ASC CMS Quality Measure Reporting: Why, What, When, Where & How

The following article was written by Ann O'Neill, RN, MBA/HCM, director of clinical operations for Regent Surgical Health.

By now, almost everyone in the ASC industry is aware of the new CMS quality measure reporting requirements. What you might like to know is why, what, when, where, and how data is to be collected and reported. Some of those questions will be answered here; however, CMS has not yet published all the detail that will be needed for full participation in reporting by ASCs.

Why:

Simply stated, the driver for monitoring, measuring, and analyzing these quality measures is to improve patient outcomes. It is an industry-wide approach to advance patient safety. CMS will be using quality measures as a leverage to control healthcare reimbursement.

Infection and injury to patients are bad for the patient, bad for the provider and bad for the industry. Many agencies have been trying to address these issues for years. Some of the pioneering agencies that have influenced the development of the newly required measures include: CMS, CDC, the Agency for Healthcare Research and Quality, the Indian Health Service, the Food and Drug Administration, National Quality Forum, National Healthcare Safety Network, ASC Quality Collaboration, the Word Health Organization and The Surgical Care Improvement Project national quality partnership of organizations.

Hospitals were the first providers required by CMS to report quality measures or face financial sanctions for non-participation.  However, with the Tax Relief and Health Care Act of 2006, Congress gave permission to CMS to create a required ASC quality measure reporting system that is tied to reimbursement. The Act also allows CMS to impose a payment penalty of up to 2 percent for any ASC that fails to submit the required data.

Objective measurement is the only way to evaluate clinical performance of an organization’s people and processes. Comparing to industry benchmarks helps us to set internal goals for improvement. Measuring against past performance gives an indication of whether or not we have sustained improvement. Addressing the concerns raised by the statistics helps us to maintain quality. CMS has not established benchmarks for the quality measures. ASCs only need to report measures in this first phase and are not required to meet a designated goal. As we move further into pay for performance we might anticipate that the next step will be a requirement to meet defined goals. These goals will likely be based on new benchmarks established from the ASC data submitted through this new reporting system.

What and when:
There are five initial patient specific quality measures to be reported in CY2012. An additional two facility practice measures must be monitored in CY2012 and reported in CY2013. CMS payment sanctions could begin in CY2014 based on compliance with reporting and the timing of reporting. One more measure is already planned to start in CY2014. Additional measures can be added and/or modified by CMS each year along with further changes to payment determination.

The following table depicts each measure, its definition and its timing.



Collaboration, "ASC Quality Measures: Implementation Guide," Version 1.6

Where and how:
Where and how to report your quality data remains ill defined. What we do know is that patient specific measures will be reported utilizing a different method than the facility-wide measures. Patient specific measures will first have to be reported using quality data codes when submitting a claim to CMS. It is expected that CMS will determine what the codes are and the exact mechanism that should be used to describe the quality measures sometime in the second quarter of 2012.

It is also anticipated that CMS will require reporting of the non-patient specific measures via the QualityNet website, beginning in 2013. The details for ASC registration have not been released.

For the initial reporting in 2012, only Medicare patients receiving Medicare allowed procedures are included in the reporting requirements for the patient specific measures. Starting in 2013, all patients treated in an ASC are included in the reported population for the patient specific measures.

Primary sources used for this article that may be useful for the reader:
1. www.hhs.gov
2. www.qualitynet.org
3. www.ascassociation.org
4. www.ascquality.org
5. www.jointcommission.org
6. www.qualityforum.org

Learn more about Regent Surgical Health.

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