CMS 2025 Final Rule: Advocating for Electrophysiology Procedures in ASCs

The Centers for Medicare and Medicaid Services (CMS) are expected to release the final rule for the 2025 Hospital Outpatient Prospective Payment System (OPPS) and ASC Payment System on November 1, which could mark a significant turning point for electrophysiology (EP) procedures in Ambulatory Surgical Centers (ASCs). This decision will impact many aspects of cardiac care delivery, especially for procedures that the AIS (Arrhythmia Intervention Society) has advocated to make accessible in the ASC setting. AIS has been actively engaging with CMS, highlighting the potential benefits of ASCs for these advanced procedures and emphasizing the importance of broadening access.

In July, CMS published its proposed rule for 2025, notably excluding EP ablation procedures from the ASC-covered procedure list (CPL). This exclusion left the field concerned, as many stakeholders view ASCs as critical in improving patient access to cardiac care. However, CMS’s final ruling may be favorable, thanks to advocacy efforts from the AIS, Heart Rhythm Society (HRS), and ACC, arguing that expanding the list of covered EP procedures would increase patient access to high-quality, efficient care. Here’s a closer look at the advocacy efforts, the role of the ASC-covered procedure list, and what the upcoming decision could mean for the future of EP procedures.

CMS’s ASC Covered Procedure List: What It Means and How It’s Updated

The ASC-covered procedure list determines which medical procedures Medicare will reimburse for when performed in ASC settings rather than in hospital outpatient departments (HOPDs). For procedures to qualify for the ASC list, CMS evaluates their complexity, associated risks, and anticipated recovery times to confirm they can be safely performed outside hospital settings. Adding a procedure to the ASC CPL also has financial implications, as it may offer a lower-cost option for patients compared to hospital settings while maintaining quality and safety standards.

Each year, CMS issues a proposed rule, typically in July, outlining this list's potential additions and modifications. This proposed rule undergoes a public comment period, during which medical professionals, advocacy organizations, and other stakeholders can provide feedback. For 2025, EP procedures were absent from the initial proposal. Still, AIS and HRS quickly mobilized to advocate for their inclusion, emphasizing recent research showing the safety and effectiveness of these procedures in ASCs.

Advocacy Efforts: AIS and HRS’s Role in Shaping CMS’s Decision

Following the proposed rule's release in July, AIS and HRS took swift action, underscoring the importance of ASCs in expanding access to cardiac care and highlighting supporting data. AIS submitted a letter to CMS advocating for EP procedures in ASCs, referencing findings from a recent study published in the Heart Rhythm Journal that demonstrated the safety of EP ablation procedures performed in ASCs. This research provides concrete evidence to support the shift, showing that ASCs can safely handle these procedures without compromising patient outcomes.

HRS also met with CMS officials to reiterate this data and share insights from clinical practice, emphasizing that ASCs provide a cost-effective alternative and help alleviate the high demand for hospital outpatient services. Both organizations are hopeful that CMS will consider this advocacy in its final ruling, with many stakeholders confident that if EP procedures are not added to the CPL for 2025, CMS may prioritize them for the 2026 proposed rule.

Potential Outcomes and Next Steps

If CMS includes EP procedures in the final 2025 rule, this would signal a significant win for patient access to cardiac care in ASCs. Such a decision could bring immediate benefits, including shorter wait times, greater convenience, and reduced costs for patients requiring these advanced procedures.

However, if CMS excludes EP procedures in the final rule, stakeholders remain optimistic about future inclusion. Many expect EP procedures to be prioritized in the following proposed rule, given the recent advocacy efforts and growing body of supportive evidence. In this case, AIS and HRS would continue to advocate for their inclusion, likely bolstered by the engagement of other medical associations and ongoing research supporting the safety and efficacy of ASCs for these procedures.

Looking Ahead: The Importance of Continued Advocacy

As CMS prepares to release the final rule, the role of advocacy remains crucial. AIS will continue to lead efforts to support policies that promote access to innovative and safe cardiac care options. Expanding the ASC CPL for EP procedures aligns with AIS’s mission to prioritize patient access, advance the quality of cardiac care, and address the financial challenges associated with hospital-based care. We hope CMS will consider the extensive data and insights shared by AIS and HRS, ultimately making these procedures more accessible to patients.

Stay tuned for updates on CMS’s final decision and AIS’s ongoing efforts to enhance the availability of cardiac care in ASCs.