As we reported in July, the Centers for Medicare & Medicaid Services (CMS) proposed a 3.5% decrease in payments for cataract and reductions for many other ophthalmic procedures. If finalized, this would mark the first time in more than 2 decades that ophthalmic ambulatory surgery centers (ASCs) have not received an increase. These are some highlights from the comments that the Outpatient Ophthalmic Surgery Society (OOSS) submitted on behalf of the American Academy of Ophthalmology, American Society of Cataract and Refractive Surgery, the American Society of Retina Specialists, and Society for Excellence in Eyecare.
- Our organizations presented a very strong case for restoration of the proposed cuts and the need to bring our rates into positive territory. Central to this argument is that CMS should eliminate the weight scaler applied to ASC payment rates, which has artificially limited reimbursement to ASCs for more than a decade.
- Ambulatory surgery centers treat the same patients with the same comorbidities as hospitals, while expending similar financial resources to provide cataract and other ophthalmic surgeries. Yet, for many years, our facilities received an annual update—the Consumer Price Index—that was typically at least a point lower than that received by hospitals. In 2019, the agency initiated a pilot program under which ASCs received the same update as hospitals. We applaud the agency’s decision to maintain the hospital market basket as the ASC update factor.
- We argued for significantly higher payments for retinal surgical care in the ASC and hospital, recognizing that current facility fees do not cover the costs of providing the service and that retinal surgeons are having difficulty referring their patients to both hospitals and ASCs.
- We recommended that CMS entirely withdraw the ASC quality reporting measure (now voluntary) that would require facilities to report on improvement in visual function. We also urged the agency to establish a quality measure reporting incidents of toxic anterior segment syndrome.
- We recommended that CMS develop a policy that covers drugs that are administered at the time of ophthalmic surgery, that are direct substitutes for postoperative medications, or that have a US Food and Drug Administration-approved indication to treat/prevent postoperative issues, such as pain, inflammation, or infection, separately under Medicare Part B. At this time, only Omidria and Dextenza qualify for separate payment.
- Our organizations raised substantial concerns regarding CMS’s prior authorization programs.
Our effort to change several important deleterious elements in the proposed rule has been a team endeavor involving the ophthalmology, ASC, and industry communities.
