Ambulatory Surgery Center Association (ASCA) CEO Bill Prentice last week submitted comments in response to CMS’ 2027 Inpatient Prospective Payment System Proposed Rule.
In particular, Mr. Prentice provided feedback on a request for information regarding the inclusion of ASCs in the Transforming Episode Accountability Model (TEAM) or “other similar episode-based payment models.”
“Surgery centers are not well suited to participate in episode-based payment models as currently constructed,” wrote Mr. Prentice. “We look forward to collaborating with CMS on the best mechanisms that leverage the advantages of ASCs and contribute to the agency’s commitment to value-based payment.”
ASCA notes that surgery centers are “typically not the primary entity responsible for coordinating patient care after discharge.” It also argues that the creation of a new episode-based payment structure could hinder the migration of surgeries such as total joint replacements to ASCs.
“The core problems that TEAM is designed to address—fragmented care coordination, poor transitions and communication between providers, a complicated patient experience—are fundamental advantages of choosing an ASC as the surgical site of service,” wrote Mr. Prentice.
He added that ASCs carefully select patients who are “least likely to need intricate recovery protocols and/or post-discharge maintenance…Most patients who would require the extensive care coordination services included in TEAM’s 30-day episodes would likely be unfit for surgery in an ASC in the first place.”
He also noted that ASCA has "serious concerns with any model design that mandates participation for facilities. Surgery centers have not been the focus of any prior CMS value-based payment model and have not accrued the same experience that hospitals have from models like Bundled Payments for Care Improvement or Comprehensive Care for Joint Replacement.” Mr. Prentice writes that “this creates fundamental issues with CMS’ method for selecting facilities to participate in TEAM, as past exposure to bundled payment models is one of the criteria used for stratification and sampling.”
As a result, wrote Mr. Prentice, ASCA “strongly recommends that any future payment model featuring ASCs be implemented with voluntary participation, giving surgery centers time to develop familiarity and best practices.”
