For ASCs that perform Medicare total joint procedures, a significant new reporting requirement is on the horizon. Beginning in calendar year 2028, facilities will be required to participate in the THA/TKA Patient Reported Outcome Based Performance Measure (PRO PM), a CMS quality measure designed to evaluate patient improvement following elective primary total hip and total knee arthroplasty.

While 2028 may seem far in the future, the challenge of this new requirement lies in the patient data collection needed to support it. ASCs will need to establish processes to identify eligible patients, collect preoperative and postoperative surveys, track response rates, and ensure the submission of complete data.

The measure assesses patient improvement following surgery by comparing self-reported pain and functional status before and after the procedure. Successfully meeting the measure’s requirements will depend on consistently capturing the patient-reported data needed to demonstrate those outcomes.

As ASCs prepare for mandatory reporting, five operational challenges stand out as areas that warrant attention today.

1. Multiple Surveys Are Required to Measure Patient Success
PRO data collection centers on two standardized surveys: HOOS, JR., for hip replacement, and KOOS, JR., for knee replacement. These surveys measure patients’ pain, mobility, and daily function before and after surgery.
ASCs must also collect preoperative health status and literacy data using PROMIS Global Mental Health or VR 12, along with SILS2, a two-question tool that assesses a patient’s ability to understand and use healthcare information.

2. The Minimum Requirement will Require Significant Patient Outreach
To satisfy CMS Outpatient Quality Reporting (OQR) requirements, Ambulatory Surgery Centers (ASCs) must submit complete preoperative and postoperative patient reported outcome (PRO) data for at least 45% of eligible patients. In practical terms, this means that 45% of patients undergoing eligible procedures at your ASC must complete both the preoperative and postoperative surveys. Failure to meet this threshold may result in noncompliance with OQR requirements and could lead to a reduction in Medicare reimbursement.

3. Post-Op Data Collection Cannot Begin Until 300 Days After the Procedure
The second administration of the HOOS, JR. and KOOS, JR. Surveys must occur during the CMS designated follow up period, which opens 300 days after surgery and closes 425 days after surgery. Surveys completed outside this window cannot be counted toward reporting requirements. Reaching patients 300 days after surgery can be challenging, as contact information such as email addresses, phone numbers, and mailing addresses often changes over time, resulting in lower patient engagement and survey completion rates.

4. Not All THA/TKA Patients Are Included
To be included in your THA/TKA PRO-PM measure data, patients must meet specific eligibility requirements. Eligible patients are those who are enrolled in Medicare fee for service, are 65 years of age or older, and are undergoing an elective outpatient primary total hip arthroplasty (THA) and/or total knee arthroplasty (TKA) procedure billed as a Medicare Part B outpatient claim. This includes patients who undergo bilateral procedures performed on the same day during a single encounter.

5. Results will have public and financial implications
CMS defines success as achieving a clinically meaningful improvement in pain and function, as measured by the change in a patient’s preoperative and postoperative HOOS/KOOS scores. ASCs must submit complete preoperative and postoperative data for at least 45% of eligible patients or risk a reduction to their Annual Payment Update. Performance results will also be publicly reported by CMS.

To learn how Nexus Health Resources can help your ASC streamline THA/TKA PRO PM patient-reported outcome data collection and reporting, please give us a call at 845-648-3057.