CMS Includes ASA Recommendations in Final IPPS Rule - American Society of Anesthesiologists (ASA)

FDA & Washington Alerts

CMS Includes ASA Recommendations in Final IPPS Rule; Revisions to H-CAHPS and Definition of Covered Professional Services

The Centers for Medicare & Medicaid Services (CMS) incorporated several ASA positions in the recently released 2018 Inpatient Medicare Inpatient Prospective Payment Systems for Acute Care Hospitals Final Rule. The rule, which governs hospital, ambulatory surgery centers and critical access hospital payments, as well as updates quality reporting requirements for those facilities, finalized questions on pain management for the Hospital Consumer Assessment of Healthcare Providers and Systems (H-CAHPS) Survey and clarified the definition of certain hospital-based eligible clinicians who may receive an exemption in the in the Merit-based Incentive Payment System (MIPS).

In June 2017, ASA strongly supported proposed changes to questions about pain management on the H-CAHPS Survey that would benefit physician anesthesiologists and pain medicine physicians. In the proposed rule, CMS revealed newly proposed questions that addressed concerns about the impact previous H-CAHPS questions had on opioid prescribing practices and the pressure they might have inadvertently placed on health care providers. ASA expressed support for the new questions and the proposed new name for the pain management dimension— “Communication About Pain.”  ASA thanks CMS for hearing these concerns and responding accordingly.

The proposed rule also sought to implement a provision in the 21st Century Cures Act where no Merit-based Incentive Payment System (MIPS) payment adjustments for 2017 or 2018 will be applied to eligible clinicians (ECs) who furnish “substantially all” of their covered professional services in an Ambulatory Surgical Center (ASC) as designated by a Place of Service (POS) Code 24. In comments to CMS, ASA advised that CMS exempt those ECs who furnish 75 percent or more of their covered professional service in an ASC setting. ASA is pleased CMS has chosen to implement the definition recommended by ASA.

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

Learn more about the Communication About Pain composite measure for use in the H-CAHPS Survey

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