draft ASC comment letter 082409

August 25, 2009 VIA HAND DELIVERY Charlene Frizzera, Acting Administrator Centers for Medicare and Medicaid Services Department of Health and Human Services Attention: CMS-1414-P Room 445-G Hubert H. Humphrey Building 200 Independence Avenue, SW Washington, DC 20201 Re: CMS-1414-P – Medicare Program; Proposed Changes to the Ambulatory Surgical Center Payment System and CY 2010 Payment Rates Dear Acting Administrator Frizzera: On behalf of the undersigned members of the ambulatory surgery center (ASC) community, please accept the following comments regarding the payment and quality issues related to ASCs in the proposed rule for CY 2010 payments (74 Fed. Reg. 35232, July 20, 2009). These comments are submitted jointly by the ASC Association and the ASC Coalition, a diverse coalition of national and state associations and companies representing all types of ASCs – single- and multi-specialty, physician-owned, joint ventures between hospitals and physicians, and joint ventures between physicians and management companies. These centers range from the very small to the very large and are located in all parts of the nation. We appreciate the diligent work of your staff to review and evaluate the proposed changes to the ASC payment system in 2010, and appreciate the opportunity to offer our insights on the impact of the ASC payment system. This is the first opportunity we have had to reflect upon actual claims experience under the ...