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Today, the Centers for Medicare & Medicaid Services (CMS) issued the Calendar Year (CY) 2024 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System Policy Changes and Payment Rates proposed rule, along with an accompanying fact sheet. The rule has a 60-day comment period, and ASCRS will be providing comments.
ASC Conversion Factor
For CY 2024, CMS proposes to adjust the CY 2023 ASC conversion factor ($51.854) by the proposed wage index budget neutrality factor of 1.0017 in addition to the productivity-adjusted hospital market basket update of 2.8% percent, which results in a proposed CY 2024 ASC conversion factor of $53.397 for ASCs meeting the quality reporting requirements.
For ASCs not meeting the quality reporting requirements, CMS is proposing to adjust the CY 2023 ASC conversion factor ($51.854) by the proposed wage index budget neutrality factor of 1.0017 in addition to the quality reporting/productivity-adjusted hospital market basket update of 0.8%, which results in a proposed CY 2024 ASC conversion factor of $52.358 for ASCs not meeting the quality reporting requirements.
Proposed ASC Payment Rate for Cataract Surgery
The proposed payment rate for cataract surgery, CPT 66984, is $1,164.90. Refer to Addendum AA of this proposed rule for additional payment rates for ophthalmic services provided in an ASC.
Separate Payment Under the ASC Payment System for Non-Opioid Pain Management Drugs and Biologicals that Function as Surgical Supplies
Previously, CMS finalized a policy that non-opioid pain management drugs or biologicals that function as a supply in a surgical procedure are eligible for separate payment if the drug or biological does not have transitional pass-through payment status, and is not already separately payable in the OPPS or ASC payment system under a different policy. CMS will continue this policy for CY 2024. As such, CMS proposes that Omidria (J1097) and Dextenza (J1096) would continue to receive separate payment in the ASC setting as non-opioid pain management drugs that function as a surgical supply for CY 2024.
Intraocular Procedures APC under the OPPS
Following previous changes in coding for Minimally Invasive Glaucoma Surgery (MIGS) and CMS’ latest analysis of claims data, the agency is proposing to create a sixth level in the Intraocular Procedures APC family base. To accomplish this, CMS proposes to divide APC 5492 into two APCs—one for services with a geometric mean cost of less than $5,000 and the other for services with a geometric mean cost of greater than, or equal to, $5,000 – to create a ‘‘Proposed APC 5493’’ with a payment rate of approximately $5,110.58. CMS notes this is closer to the geometric mean of CPT codes 66989 (Extracapsular cataract removal with IOL insertion, complex; with insertion of intraocular (e.g., trabecular meshwork, supraciliary, suprachoroidal) anterior segment aqueous drainage device, without extraocular reservoir, internal approach, one or more) and 66991 (Extracapsular cataract removal with IOL insertion; with insertion of intraocular (e.g., trabecular meshwork, supraciliary, suprachoroidal) anterior segment aqueous drainage device, without extraocular reservoir, internal approach, one or more). Despite having different estimated geometric mean costs, stakeholders have urged the agency to place these services within the same APC due to clinical similarity. CMS proposes to reassign CPT codes 66989 and 66991 to Proposed APC 5493 for CY 2024.
ASC Quality Reporting (ASCQR) Program
The ASCQR Program is a pay-for-reporting quality program for the ASC setting. The ASCQR Program requires ASCs to meet program requirements or receive a reduction in their annual fee schedule update.
Unfortunately, CMS is finalizing the Cataracts: Improvement in Patient's Visual Function within 90 Days Following Cataract Surgery (ASC-11) measure, which will continue to be voluntary in 2024, but mandatory in 2025. They are also proposing to clarify specific survey instruments that may be used to assess changes in a patient’s visual function beginning with the 2024 reporting period. These include:
- The National Eye Institute Visual Function Questionnaire-25 (NEI VFQ-25)
- Visual Functioning Patient Questionnaire (VF-14)
- The Visual Functioning Index Patient Questionnaire (VF-8R)
While recommending that physicians administer, collect, and report survey results to the ASC, CMS indicates that survey instruments can be administered by the ASC via phone, by the patient via regular mail or electronic mail, or during clinician follow-up.
ASCRS strongly opposes the inclusion of this measure and will continue to work to ensure that the reporting is not mandatory.
More information will be detailed in upcoming editions of Washington Watch Weekly.
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