1. Medicare’s Quality Reporting for Ambulatory Surgical Centers Putting the Pieces Together Anita J. Bhatia, PhD, MPH Program Lead, ASC Quality Reporting Program Centers for Medicare and Medicaid Services September, 2012 Putting the Pieces Together Anita J. Bhatia, PhD, MPH Program Lead, ASC Quality Reporting Program Centers for Medicare and Medicaid Services September, 2012 1

2. Objectives Present the Program Pieces Discuss the Program Connect the Program Pieces Provide sources of information and assistance Check on the Pieces Present the Program Pieces Discuss the Program Connect the Program Pieces Provide sources of information and assistance Check on the Pieces 2

3. Pieces Program Participants Reporting Requirements Reporting Mechanisms Validation Extension, Waiver, & Reconsideration Requests Questions & Answers Online Assistance References Program Participants Reporting Requirements Reporting Mechanisms Validation Extension, Waiver, & Reconsideration Requests Questions & Answers Online Assistance References 3

4. Program Quality measure data reporting for ASCs – promotes quality through measurement and publication ASCs that do not meet program requirements face a 2% reduction in their Medicare annual payment update Initial implementation: CY 2012 to affect CY 2014 payment Pay for Reporting; No performance thresholds Quality measure data reporting for ASCs – promotes quality through measurement and publication ASCs that do not meet program requirements face a 2% reduction in their Medicare annual payment update Initial implementation: CY 2012 to affect CY 2014 payment Pay for Reporting; No performance thresholds 4

5. Participants : ASCs An ASC for Medicare purposes is a distinct entity that operates exclusively for the purpose of furnishing outpatient surgical services to patients. The ASC must have in effect an agreement with CMS obtained in accordance with 42 CFR 416 subpart B (General Conditions and Requirements). An ASC is either independent (i.e. not a part of a provider of services or any other facility), or operated by a hospital (i.e. under the common ownership, licensure or control of a hospital). A hospital operated facility has the option of being considered by Medicare either to be an ASC or to be a provider-based department of the hospital as defined in 42 CFR 413.65 5

6. Program Requirements Administrative Requirements QualityNet Account & Administrator Participation Status Requirements Regarding Form, Manner, & Timing for Claims-based Measures ASCs are to report quality measure data to CMS beginning with October 1, 2012 services Minimum case thresholds Validation Administrative Requirements QualityNet Account & Administrator Participation Status Requirements Regarding Form, Manner, & Timing for Claims-based Measures ASCs are to report quality measure data to CMS beginning with October 1, 2012 services Minimum case thresholds Validation 6

7. Administrative Requirements: Quality Net Account and Administrator In May 2013, ASCs can register with QualityNet https://www.qualitynet.org/dcs/ContentServer?c=Page&pagen ame=QnetPublic%2FPage%2FQnetTier1&cid=1138115987249 https://www.qualitynet.org/dcs/ContentServer?c=Page&pagen ame=QnetPublic%2FPage%2FQnetTier1&cid=1138115987249 Recommend two (2) active Security Administrators per facility Participation Status An ASC is considered as participating by submitting claims with QDCs To withdraw from the ASC program, an ASC must submit on online participation form indicating the desire to withdraw from the program An ASC can withdraw for the program anytime up to August 31, 2013 for the CY 2014 payment determination Quality Net Account and Administrator In May 2013, ASCs can register with QualityNet https://www.qualitynet.org/dcs/ContentServer?c=Page&pagen ame=QnetPublic%2FPage%2FQnetTier1&cid=1138115987249 https://www.qualitynet.org/dcs/ContentServer?c=Page&pagen ame=QnetPublic%2FPage%2FQnetTier1&cid=1138115987249 Recommend two (2) active Security Administrators per facility Participation Status An ASC is considered as participating by submitting claims with QDCs To withdraw from the ASC program, an ASC must submit on online participation form indicating the desire to withdraw from the program An ASC can withdraw for the program anytime up to August 31, 2013 for the CY 2014 payment determination 7

8. Form, Manner, Timing Requirements for Claims-based Measures ASCs are to report quality measure data to CMS beginning with October 1, 2012 services Minimum case thresholds CY 2014 payment; finalized a 50% completeness threshold in the FY 2013 IPPS/LTCH final rule CY 2015 payment; proposed a 50% completeness threshold in the CY 2013 OPPS/ASC proposed rule ASCs are to report quality measure data to CMS beginning with October 1, 2012 services Minimum case thresholds CY 2014 payment; finalized a 50% completeness threshold in the FY 2013 IPPS/LTCH final rule CY 2015 payment; proposed a 50% completeness threshold in the CY 2013 OPPS/ASC proposed rule 8

