Breaking Down ASC-22, ASC-23, and ASC-24: What Medicare’s 2025 Final Rule Means for ASCs

By Allison Stock, COO, Surgical Management Professionals

The Centers for Medicare & Medicaid Services (CMS) have finalized the Ambulatory Surgical Center (ASC) Payment System Rule for the calendar year 2025. ASCs must report on 14 ASCQR Program measures to avoid Medicare penalties. Although regulatory adjustments happen regularly, this particular update poses significant challenges for ASCs, primarily due to the introduction of untested measures that require surgery centers to collect social determinants of health (SDOH) data. Unfortunately, there’s little guidance on how to utilize this information effectively.

At Surgical Management Professionals (SMP), we recognize the uncertainty that ASCs are facing due to these changes. Here’s a breakdown of what this ruling entails, its implications, and how surgery centers can prepare themselves.

Key Points from Medicare’s 2025 Final Rule

1. ASC-22, ASC-23, and ASC-24: Pay-for-Reporting Measures, Not Pay-for-Performance

CMS has introduced three new reporting measures, ASC-22, ASC-23, and ASC-24. These measures are collected starting in 2025 but will first be reported by May 15, 2026. It is crucial to note that these are pay-for-reporting measures rather than pay-for-performance, meaning that ASCs are required to submit the data, but reimbursement is not directly tied to performance outcomes at this stage.

2. Increase in Medicare Payment Rates

The good news is that CMS has approved a 2.9% increase in ASC payment rates for facilities that comply with the ASC Quality Reporting (ASCQR) Program requirements. This update arises from:

• A 3.1% increase in the hospital market basket
• A 0.2 percentage point productivity adjustment

However, it’s worth noting that ASCs that don’t report the necessary quality data will see a 2% cut in their Medicare reimbursement.

3. Extension of the Market Basket Adjustment

CMS has extended the hospital market basket update to ASCs through 2024 and 2025, aligning ASC payment trends more closely with those of hospital outpatient departments. While this offers short-term financial stability, long-term prospects for ASC payment models are still under consideration by CMS.

4. The Challenge of SDOH Data Collection

One of the most concerning aspects for ASCs is CMS’s requirement to collect SDOH data without any clear guidelines on how to use it. This measure hasn’t been tested before in the ASC space, and ASCs are being asked to comply with a mandate that comes with considerable uncertainty.

“This has never been tested in the ASC space. Unlike previous quality measures, CMS hasn’t studied the implications for surgery centers. So, ASCs are being asked to collect data without knowing what the next steps are.”
— Allison Stock, JD, RN, COO, Surgical Management Professionals

What Should ASCs Do with This Data?

Collecting SDOH data means ASCs will need to ask patients important questions, such as:

• Do you have stable housing?
• Are you getting enough food to eat?
• Do you have transportation to your procedure?

However, the challenge lies in the fact that once ASCs collect this data, there is no clear direction on how to address the needs identified. Unlike hospitals, ASCs typically have limited resources and staff, lacking social workers to help patients with unmet needs.

“We don’t have case managers or social workers on staff. ASCs operate lean, focusing on efficient, high-quality care. We can identify patients who have needs, but what is our role in solving those problems?”
— Allison Stock, JD, RN, COO, Surgical Management Professionals

How Can ASCs Prepare for ASC-24?

1. Identify Key Community Needs

Each ASC serves a different patient demographic. The first step is to understand the unique challenges faced by your community. This can be achieved through:

• Reviewing county-level health data
• Engaging with local hospitals and primary care providers
• Analyzing patient demographics to pinpoint gaps in access

2. Develop an SDOH Data Collection Strategy

If ASCs are required to gather SDOH data, it’s essential to make the process manageable and purposeful:

• Incorporate SDOH screening questions into pre-operative assessments
• Focus on practical matters impacting ASCs, such as transportation and food insecurity
• Train staff on how to approach these questions in a compassionate, patient-centered manner

“Staff training is crucial. ASCs may need to introduce cultural awareness training, incorporate multilingual resources, or focus on how to have meaningful conversations about these social factors with patients.”
— Allison Stock

3. Connect Patients to Local Resources

Although ASCs may not be equipped to resolve social issues directly, they can provide valuable referrals for:

• Medical transportation services for elderly or low-income patients
• Local food assistance programs
• Multilingual resources to assist non-English speaking patients

Many ASCs may already work informally with community partners; however, formalizing a referral process can greatly enhance patient experience and ensure compliance.

4. Stay Active in Advocacy Efforts

Given CMS’s current direction with ASC-24, more policy changes are likely on the horizon. The ASC industry must advocate for practical solutions that accommodate the unique characteristics of surgery centers.

• Join industry associations like ASCA to stay informed and influence policy
• Utilize CMS feedback channels to voice concerns regarding the implementation of untested measures
• Explore collaboration opportunities through the ASC Quality Collaborative

Moving Forward with ASC-22, ASC-23, and ASC-24

While the 2025 final rule poses challenges, it also opens up opportunities. The increase in payment rates is certainly welcomed. However, the requirement for untested SDOH data collection brings a significant degree of uncertainty.

At SMP, we are dedicated to helping ASCs navigate these changes. By taking proactive, strategic steps and engaging in advocacy, ASCs can position themselves for success as they adapt to this evolving landscape.

📩 Need help with compliance, operational efficiency, or advocacy? Contact SMP.