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CY 2025 ASC Proposed Rule: Ambulatory Surgery Centers Implications

CY 2025 Ambulatory Surgical Center Proposed Rule

On July 10, the Centers for Medicare & Medicaid Services (CMS) released its calendar year 2025 Medicare Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System proposed rule. This proposed rule is more than just a list of updates; it's a roadmap that will shape the future of ambulatory surgery centers (ASCs). Understanding these changes is crucial for ASCs looking to adapt and thrive in an evolving healthcare landscape. 

In this blog post, we will explore the key proposals outlined by CMS, including adjustments in payment rate settings, additions to covered procedures and new measures for quality reporting. Our goal is to provide you with a comprehensive overview of the potential impacts on your operations, helping you make informed decisions as you prepare your comments for CMS before the Sept. 9 deadline.  

Unpacking the CY 2025 ASC Proposed Rule 

At the heart of the CY 2025 proposal is a series of strategic changes aimed at enhancing the efficiency and effectiveness of ASCs. These changes encompass various aspects of operations — from payment rates to quality reporting — emphasizing CMS's commitment to ensuring high standards across healthcare facilities. 

Let's break down these proposals and understand how they could impact your ASC. 

The last year using the hospital market basket for payment rate setting 

Understanding the market basket approach 

One of the central proposals in the CY 2025 ASC rule is this will be the final year using the hospital market basket to gauge inflation in the costs of providing healthcare services when setting payment rates.  

By aligning ASC payment rates with those used for hospitals, CMS intends to more accurately analyze whether the application of the hospital market basket update to the ASC payment system had an impact on the migration of services from the hospital to the ASC setting. 

Implications for ASCs 

It is important for ASCs to recognize this is the last year CMS will use the hospital market basket update. Next year, the shift could have significant financial implications for ASCs. By using a broader measure of healthcare costs, ASCs might experience changes in reimbursement levels that more accurately reflect their expenses. This could also lead to fluctuations in revenue, necessitating careful financial planning and budgeting. 

Preparing for the transition 

To prepare for this transition, ASCs should closely examine their current cost structures and compare them against hospital benchmarks. Engaging with tools like DataGen’s Medicare Fee-For-Service Policy Analytics could offer insights into how these changes will affect your bottom line. Staying informed and proactive will help your ASC adapt smoothly.  

Expanding the list of covered procedures 

New additions to the surgical procedures list 

Among the proposed changes is the addition of 20 medical and dental procedures to the ASC-covered surgical procedures list and ancillary services list. This expansion opens new avenues for ASCs to broaden their service offerings and attract a wider patient base. 

Opportunities and challenges 

The inclusion of these new procedures presents exciting opportunities for ASCs to diversify their services. However, it also brings challenges related to capacity, staffing and resource allocation. ASCs need to evaluate their current infrastructure and determine whether they can accommodate these additional procedures without compromising quality or efficiency. 

Strategic implementation strategies 

Successfully integrating these new procedures requires strategic planning. ASCs should assess their physical space, invest in necessary equipment and consider recruiting or retraining staff to ensure readiness. Collaborating with vendors and other healthcare providers can also streamline the process and enhance your ASC's capabilities. 

Addressing non-opioid pain management 

Separate payments for non-opioid treatments 

In a significant move aimed at addressing the opioid crisis, the proposed rule includes provisions to continue to unpackage and pay separately for non-opioid pain management drugs that function as surgical supplies. Additionally, separate payments are proposed to be implemented for certain non-opioid treatments for pain relief from Jan. 1, 2025, to Dec. 31, 2027. 

Impacts on patient care and ASC operations 

These changes underscore CMS' commitment to promoting safer pain management alternatives. For ASCs, this means a heightened focus on non-opioid treatments, requiring adjustments in prescribing practices and patient education. However, it also presents an opportunity to position your ASC as a leader in providing innovative, patient-centered care. 


Enhancing health equity through quality reporting 

Introducing health equity measures 

The proposed rule introduces three health equity measures to the ASC Quality Reporting (ASCQR) program. These measures aim to address disparities in healthcare access and outcomes, reflecting CMS' broader initiative to promote health equity across the board. 

The importance of health equity in ASCs 

For ASCs, integrating health equity measures into quality reporting is not just a regulatory requirement. It’s an initiative that holds ASCs accountable for providing quality care across racial and ethnic groups and socioeconomic status. By identifying and addressing disparities, ASCs can contribute to creating a more equitable healthcare system where all patients receive high-quality care and better addressing social determinants of health


Seeking public input for future frameworks 

Request for public comment 

CMS is actively seeking public input on the potential development of frameworks for specialty-focused reporting and minimum case numbers for required reporting under the ASC program.  


Projected financial impacts of the proposed rule 

Estimating payment increases 

Alongside the proposed changes, CMS estimates that total payments to ASCs will increase by $202 million from CY 2024 to CY 2025. This projected growth highlights the potential financial benefits of the proposed rule. 

Navigating financial changes 

To capitalize on this growth, ASCs need to strategically manage their finances. This involves optimizing revenue streams, controlling costs and investing in areas that drive value and improve patient outcomes. 

Leveraging financial opportunities 

The anticipated increase in payments offers ASCs an opportunity to invest in infrastructure, technology and workforce development. By making targeted investments, ASCs can enhance their competitive advantage and deliver even greater value to patients. 


Prepare for the CY 2025 ASC final rule: Partner with DataGen 

The CY 2025 ASC proposed rule contains changes spanning payment models, procedure lists and quality reporting, ASCs must remain agile and adaptable to meet evolving regulatory requirements.  

By understanding the implications of these changes and proactively engaging with CMS, ASCs can position themselves for success in an increasingly competitive and dynamic healthcare landscape. 

Use this fact sheet for more information on the CY 2025 Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System Proposed Rule

Reach out for your free demo 

Reach out to DataGen to learn how the CY 2025 ASC proposed rule impacts you, including a free demo of our data analysis platform. Get an overview of how our Medicare Fee-For-Service Policy Analytics can help you:  

  • deliver continuous quality improvement with time-saving Medicare data analysis; 

  • analyze major Medicare policy changes before and after they take effect; 

  • create reports that help clients and their members strategize, advocate, adjust and budget; and 

  • guide the future of your facility. 

This content is for informational purposes only. It has been partially generated from an AI language model, which may not always be exhaustive or tailored to individual circumstances. We encourage you to contact one of our experts for more information. We assume no liability arising from any use of this content. 

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