9. Reporting Mechanisms Claims Using Quality Data Codes − Patient Burn − Patient Fall − Wrong Site, Wrong Side, Wrong Patient, Wrong Procedure, Wrong Implant − Hospital Admission/Transfer − Prophylactic IV Antibiotic Timing Web-based tool − Safe Surgery Check List Use − ASC Facility Volume Data on Selected ASC Surgical Procedures National Health Care Safety Network Influenza Vaccination Coverage Among Health Care Workers Claims Using Quality Data Codes − Patient Burn − Patient Fall − Wrong Site, Wrong Side, Wrong Patient, Wrong Procedure, Wrong Implant − Hospital Admission/Transfer − Prophylactic IV Antibiotic Timing Web-based tool − Safe Surgery Check List Use − ASC Facility Volume Data on Selected ASC Surgical Procedures National Health Care Safety Network Influenza Vaccination Coverage Among Health Care Workers 9

10. Quality Data Codes (QDC) Submit on the CMS-1500 o These codes will populate fields 24D and 24F on the Form CMS-1500 o Submitted charge field cannot be blank, a line item charge should be the numeral “0” o If the system does not accept a “0” then a nominal amount can be submitted, the beneficiary is not responsible to this amount QDCs can be found in the ASC Specifications Manual https://www.qualitynet.org/dcs/ContentServer?c=Page&pagename=Qne tPublic%2FPage%2FQnetBasic&cid=1228772323772 https://www.qualitynet.org/dcs/ContentServer?c=Page&pagename=Qne tPublic%2FPage%2FQnetBasic&cid=1228772323772 Only required to apply to claim forms where Medicare is the primary payer thru December 31, 2012 services Required for services January 1, 2013 onward for claims where Medicare is the primary OR secondary payer; may submit for services beginning April 2012 Submit on the CMS-1500 o These codes will populate fields 24D and 24F on the Form CMS-1500 o Submitted charge field cannot be blank, a line item charge should be the numeral “0” o If the system does not accept a “0” then a nominal amount can be submitted, the beneficiary is not responsible to this amount QDCs can be found in the ASC Specifications Manual https://www.qualitynet.org/dcs/ContentServer?c=Page&pagename=Qne tPublic%2FPage%2FQnetBasic&cid=1228772323772 https://www.qualitynet.org/dcs/ContentServer?c=Page&pagename=Qne tPublic%2FPage%2FQnetBasic&cid=1228772323772 Only required to apply to claim forms where Medicare is the primary payer thru December 31, 2012 services Required for services January 1, 2013 onward for claims where Medicare is the primary OR secondary payer; may submit for services beginning April 2012 10

11. Measures 11 MeasureReporting PeriodInitial Payments Affected 1. Patient BurnOct 1, 2012 thru Dec 31, 2012CY 2014 2. Patient FallOct 1, 2012 thru Dec 31, 2012CY 2014 3. Wrong Site, Side, Patient, Procedure, Implant Oct 1, 2012 thru Dec 31, 2012CY 2014 4. Hospital Admission/TransferOct 1, 2012 thru Dec 31, 2012CY 2014 5. Prophylactic IV Antibiotic TimingOct 1, 2012 thru Dec 31, 2012CY 2014 6. Safe Surgery Check List UseJul 1, 2013 thru Aug 15, 2013 (for Jan 1 to Dec 31, 2012) CY 2015 7. Volume of Selected Procedures (all-payer) Jul 1, 2013 thru Aug 15, 2013 (for Jan 1 to Dec 31, 2012) CY 2015 8. Influenza Vaccination Coverage Among Health Care Workers Oct 1, 2014 thru Mar 31, 2015CY 2016

12. Validation As stated in the FY 2013 IPPS/LTCH final rule No requirement for validation of structural measures No requirement for validation of the current claims- based measures As experience gained with the program, CMS will reassess whether a data validation process is needed As stated in the FY 2013 IPPS/LTCH final rule No requirement for validation of structural measures No requirement for validation of the current claims- based measures As experience gained with the program, CMS will reassess whether a data validation process is needed 12

13. Extension, Waiver, & Reconsideration Requests Extraordinary Circumstances extension and waivers are available on the QualityNet Web site o Must submit 45 days from when the extraordinary circumstance occurred o Must provide evidence of the circumstance incident Reconsideration Process o For failure of meeting ASC Quality Reporting Program Requirements o Submit a reconsideration request form available on the QualityNet o Must be submitted by March 17 th of the affected payment year Extraordinary Circumstances extension and waivers are available on the QualityNet Web site o Must submit 45 days from when the extraordinary circumstance occurred o Must provide evidence of the circumstance incident Reconsideration Process o For failure of meeting ASC Quality Reporting Program Requirements o Submit a reconsideration request form available on the QualityNet o Must be submitted by March 17 th of the affected payment year 13

