The Centers for Medicare & Medicaid Services (CMS) has released the 2025 proposed payment rule for Ambulatory Surgical Centers (ASCs) and Hospital Outpatient Departments (HOPDs). This announcement includes significant updates and proposals aimed at aligning ASC payment factors with HOPDs and extending the interim period by two additional calendar years, through 2025.
2.6% Average Rate Update to 2025 Proposed CMS Payment Rule
One of the most noteworthy elements of the 2025 Proposed CMS Payment Rule is the average rate update of 2.6% for ASCs. This figure results from a 3.0% inflation update based on the hospital market basket, adjusted by a 0.4 percentage point reduction mandated by the Affordable Care Act (ACA). It is important to note that this average may vary significantly depending on specific codes and specialties.
Comparison of 2025 ASC and HOPD Reimbursement Proposals:
ASC | HOPD | |
Inflation update factor | 3.0% | 3.0% |
Productivity reduction mandated by the ACA | 0.4 percentage points | 0.4 percentage points |
Effective update | 2.6% | 2.6% |
Conversion factor | $53.609 | $89.379 |
Changes to the ASC Covered Procedures List
For CY 2025, CMS proposed to add 20 medical and dental surgical procedures to the ASC Covered Procedures List (ASC-CPL). However, none of the 18 codes submitted by the Ambulatory Surgery Center Association (ASCA) were included. Despite a new process intended to be more transparent, CMS did not acknowledge the submitted cardiovascular and spine codes.
ASCA CEO Bill Prentice expressed disappointment:
“It is disheartening that CMS established a new, supposedly more transparent process for submitting procedure codes that could be added to the ASC Covered Procedures List, yet proceeds in this proposed rule to ignore the 18 cardiac and spine codes we submitted. Medicare beneficiaries would have more access to the care they need if the agency simply relied on the clinical expertise of surgeons who safely perform these procedures and who are best positioned to know where they can be performed.”
Updates to ASC Quality Reporting Program
CMS proposed several updates to the ASC Quality Reporting (ASCQR) Program, including the adoption of new measures:
Facility Commitment to Health Equity (FCHE): Starting with the CY 2025 reporting period for CY 2027 payment determination.
Screening for Social Drivers of Health (SDOH): Voluntary reporting beginning in CY 2025, with mandatory reporting starting in CY 2026 for CY 2028 payment determination.
Screen Positive Rate for SDOH: Voluntary reporting beginning in CY 2025, with mandatory reporting starting in CY 2026 for CY 2028 payment determination.
These measures are also proposed for addition to the Hospital Outpatient Quality Reporting Program, despite not being tested in the ASC setting. Additionally, CMS is seeking public comment on potential frameworks for specialty-focused reporting and minimum case number requirements for the ASCQR Program.
Continuing Opposition on 2025 Proposed CMS Payment Rule
ASCA will continue to oppose the inclusion of ASC-20: COVID-19 Vaccination Coverage Among Health Care Personnel in the ASCQR Program due to its burdensome nature.
What Are the Next Steps?
Comments on the proposed rule are due by September 9, 2024. ASCA staff will continue to analyze the details and provide further insights to help ASC operators understand the impact of these proposals on their facilities.
At Marisa Consulting, we are dedicated to helping ASCs and HOPDs navigate these changes and optimize their operations under the 2025 Proposed CMS Payment Rule. Stay tuned for our in-depth analysis and strategic recommendations.
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