Becker's ASC Review

12 Becker's ASC 21st Annual Meeting – The Business and Operations of ASCs – Call (800) 417-2035 than lower acuity cases, which should be consid- ered during future projections. "Make sure you have determined whether there are any instances when you will not allow phy- sicians to perform these cases in your ASC and ensure your schedulers and the physicians' offices are aware of these rules," says Ms. Nantz. "ASCs must always prioritize safety, even if it means less case volume." 5. Lower distribution checks. There are sev- eral reasons why physician owners may be seeing lower distribution checks. Big declines are usu- ally related to poor revenue cycle management or high accounts receivable days, says Mr. Casey. For example, bills may not be going out on time, contracts change without notification to the ASC or the center didn't receive preauthorizations that led to case cancellations or payment denial. However, some of the most common issues are claims sent out that are not clean. Oftentimes the business office doesn't check on the claims for 30 days to 45 days, when the best benchmark is confirming claims are on file and being processed within two weeks. "With this approach, you're more likely to catch a problem and resubmit the claims early enough that you won't significantly impact your A/R days," says Mr. Casey. "Depending on your payer mix, the average days in A/R should be close to 30. If it's not, you should try to determine why and then work to get your number down to get closer to this benchmark." n T he OIG's recommendation earlier this year that certain Medicare hospital outpatient department rates be lowered to ASC rates was met with significant resistance from both parties, and for good rea- son. While ASCs have lobbied to eliminate the growing disparity in HOPD and ASC rates, the potential fallout from such a drastically opposite change could be catastrophic for both HOPDs and ASCs alike. But what would the lay of the land look like, if the OIG's HOPD rate-reduction came to pass? "There has been a lot of discussion from the Medicare Payment Advisory Commission on site neutral payments," says Nicholas Janiga, ASA, director at HealthCare Appraisers. "It could alter the way in which transactions are completed. Right now it's easy for hospitals to justify an acquisition of an ASC if they will collect more on a per-case level for the same services, post acquisition." Lowered HOPD rates could both make hospitals more disciplined about any ASC acquisition decisions and potentially allow for more hospital-ASC joint ventures with freestanding ASCs. The shift in rates might also cause a change in which specialties are per- formed in HOPDs versus freestanding ASCs. Mr. Janiga cites the MedPAC 2013 pain management and ophthalmology policy proposals. "Pain manage- ment isn't overly expensive from a capital expenditures standpoint, but cer- tain ophthalmology cases require a considerable amount of OR equipment," he says. "As a result, there has been a shift in ophthalmology to outside of the HOPD, to now being done more heavily in freestanding facilities." Ambulatory Surgery Center Association CEO William Prentice says that a rate-lowering shift would be felt throughout the healthcare industry, by phy- sician groups, ASCs, hospitals and others; however, the extent of the impact would depend on the final rate. At the time of the OIG report's release, ASCA expressed concerns that re- ducing HOPD rates to ASC rates was not a sustainable payment solution. A blend between HOPD and ASC rates, however, could be both favorable to ASCs and money-saving for the healthcare system at large, says Mr. Prentice. In any site-neutral payment case, the payments might not stay site-neutral for long. As the situation currently stands, ASC and HOPD payment algorithms are updated using different inflation factors. After a first year of site-neutral payments, without updated inflation factors, ASCs and HOPDs would again receive different Medicare payment rates. While CMS has stated it has no plans to pursue site-neutral payments, Mr. Pren- tice says Congress could raise the issue again, depending on the state of the bud- get. "We're still seeing a lot of interest on Capitol Hill in looking for savings in the Medicare system. Of course, any site neutral policy implementation would be dependent upon Congress needing to pay for something else. With elections coming up later this year, it's unlikely that Congress will get much done," he says. "For policymakers, site-neutral payments are on the table, but the future ap- pears dim. There are lots of details to be worked out. To make site-neutral payments work so they don't reduce access to care, you need to use a scalpel, not a sledge hammer," he adds. "The important message is that there are so many different nuances to the way site-neutral payments could be imple- mented, the devil is clearly in the details when it comes to how it would im- pact ASCs and access to care in general." Mr. Janiga agrees. "At this point, site-neutral payments are just a recommen- dation. The adoption of a site-neutral payment methodology is very uncer- tain at this point." n If CMS Lowered HOPD Rates, What Could ASCs Expect? By Ellie Rizzo info@physiciancontrol.com or call 404.920.4950 www.physiciancontrol.com At IMS affiliated ASCs, physician owners are involved with decision making for the organization, a rare concept in today's ASC environment. IMS specializes in development and management solutions for all types of ASCs. Our emphasis on physician control and our no-nonsense ap approach set us apart from traditional ASC management companies. Our experience allows us to finalize transactions quickly, so you can focus on what matters: your patients. Let us show you how partnering with IMS can enhance your center's success through physician control. Interventional Management Services Less Red Tape. More Time For What Matters.

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