14. Questions & Answers Accessible via link on www.qualitynet.org or directly https://cms-ocsq.custhelp.com/www.qualitynet.org https://cms-ocsq.custhelp.com/ Found on Website on QualityNet Outpatient Questions and Answers Specific Questions and Answers related to ASCs Must sign-in and create an account with password to ask a question https://cms-ocsq.custhelp.com/ Accessible via link on www.qualitynet.org or directly https://cms-ocsq.custhelp.com/www.qualitynet.org https://cms-ocsq.custhelp.com/ Found on Website on QualityNet Outpatient Questions and Answers Specific Questions and Answers related to ASCs Must sign-in and create an account with password to ask a question https://cms-ocsq.custhelp.com/ 14

15. Assistance ASC Quality Reporting Web page www.qualitynet.orgwww.qualitynet.org ASC Quality Reporting section www.cms.hhs.govwww.cms.hhs.gov Listserv https://www.qualitynet.org/dcs/ContentServer?pagename=QnetPublic /ListServe/Register https://www.qualitynet.org/dcs/ContentServer?pagename=QnetPublic /ListServe/Register Direct Support Telephone (toll-free) 1-866-800-8756, Monday-Friday 7:00 am to 6:00 pm Eastern Time Email http://www.hospitaloqr@fmqai.comhttp://www.hospitaloqr@fmqai.com ASC Quality Reporting Web page www.qualitynet.orgwww.qualitynet.org ASC Quality Reporting section www.cms.hhs.govwww.cms.hhs.gov Listserv https://www.qualitynet.org/dcs/ContentServer?pagename=QnetPublic /ListServe/Register https://www.qualitynet.org/dcs/ContentServer?pagename=QnetPublic /ListServe/Register Direct Support Telephone (toll-free) 1-866-800-8756, Monday-Friday 7:00 am to 6:00 pm Eastern Time Email http://www.hospitaloqr@fmqai.comhttp://www.hospitaloqr@fmqai.com 15

16. Public Reporting Per statute, data collected under the ASC Quality Reporting Program is to be made publicly available Finalized in the FY 2013 IPPS/LTCH final rule that any and all data collected could be made available Earliest publication would be in 2014 Per statute, data collected under the ASC Quality Reporting Program is to be made publicly available Finalized in the FY 2013 IPPS/LTCH final rule that any and all data collected could be made available Earliest publication would be in 2014 16

17. References: Rules CY 2012 OPPS/ASC final rule (published) http://www.gpo.gov/fdsys/pkg/FR-2012-07-30/pdf/2012- 16813.pdf http://www.gpo.gov/fdsys/pkg/FR-2012-07-30/pdf/2012- 16813.pdf FY 2013 IPPS/LTCH Final Rule Home Page (display) http://www.ofr.gov/OFRUpload/OFRData/2012-19079_PI.pdf CY 2013 OPPS/ASC proposed rule (published) http://www.gpo.gov/fdsys/pkg/FR-2012-07-30/pdf/2012- 16813.pdf http://www.gpo.gov/fdsys/pkg/FR-2012-07-30/pdf/2012- 16813.pdf CY 2012 OPPS/ASC final rule (published) http://www.gpo.gov/fdsys/pkg/FR-2012-07-30/pdf/2012- 16813.pdf http://www.gpo.gov/fdsys/pkg/FR-2012-07-30/pdf/2012- 16813.pdf FY 2013 IPPS/LTCH Final Rule Home Page (display) http://www.ofr.gov/OFRUpload/OFRData/2012-19079_PI.pdf CY 2013 OPPS/ASC proposed rule (published) http://www.gpo.gov/fdsys/pkg/FR-2012-07-30/pdf/2012- 16813.pdf http://www.gpo.gov/fdsys/pkg/FR-2012-07-30/pdf/2012- 16813.pdf 17

18. Additional References Ambulatory Surgical Centers Center http://www.cms.gov/Center/Provider- Type/Ambulatory-Surgical-Centers-ASC-Center.html Transmittal 2425 CY 2012 OPPS/ASC final rule HHS Report to Congress (ASC Value Based Purchasing) Ambulatory Surgical Centers Center http://www.cms.gov/Center/Provider- Type/Ambulatory-Surgical-Centers-ASC-Center.html Transmittal 2425 CY 2012 OPPS/ASC final rule HHS Report to Congress (ASC Value Based Purchasing) 18

19. Checking the Pieces What can be improved? What do you like? Do you like anything? What don’t you like? What do you think? Thank you! anita.bhatia@cms.hhs.gov What can be improved? What do you like? Do you like anything? What don’t you like? What do you think? Thank you! anita.bhatia@cms.hhs.gov 19