Anesthesiologists' Role in Helping Surgery Centers Meet Their Quality Reporting Requirements

We are in the fifth year of Medicare’s Physician Quality Reporting System (PQRS) and most anesthesiologists and nurse anesthetists are at least aware of the program, even if they are not participating.  Now it is the turn of the ambulatory surgery centers (ASCs) to start reporting quality measures to CMS or face payment penalties.

Not only are anesthesiologists generally involved in the quality and safety protocols that ASCs must report, many are in leadership or management positions in their ASCs and have a particular interest in compliance with reporting requirements.  Whether or not they are directly responsible for the completeness and accuracy of the reporting—the new ASC requirements do not in any way require anesthesiologists to report any measures, but some may voluntarily assume the role within and for their facility—ASC anesthesiologists will benefit from understanding what procedural changes the facility is making, and why. 

Beginning October 1, 2012, the ASC Quality Reporting Program will require ASCs to report the following five quality measures on Medicare claims forms:

ASC-1	Patient Burn	scalds, contact, fire, chemical, electrical, or radiation
ASC-2	Patient Fall	falls within the confines of the ASC
ASC-3	Wrong Site, Wrong Side, Wrong Patient, Wrong Procedure, Wrong Implant	not the intended site, side, patient, procedure, or implant
ASC-4	Hospital Transfer/Admission	transfer/admission directly to the hospital or emergency department
ASC-5	Prophylactic Intravenous (IV) Antibiotic Timing	initiated within one hour prior to incision or the beginning of the procedure; 2 hours for vancomycin

The measures listed above were all developed by the ASC Quality Collaboration, a coalition of ASC umbrella organizations formed in 2006.  They were endorsed by the National Quality Forum, a de facto prerequisite to use in the Medicare program.  The ASC Quality Collaboration also maintains very useful performance benchmarking data.

Beginning on January 1, 2013, there will be two additional measures:

ASC-6	Safe Surgery Checklist Use in 2012
ASC-7	2012 Volume of Certain Procedures

 

Although the use of a safe surgery checklist and the collection of data on the numbers of procedures do not need to be reported until next year, the reporting will be based on activities conducted in 2012.  Anesthesiologists working in ASCs probably have already encountered the use of a safe surgery checklist or other implementation of the Universal Protocol for avoiding wrong site surgery, and they may have observed that there is a new system in place to capture surgical volume data in their facilities.  They are also likely to have been involved in preparations for or internal implementation of the adverse-outcome and antibiotic prophylaxis measures listed in ASC-1 through ASC-5 above.

Like the PQRS, the ASC Quality Reporting Program incentivizes reporting, pure and simple, and not performance (many of us believe, however, that rewards for outcomes or penalties for negative outcomes are on the way for physicians and probably for ASCs, given that hospital payment rates are now being reduced by such intermediate outcomes as unplanned readmissions).  Also like the PQRS, the ASC Program requires quality data codes on claims for Medicare patients only, who constitute about 25 percent of a typical ASC’s patient population (more if the ASC specializes in cataract surgery or gastrointestinal endoscopies).  Safe-surgery checklist use and volume information, however, will include all patients.

Unlike the PQRS, the ASC Program will not offer a carrot or a payment bonus at the outset.  Rather, it will introduce a payment reduction of two percent (2%) for non-reporting beginning in 2014 and for each subsequent year.

Timeline for Reporting to Avoid Penalties

October 1 – December 31, 2012:
ASCs will be considered successful reporters and not face financial penalties in 2014 if fifty percent (50%) of their Medicare claims contain quality data codes (G-codes). ASCs should include quality data codes only on claims where Medicare is the primary payer.

January 1, 2013:
ASCs should begin placing the G-codes on claims where Medicare is either the primary or secondary payer. ASCs can now register to use CMS’s QualityNet website, qualitynet.org. Because these accounts will be deactivated after 120 days of inactivity, the Ambulatory Surgery Center Association (ASCA) suggests that ASCs wait until March 2013 to register.

July 1 – August 15, 2013:
ASCs will be required to go to qualitynet.org and report their total surgical care volume for selected groups of procedures and whether they used a safe surgery checklist at any time between January 1, 2012, and December 31, 2012. No particular checklist is required.

2014:
One additional measure, Influenza Vaccination Coverage among Health Care Personnel, which must be reported to the Centers for Disease Control rather than CMS, is slated to be added to the list of quality reporting measures.

The long-anticipated ASC Quality Reporting Program was launched as part of the calendar year (CY) 2012 Medicare Hospital Outpatient Prospective Payment System (OPPS) / ASC Payment final rule on November 1, 2011.   Just as CMS publishes updates to the Physician Fee Schedule in a final rule every November, it will continue to make changes to the ASC Quality Reporting Program in similar fashion.  These changes will include more measures as early as 2015.  We welcome any questions about the ASC Program and will endeavor to provide our readers with relevant updates.