OOSS Demands Higher Annual Update and Withdrawal of Misguided Cataract Quality Measures in Comments to CMS

On September 6, the Outpatient Ophthalmic Surgery Society (in collaboration with the Academy, ASCRS, and ASRS) submitted formal comments to the Centers for Medicare and Medicaid Services (CMS) on its proposed rule to update ASC payment rates and expand quality reporting requirements for ASCs.

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 used to update hospital outpatient department payment rates and is typically about a point higher.  The ophthalmic ASC community also urged CMS to utilize the same reimbursement policies for ASCs and HOPDs with respect to the Medicare wage index, billing for services under unlisted codes, and payment for device-intensive surgical procedures.

In this rule, CMS is proposing that, commencing in 2014 for purposes of 2016 payment determinations, ASCs report on two new ophthalmic quality measures:

• Complications Within 30 days Following Cataract Surgery Requiring Additional Surgical Procedures (NQF#0564); and,
• Improvement in Patient’s Visual Function Within 90 days Following Cataract Surgery (NQF#1536).

We are opposed to both of these measures and have vigorously urged that they be withdrawn.  First, both measures were designed for reporting by physicians and never intended to serve as measures of facility-level quality.  Second, because ophthalmic surgeons are already reporting on these measures, requiring ASCs to do likewise is duplicative.  Most importantly, these measures are inappropriate because ASCs are not in a position to efficiently collect and report data that is located in the medical records of the surgeon in his or her office-based practice.  The ophthalmology community has reiterated to CMS our willingness to develop and implement eye measures that are appropriate for the ASC and would embody the potential to improve surgical outcomes.

OOSS also joined ASCRS in the submission of comments to CMS on policies relating to the Medicare Physician Fee Schedule.

OOSS’ comments to CMS on the ASC Rule may be reviewed by clicking here.

For more information, contact OOSS Washington Counsel, Michael Romansky, atmromansky@OOSS.org.