The Ambulatory Surgery Center Association submitted comments in response to the Centers for Medicare & Medicaid Services’ 2027 inpatient prospective payment system proposed rule earlier this month. In the comments, ASCA provided feedback on a request for information regarding the inclusion of surgery centers in an episode-based payment model.
“ASCA appreciates CMS’ understanding of the vital role ASCs play in improving care and reducing costs for the Medicare program,” ASCA CEO Bill Prentice said. “However, surgery centers are not well-suited to participate in episode-based payment models as currently constructed. We look forward to collaborating with CMS on the best mechanisms that leverage the advantages of ASCs and contribute to the agency’s commitment to value-based payment.”
In the comments, ASCA noted that surgery centers are typically not the primary entity responsible for coordinating patient care after discharge. Additionally, creating a new episode-based payment structure could hinder the migration of surgeries such as total joint replacements, creating unnecessary additional spending while limiting beneficiary access to care. A recent analysis by KNG Health Consulting found that surgery center performance of musculoskeletal procedures, including total joint replacement, saved Medicare more than $792 million in 2024 alone.





