active medical monitoring and care at midnight following the proce-
dure."
CMS uses a list of exclusionary criteria to determine whether there
is a significant safety risk that would preclude ASCs from performing
certain cases on Medicare patients. Exclusions include:
• generally result in extensive blood loss;
• require major or prolonged invasion of body cavities;
• directly involve major blood vessels;
• are generally emergent or life-threatening in nature; and
• commonly require systemic thrombolytic therapy.
For 2017, there are more than 300 codes for which CMS will reim-
burse HOPDs but not ASCs, which makes little sense considering the
facility types are so similar.
OSM
Ms. Newbury (knewbury@ascassociation.org) serves as
regulatory counsel for the Ambulatory Surgery Center Association.
D E C E M B E R 2 0 1 6 • O U T PA T I E N TS U R G E R Y. N E T • 2 7
