CMS Releases 2024 Proposed Medicare Payment Rule: An Overview
By Kelsey Moore, CPCO, Director of Regulatory Affairs, nimble solutions
The Centers for Medicare & Medicaid Services (CMS) recently unveiled the 2024 proposed payment rule for Ambulatory Surgical Centers (ASCs) and Hospital Outpatient Departments (HOPDs).
This eagerly awaited release outlines several key changes and updates that could impact healthcare providers and beneficiaries in 2024.
In this blog post, we will delve into the proposed rule and highlight some significant observations and potential implications.
1. Aligning ASC Update Factor with HOPD Payments
One notable aspect of CMS’s proposed rule is the extension of the ASC update factor with that of HOPD payments. This alignment extends the interim period through 2025. This was initially set for five years and is now extended for an additional two years. CMS intends to utilize utilization data from both hospital outpatient and ASC settings in 2023 and 2024 to analyze the effects of applying the hospital market basket update to the ASC payment system.
2. Average Rate Update
If the proposed rule is finalized as currently drafted, ASCs would experience an average effective update of 2.8 percent for all covered procedures. This update consists of a 3.0 percent inflation update based on the hospital market basket, combined with a mandated productivity reduction of 0.2 percentage points from the Affordable Care Act. It is important to note that specific procedure codes and specialties might see variations in the updates.
The information below provides a comparison between the 2024 ASC and HOPD reimbursement proposals:
| ASC | HOPD | |
| Inflation update factor | 3.0% | 3.0% |
| Productivity reduction mandated by the ACA | 0.2 percentage points | 0.2 percentage points |
| Effective update | 2.8% | 2.8% |
| Conversion factor | $53.397 | $87.488 |
3. Changes to the ASC Covered Procedures List
The proposed rule aims to expand the ASC Covered Procedures List (ASC-CPL) to include dental procedures. CMS suggests adding 26 dental surgical codes for 2024.
However, CMS declined to include an additional list of 62 surgical codes, including total shoulder arthroplasty.
4. ASC Quality Reporting Program
The proposed rule also includes changes and modifications to the ASC Quality Reporting (ASCQR) Program. For example:
- ASC-20: COVID-19 Vaccination Coverage Among Health Care Personnel is proposed to remain the ASCQR Program, with some modification.
- ASC-7: ASC Facility Volume Data on Selected ASC Surgical Procedures is proposed to be voluntary reporting initially in CY 2025, followed by mandatory reporting starting in CY 2026.
- ASC-21: Risk-Standardized Patient Reported Outcome-Based Performance Measure (PRO-PM) is also proposed to be voluntary following elective primary total hip arthroplasty (THA) and/or total knee arthroplasty (TKA) in the ASC setting in CY 2025 and 2026, with mandatory reporting beginning in CY 2027.
- ASC-11: Cataracts Visual Function (previously referred to as Cataracts: Improvement in Patient’s Visual Function within 90 Days Following Cataract Surgery) also has proposed modifications, but the measure remains voluntary at this time.
The release of the 2024 proposed payment rule brings several important updates and changes for ASCs and HOPDs. As the rule undergoes further analysis and potential revisions, it will be crucial for healthcare providers and organizations to stay informed.
nimble solutions will continue to analyze the rule in detail to help ASCs understand the impact of the proposal from a compliance and revenue cycle standpoint.
For more information, visit the CMS 2024 Proposed Medicare Payment Rule Fact Sheet.
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