"I am honored to testify on the critical issues of price transparency and reducing health care costs. Thank you for the opportunity to represent my ambulatory surgery center (ASC) as well as the
"ASCs like mine are health care facilities that specialize in providing essential surgical and preventive services in an outpatient setting. ASCs have transformed the outpatient experience by offering a convenient, personalized and lower-priced alternative to hospitals.
"I am the chief executive office and administrator for the St. George Surgical Center in
"The demand for price transparency is real. Since posting prices online, our patient base has expanded. For example, we recently served a patient from
ASC Cost Savings and Value
"Price, however, is only one factor in determining value. Lower prices must be combined with high quality care and a safe patient environment. In addition, patients must be disabused of the notion that higher costs indicate higher quality. As health policy experts will tell you, there is no correlation between cost and quality in terms of health care outcomes.
"To that point, across the roughly 23,600 procedures on 13,500 patients performed in St. George Surgical Center since 2013, only five cases have reported infection. Our quality and patient safety rates are so good, in fact, a prominent physician from
"From the national perspective, ASCA was a strong proponent for the requirement enacted in 20143 that CMS develop a web portal for Medicare beneficiaries that would allow them to compare their costs for a procedure based upon the sites of service available to them. Since ASC fees for most Medicare procedures are roughly half of HOPDs, this could lead to patient decision-making that would produce significant savings for both them and the Medicare program. Unfortunately, that web portal has not yet been developed.
Quality and Reporting
"The ASC community is concerned that, in terms of measuring quality to determine value, there is little uniformity across settings--if patients can choose to get their care from either an ASC or a hospital, shouldn't it be easy for them to compare price, safety and quality metrics in both settings? That is not the way things work now, and we need to address that.
"At the federal level, differences between ASC and HOPD reporting systems make it impossible to compare quality and outcomes between the two settings. In fact, only ASCs report on such adverse event measures as patient burns, patient falls, wrong site surgeries and hospital transfers in the
"Since the quality reporting program started in 2012, ASCs have been so consistent on these adverse event measures that CMS recently proposed to eliminate them from our reporting system, citing "measure performance among ASCs is so high and unvarying that meaningful distinctions and improvements in performance can no longer be made."4
"That is usually a conclusion that leads a group like ASCA to declare victory and move on. However, we believe these metrics are so elemental in terms of highlighting patient safety, we will ask CMS to keep them. In fact, we want the reporting to be expanded, requiring us to report on adverse events for all patients--not just Medicare patients--and that other sites of service do the same.
"Disparities in reporting also exist at the state level. In my home
Patient Safety and Outcomes
"A growing body of academic research shows that ASCs are achieving equal or better outcomes than other outpatient surgical facilities while saving billions of dollars for both public and private patients and payors.5
"One recent study6, published in the
"Another study7, published last year in the
"If we are to truly empower patients to get the best value for their health care dollars, both price and quality data must be transparent, meaningful and comparable across all settings where care is available.
"Specifically, the ASC community supports the following initiatives to create a more transparent and efficient health care system:
* Medicare and insurers should publicly post information about prices paid or the beneficiaries' out-of-pocket liability for procedures across settings, rather than in the traditional silos of facility type;
* Patients should be given information on providers in their area, including health outcomes, patient satisfaction, beneficiary cost-sharing and reimbursement to those facilities, in an easy-tounderstand manner;
* Disclosed pricing information must be accurate and present the most meaningful comparison for consumer choice. Providers should have the right to appeal and correct any inaccuracies of posted information;
* All health care providers and facilities should publicly disclose, in a user-friendly format, all relevant information about the relative price, quality, safety and efficiency of health care as well as any other information that may impact care decisions, such as financial arrangements and clinical guidelines for treatment;
* Medicare, insurers and other payers should encourage beneficiaries and the physicians who refer patients to use lower-cost settings; and
* Payers should seek innovative methods, such as tiered co-payments, to incentivize patients to seek care in the least costly setting that is appropriate for their treatment.
"Thank you again for inviting me to participate in today's hearing, and I look forward to answering the Committee's questions."
* * *
1 Medicare Cost Savings Tied to Ambulatory Surgery Centers,
2 Healthcare Bluebook and HealthSmart, Commercial Insurance Cost Savings in Ambulatory Surgery Centers (2016) available at https://www.ascassociation.org/HigherLogic/System/DownloadDocumentFile.ashx?DocumentFileKey=829b1dd6- 0b5d-9686-e57c-3e2ed4ab42ca&forceDialog=0.
3 Sec 4011 of the 21st Century Cures Act. Pub. L. 114-255. 130 Stat. 1033.
4 83 FR 37046. CY 2019 Hospital Outpatient Prospective Payment System / Ambulatory Surgical Center Payment System Proposed Rule available at https://www.federalregister.gov/documents/2018/07/31/2018-15958/medicareprogram- proposed-changes-to-hospital-outpatient-prospective-payment-and-ambulatory-surgical
6 Munnich, Elizabeth L. and Parente, Stephen T. Return to specialization: Evidence from outpatient surgery market. (2018)
7 Brolin TJ, et al. Outpatient total shoulder arthroplasty in an ambulatory surgery center is a safe alternative to inpatient total shoulder arthroplasty in a hospital: a matched cohort study. (2017)