ASCQC recently submitted a formal comment letter to the Centers for Medicare & Medicaid Services (CMS) in response to the 2026 proposed payment rule for ASCs and hospital outpatient departments, outlining key areas of support and concern on behalf of ambulatory surgery centers.
In its comments, ASCQC expressed support for CMS’s proposal to remove the COVID-19 vaccination and health equity/social determinants of health (SDOH) measures from the ASC Quality Reporting Program. This position was not based on a lack of importance of these issues, but rather on the significant implementation challenges and the limited return on investment these measures present for ASCs.
ASCQC also raised strong concerns regarding the proposed Information Transfer Patient-Reported Outcome Performance Measure (PRO-PM), which CMS has proposed for mandatory reporting beginning in calendar year 2029. The measure relies on a nine-item patient survey administered to individuals age 18 and older following surgical or non-surgical procedures, intended to assess patients’ understanding of discharge instructions related to medications, daily activities and follow-up care.
ASCQC opposed adoption of this measure for several reasons, including the lack of evidence demonstrating that it would improve outcomes or address performance gaps in the ASC setting. In addition, the measure has not been tested in ASCs and was piloted only in hospital outpatient departments. ASCQC also noted that the requirement would likely necessitate the use of third-party vendors to ensure survey anonymity, adding new costs on top of the existing OAS CAHPS survey requirements.
CMS is expected to issue the final OPPS/ASC rule in early November 2025. ASCQC will continue to monitor developments closely and advocate for policies that are meaningful, evidence-based and appropriate for the ASC environment.