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In its 2025 proposed payment rule for ambulatory surgery centers (ASCs), the U.S. Centers for Medicare & Medicaid Services (CMS) floated a 2.6% increase to surgery center payments and adjustments to select quality-reporting measures.

One thing CMS didn’t call for: key additions to the ASC Covered Procedures list for 2025.

“It is disheartening that CMS established a new, supposedly more transparent process for submitting procedure codes that could be added to the ASC Covered Procedures List, yet proceeds in this proposed rule to ignore the 18 cardiac and spine codes we submitted,” Bill Prentice, CEO of the Ambulatory Surgery Center Association (ASCA), said a statement. “Medicare beneficiaries would have more access to the care they need if the agency simply relied on the clinical expertise of surgeons who safely perform these procedures and who are best positioned to know where they can be performed.”

ASC operators and industry stakeholders have until Sept. 9 to submit comments of their own related to the 2025 proposed payment rule from CMS, which the agency first released in July.

And with just under a week to go before that comment window closes, ASC professionals are making their voice heard.

As of Tuesday morning, CMS had received nearly 1,250 comments tied to the proposed rule.

Broadly, there wasn’t a single issue that ASC stakeholders flagged to CMS, an ASC News review of comments found. Instead, commenters shared their views on a long list of topics, including COVID-19 vaccination reporting in the ASC setting, ocular-procedure reimbursement, cardiology codes and more.

Specifically, many commenters asked CMS to remove “ASC-20” – COVID-19 vaccination coverage among health care personnel – from the ASC Quality Reporting (ASCQR) Program.

“This measure has placed an undue burden on our facility, and the implementation has been confusing, with definitions constantly changing mid-stream,” one commenter wrote.

“It is difficult to claim it is a matter of epidemiology when we do not know the vaccination status for a sizable number of the individuals coming through the facility daily – including the patients undergoing surgery,” another commenter submitted.

Vaccination comments appeared to be part of a targeted campaign on the issue, with commenters using similar language or the same template.

In terms of ocular procedures, several commenters called for CMS to include a separate payment for the insertion procedure for Dextenza, a treatment for ocular inflammation and pain that provides 30 days of pain relief following ophthalmic surgery without the need for eye drops.

“When we provide Dextenza in our ASC, we seek reimbursement for the medication and payment for the service of inserting the drug (CPT code 68841),” one ASC leader from Texas wrote. “Unfortunately, CMS has declined to propose paying separately for the insertion procedure in the ASC setting.”

The insertion requires specific instrumentation such as punctal dilators and blunt tooth forceps, an additional five minutes in the operating room and the assistance of an ophthalmic technician, the commenter summarized.

“Those uncompensated costs to our facility make it difficult to provide this important medication,” the Texas ASC leader continued.

Several other commenters agreed with ASCA’s Prentice about more cardiology codes.

“On behalf of the ambulatory surgery center industry, I would like to provide public comment on the addition of more cardiology codes to the CY 2025 payment rule,” one such commenter stated. “There have been a number of codes that have been requested in the past few years, and have received virtually no acknowledgement from CMS, even though there have been multiple studies of efficacy, excellent outcomes, and a safety profile that is virtually the exact same as hospital settings.”

The commenter specifically pointed to “the EP studies & Ablation codes” 93613, 93619, 93620, 93623, 93650, 93653, 93654, 93655, 93656 and 93657. The commenter also highlighted “peripheral vascular codes” 75630, 75710, 75716 and 75736, along with “cardioversion and transesophageal echocardiogram codes” 92960 and 93355.

“All of the above-mentioned codes have support from various cardiology societies, associations and organizations, as well as countless physicians across the country,” the commenter added. “There are even a number of private sector commercial payers that have seen the value in contracting for these services in the ASC setting.”

At least one ASC commenter pushed back on some of the health-equity changes from CMS in its 2025 proposed payment rule.

“Identifying social inequities that may impact health is important, however, [it] is not applicable in our setting,” the commenter wrote. “We do not establish long-term relationships with the patients and have no mechanism to follow-up on interventions.”

Scores of comments focused on payment for diagnostic radiopharmaceuticals and cardiac computed tomography (CCT), too.

“Cardiac CTs really do take a lot of time,” a commenter wrote. “We frequently spend as much time getting patients ready for the scans as we do reading them and, in some cases, more time.”