This week, ASCRS submitted comments on CMS’ proposed rule that would lift the requirement that comprehensive history and physical exams (H&Ps) be performed on all patients undergoing surgery in outpatient facilities. Instead, facilities would be required to develop policies based on the clinical judgement of the operating surgeons that would identify which patients need more significant pre-operative testing. In the proposed rule, CMS specifically cites cataract surgery as an example of a procedure where patients may not require pre-operative H&Ps, and that eliminating the requirement would reduce the burden on physicians and patients and result in cost savings to the Medicare program. In our comments, ASCRS supports the proposal and agrees that for ophthalmic surgery, comprehensive H&Ps are not necessary for every patient and cite studies showing no difference in the rate of adverse events—either systemic or ocular—following cataract surgery between patients who had pre-operative H&Ps and those who did not.
In addition to the proposals related to H&Ps, CMS also proposes to eliminate the requirement that an ASC have an emergency transfer agreement with a local hospital and that any surgeon operating in the ASC have admitting privileges at the hospital. ASCRS also supported this proposal and recommended CMS finalize it. Finally, ASCRS expressed support for CMS’ proposals to reduce the administrative burden associated with facilities’ emergency preparedness by decreasing the frequency of emergency program reviews from once a year to once every two years; eliminating documentation of efforts to contact emergency responders and officials; reducing the frequency of emergency preparedness training; and reducing the frequency of emergency testing exercises from twice a year to once a year.
We will keep you updated when a final rule is released.