OOSS joined the AAO and ASCRS in submitting comments to the Centers for Medicare and Medicaid Services (CMS) regarding its proposed 2012 ASC payment regulation.  As in past years, we strenuously objected to CMS’ use of the Consumer Price Index (Urban) as the update factor for ASCs, urging instead that facilities be afforded the Hospital Market Basket, which is provided hospital outpatient departments and is typically about a point higher. 

 This regulation was significant in that CMS also proposed that ASCs be subject to quality reporting commencing January 1, 2012 and be subject to penalties in 2014.  OOSS recommended that the new program be voluntary through 2013 and that the performance period commence in 2014. Moreover, penalties should start at no greater than 0.4 percent, consistent with the inpatient hospital program.  OOSS comments also included substantive recommendations regarding data collection, measure development, future topics, and other important issues.

 OOSS’ comments to CMS may be reviewed at FINAL AAO-ASCRS-OOSS Comments ASC 2012 NPRM 8-30-11.

The CMS proposed rule may be viewed at: http://www.gpo.gov/fdsys/pkg/FR-2011-07-18/pdf/2011-16949.pdf

 For more information, contact Mike Romansky at mromansky@OOSS.org.