On November 1, the Centers for Medicare and Medicaid Services (CMS) issued its final CY 2025 payment rate regulation for hospital outpatient departments (HOPD) and ambulatory surgery centers (ASC).
In a letter to its members, the Outpatient Ophthalmic Surgery Society (OOSS) noted that under the final rule, ASC payment rates will be updated by 2.9% in 2025 (reflecting the hospital market basket index of 3.4% less the MFP adjustment of 0.2%). The updated percentage of 2.9% represents an average across all ASC procedures. The 2025 rates represent the 26th consecutive years of positive ASC updates, the letter stated.
Five years ago, CMS agreed, for the period 2019-2023, to update ASC payment rates by the Hospital Market Basket rather than the lower Consumer Price Index-Urban, according to the letter. OOSS says it has been a leader in the effort to effectuate this change for over 20 years, seeking to persuade both CMS and Congress of its merits. Under this policy, OOSS says, ASCs have received the same update as hospitals, subject to certain adjustments.
The policy was supposed to come up for review in this rulemaking session. However, because of data problems associated with the pandemic, the OOSS says that the agency last year extended the application of the Hospital Market Basket to ASCs for an additional 2 years, through 2025. OOSS relays that it will continue to strenuously recommend that CMS maintain permanently the application of the Hospital Market Basket in computing the annual ASC payment update.
The following is a representative sampling of the proposed rates:
2025 ASC Payment Rates for Ophthalmic Services
regrettably and over the objections of the ASC and ophthalmology communities, CMS has not repealed the misguided and administratively burdensome quality measure requiring facilities to report on patient visual function 90 days after cataract surgery. However, the measure will continue to remain voluntary, the OOSS says.
According to the letter, for the past several years, OOSS and the ASC and ophthalmology communities, have been engaged in the process of developing and proposing new and appropriate ophthalmic ASC measures. The agency adopted in 2019 a new ophthalmic quality measure, ASC 14: Unplanned Anterior Vitrectomy, which assesses the percentage of cataract surgery patients who have the procedure in an ASC. OOSS says that it will continue to recommend the implementation of an ASC quality measure for TASS.
According to the letter, CMS is adopting three new quality measures:
- The Facility Commitment to Health Equity measure beginning with the CY 2025 reporting period/CY 2027 program determination
- The Screening for Social Drivers of Health measure beginning with voluntary reporting in the CY 2025 reporting period, followed by mandatory reporting beginning with the CY 2026 reporting period/CY 2028 payment determination
- The Screen Positive Rate for Social Drivers of Health measure beginning with voluntary reporting in the CY 2025 reporting period, followed by mandatory reporting beginning with the CY 2026 reporting period/CY 2028 payment determination.
OOSS says it will provide members with guidance regarding compliance with the new measures — failure to report on quality measures results in a 2% reduction on payment rate updates.
In addition, OOSS says that in the proposed rule, CMS requested public comment on the “potential development of frameworks for specialty-focused reporting and minimum case number for required reporting under the ASCQR Program.” CMS will consider the development of changes to the reporting requirements for specialty ASCs. This could potentially reduce the administrative burden on ophthalmic ASCs by limiting requirements that our centers report on measures that are not relevant to our patient population or the services we provide, the letter stated.
Coverage of Drugs Used During Cataract Surgery
Omidria and Dextenza will continue to be paid for separately in the ASC under the agency’s non-opioid pain management program, the letter noted.
The final 2025 Medicare ASC payment regulation may be reviewed here.
OOSS said that it will keep members abreast of any developments. For any questions regarding the rule, please contact Michael Romansky, JD, at mromansky@OOSS.org.