within seven days of a qualifying outpatient colonoscopy. The measure defines a hospital visit as any ED visit, observation stay, or unplanned inpatient admission, so even if the hospital visit was not related to the colonoscopy, it should be reported.

 

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How frequently can you get the data on measures for ASC-12 (Facility Seven-Day Risk-Standardized Hospital Visit Rate after Outpatient Colonoscopy), ASC-17 (Hospital Visits after Orthopedic Ambulatory Surgical Center Procedures) and ASC-18 (Hospital Visits after Urology Ambulatory Surgical Center Procedures)?

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CMS plans to release Claims-Detail Reports (CDRs) and Facility-Specific Reports (FSRs) reports multiple times a year. These reports will be made available via the QualityNet Secure Portal prior to public reporting of the measures. In the past, CMS has released these reports during the months/years listed below:

  • 3 Claims-Detail Reports (CDRs)
    • Released in September and December of 2017, and March of 2018, and containing data from a portion of CY 2017.
  • 1 Facility- Specific Report (FSR)
    • Released in October 2018 and based on data from CY 2017.

 

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Is the sampling for ASC-13 (Normothermia Outcome) only Medicare patients or all patients?

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The data submitted for ASC-13 is a sampling that meets the denominator criteria (all patients, regardless of age, undergoing surgical procedures under general or neuraxial anesthesia of greater than or equal to 60 minutes duration).

 

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For ASC-17 (Hospital Visits after Orthopedic Ambulatory Surgical Center Procedures) and ASC-18 (Hospital Visits after Urology Ambulatory Surgical Center Procedures), will there be a payment penalty from Medicare in 2022 if there are a certain number of hospital visits within seven days of the orthopedic or urology procedure? If so, how will CMS determine if a penalty is warranted and how much will the penalty be?

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The ASC program is still considered “pay for reporting” and not “pay for performance.” For ASC-17 and ASC-18, the measures’ results or number of hospital visits within seven days of the orthopedic or urology procedure will not impact payment or cause a penalty at this time.