ASA Argues for Expanded Definition of Hospital-Based Physicians Under MIPS - American Society of Anesthesiologists (ASA)

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ASA Urges Expanded Definition of Hospital-Based Physicians Under MIPS; Supports Revisions to H-CAHPS

In recent comments to the Centers for Medicare & Medicaid Services (CMS), the American Society of Anesthesiologists® (ASA) argued for an expanded definition of how physicians will be considered hospital-based under the Medicare Access and CHIP Reauthorization Act (MACRA). The expanded definition would allow for more physician anesthesiologists to be exempt from reporting the Advancing Care Information (ACI) component of the Merit-based Incentive Payment System (MIPS).

The ASA comments were in response to the 2018 Inpatient Medicare Inpatient Prospective Payment Systems for Acute Care Hospitals Proposed Rule. The rule governs hospital, ambulatory surgery centers and critical access hospital payments as well as updates quality reporting requirements for those facilities. Related, ASA expressed its support for the concept of using a hospital or facility’s quality measure scores to serve as a proxy in the Quality Payment Program Merit-based Incentive Payment System (MIPS) Quality and Cost Components for ECs and their groups.

Under MACRA regulation, hospital-based physicians ae considered exempt from reporting the MIPS ACI Component if they furnish 75 percent or more of his or her covered professional services in sites identified with Place of Service Codes (POS) 21 (Inpatient Hospital), 22 (On campus outpatient hospital), or 23 (Emergency room). With the 21st Century Cures bill, the ASA was able to expand that definition to include POS 24 (Ambulatory Surgical Center). In this letter, ASA urged CMS to maintain the 75 percent threshold and implement a provision allowing for services provided in all the identified outpatient facility settings to be summed cumulatively to meet the threshold.

ASA also supported proposed changes to the Hospital Consumer Assessment of Healthcare Providers and Systems (HCAHPS) Survey. In recent years, ASA became increasingly concerned with how the original HCAHPS pain management questions had the unintentional consequence of placing increased pressure on physicians to overprescribe opioids. The proposed new questions focus on how providers communicate with patients about pain, including treatment options.

ASA expects that CMS will release the final IPPS rule later this fall.

For more information on MIPS categories and requirements, please e-mail and visit the ASA MACRA resources and Quality Payment Program website. For more information on ASA pain medicine activities, please contact ASA Advocacy at
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