2025 AMBULATORY SURGERY CENTER (ASC) PAYMENT SYSTEM AND QUALITY REPORTING (ASCQR) PROGRAM FINAL RULE RELEASED
2025 ASC Conversion Factor Finalized at $54.895 for
ASCs Meeting Quality Reporting Requirements
Today, the Centers for Medicare & Medicaid Services (CMS) issued the Calendar Year (CY) 2025 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System Policy Changes and Payment Rates final rules, along with an accompanying fact sheet.
ASC Conversion Factor
For CY 2025, CMS is adjusting the CY2024 ASC conversion factor ($53.514) by the finalized wage index budget neutrality factor of 0.9969 in addition to the productivity-adjusted hospital market basket update of 2.9% percent, which results in a CY2025 ASC conversion factor of $54.895 for ASCs meeting the quality reporting requirements.
For ASCs not meeting the quality reporting requirements, CMS is adjusting the CY 2024 ASC conversion factor ($53.514) by the finalized wage index budget neutrality factor of 0.9969 in addition to the quality reporting/productivity-adjusted hospital market basket update of 0.9%, which results in a CY2025 ASC conversion factor of $53.828 for ASCs not meeting the quality reporting requirements.
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. As a result, Omidria (J1097) and Dextenza (J1096) have been receiving separate payments in the ASC setting.
CMS has finalized provisions within the final rule to implement section 4135 of the Consolidated Appropriations Act of 2023, which provides temporary additional payment for certain non-opioid treatments for pain relief in the hospital outpatient department and ASC settings from January 1, 2025, through December 31, 2027. CMS will implement these statutory provisions, including evidence requirements for medical devices and FDA-approved drug indications. In addition, to implement the statutory payment limitations under which the additional payment may not exceed an estimated 18% of the OPPS payment for OPPS service or group of services with which the non-opioid treatment is provided, CMS will utilize the top five OPPS procedures by volume of each non-opioid drug to calculate the payment limitation.
Under these provisions, CMS has finalized seven drugs and one device to qualify as non-opioid treatments for pain relief. These products are to be paid separately in both the HOPD and ASC settings starting in CY2025, including Omidria (J1097) and Dextenza (J1096). The final payment limitations for these two drugs are:
- Omidria (J1097) payment limitation: $428.89
- Dextenza (J1096) payment limitation: $427.57
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.
CMS has not finalized any changes to the Cataracts: Improvement in Patient's Visual Function within 90 Days Following Cataract Surgery (ASC-11) measure, which will remain voluntary in 2025. ASCRS strongly opposes the inclusion of this measure and will continue to work to ensure that the reporting does not become mandatory in the future.
CMS has finalized as proposed the addition of the following three health equity-focused measures to the ASCQR in 2025:
- Facility Commitment to Health Equity (FCHE)
- Mandatory beginning in 2025
- Assesses 5 domains and is similar to the existing Hospital Commitment to Health Equity (HCHE) measure.
- Screening for Social Drivers of Health (SDOH)
- Voluntary for 2025, Mandatory beginning in 2026
- This measure is similar to the MIPS measure of the same name (measure 487), with the only major difference being the site of service limited to ASCs.
- Screen Positive Rate for SDOH
- Voluntary for 2025, Mandatory beginning in 2026
- Using the results of the SDOH screens, report 5 separate performance rates (1 rate for each health-related social needs domain surveyed under the screening measure).
More information will be detailed in upcoming editions of Washington Watch Weekly.