member entities, contribute information and perspectives regarding important healthh care decisions to a degree that has not been possible
|
|
- Wilfrid Griffin
- 5 years ago
- Views:
Transcription
1 September 6, 2013 Marilyn Tavenner Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services Hubert H. Humphrey Building, Room 445-G 200 Independence Avenue, SW Washington, DC Re: CMS-1600-P- Medicare Program; Revisions to Payment Policies under the Physician Fee Schedule, Clinical Laboratory Fee Schedule & Other Revisions to Part B for CY 2014 Dear Administrator Tavenner: The Regulatory Education and Action for Patients (REAP) Council would like to thank you for the opportunity to comment on the Proposed Rule entitled Medicare Program; Revisions to Payment Policies under the Physician Fee Schedule, Clinical Laboratory Fee Schedule & Other Revisions to Part B for CY 2014 (the Proposed Rule), which was published in the Federal Register on July 19, REAP is an umbrella coalition comprised of 61 patient advocacy groups. The unique experience and expertise of each REAP member organization allows REAP to provide the patient voice in a crossregulatory bodies, disciplinary manner. REAP s mission is to communicate issues to Federal and State Congress, health care insurers and others to regulate, develop, manage and/or impact health delivery, coverage, cost, and availability of services to the United States population. REAP will, through its member entities, contribute information and perspectives regarding important healthh care decisions to a degree that has not been possible heretofore by health care advocacy groups in the regulatory arena. Both REAP and its member organizations are concerned that in its efforts to control Medicare spending and preserve the Medicare Trust Fund operating within the current statutorily mandated Sustainable Growth Rate (SGR) formula, the Centers for Medicare & Medicaid Services (CMS) has lost sight of the subsequent impact of such efforts on patients, specifically their potential access to needed health care and the quality of care that such patients receive. While REAP members appreciate the daunting task of managing the exponential costs associated with caring for the Medicare beneficiary population which continues to expand, CMS nonetheless needs to ensure it is implementing any cost-controlling proposals or measures in the most patient-centric manner possible. It is against this background that we offer the following comments to the Proposed Rule. We have organized our comments around three overarching principles (1) proposals that may impact Medicare 1 78 Fed. Reg. 43,282 (Jul. 19, 2013).
2 beneficiary access to needed healthcare, (2) proposals focused on rewarding providers for the provision of quality care and (3) proposals focused on transparency in Medicare coverage and quality of care provided. Proposals that may impact Medicare beneficiary access to needed healthcare The Hospital Outpatient/Ambulatory Surgery Cap on Practice Expenses In the Proposed Rule, CMS has proposed refining the practice expense (PE) methodology used to construct the Physician Fee Schedule (PFS) to limit the nonfacility PE relative value units (RVUs) for more than 200 Healthcare Common Procedure Coding System (HCPCS) codes so that the total Medicare nonfacility PFS payment amount would not exceed the total combined Medicare payment amount (facility PFS payment plus facility fee) for the same service furnished in a hospital outpatient department or, if allowable, in an ambulatory surgery center (ASC) where facility fees are lower (the OPPS/ASC Cap). 2 For many capital intense treatments or procedures, such as radiation therapy for cancer and phototherapy for conditions such as psoriasis, the result is a substantial decrease in reimbursement for such treatments or procedures when performed in the physician s office setting. The chart below illustrates the projected reimbursement decreases resulting solely from implementation of the proposed OPPS/ASC Cap for several HCPCS codes: Code Description PFS 13 PFS 14 PFS % Change RT Delivery Complex $ $ % MEV RT Delivery Complex 6- $ $ % 10 MEV Radiation Therapy $ $ % Dose Plan IMRT Simulation Complex $ $ % Photochemotherapy $76.21 $ % with uv-b Photochemotherapy with uv-a $97.65 $ % As you can see from the foregoing, the CMS-proposed OPPS/ASC Cap often times has the effect of substantially reducing Medicare reimbursement for treatments and procedures provided in the physician s office setting over 2013 Medicare PFS reimbursement amounts up to 60 percent in the case of photochemotherapy with uv-a. Such substantial decreases are simply unabsorbable for physicians, particularly if commercial third party payors follow Medicare s lead in reducing reimbursement for the impacted HCPCS codes. As such, if CMS moves forward in implementing the proposed OPPS/ASC Cap, many physicians may decide to cease offering such services or cease accepting Medicare patients, forcing beneficiaries to seek alternative treatment locations, pay out-of-pocket for such treatments or procedures at their current physician offices or switch to alternative treatments which may be more expensive for Medicare and the patient. For instance, certain biologics are an 2 Id. at 43,296. 2
3 alternative treatment to phototherapy for psoriasis. Such biologics can cost up to $30,000 a year compared to the average cost of $3,000 a year for phototherapy. 3 Implementation of the proposed OPPS/ASC Cap will undoubtedly hinder patient access to needed treatments or procedures since patients will be forced to travel to hospital outpatient departments, which are often inconvenient and hours from a patient s home, pay out-of-pocket for the entire cost of treatment at their current physician s office or switch to an alternative course of treatment, which will often result in a higher co-insurance obligation for a beneficiary given the higher costs associated with such a treatment alternative. REAP urges CMS to reconsider the proposed OPPS/ASC Cap given the potential negative impact on beneficiaries access to needed medical treatments and procedures. REAP is concerned that by capping the values as proposed, CMS is arbitrarily setting values for non-facility PE in the RVU calculation to achieve the goal of equalization. Rather, the goal should be to adequately reimburse physicians for quality care so that their clinical decisions are driven by what is in the best interests of the patient and not by the economics of their decision(s). If CMS is truly interested in Medicare reimbursement parity between the hospital outpatient and physician s office sites of service, we recommend that CMS explore establishing universal Medicare reimbursement for treatments and procedures regardless of the site of service for Sustainable Growth Rate REAP members are concerned thatt substantial decreases in Medicare reimbursement, whether targeted or specific to certain specialties, procedures or treatments or more global in nature, can result in diminished access for Medicare patients to specialists, treatments and procedures. REAP members are particularly concerned that the projected 24.4 percent decrease in Medicare reimbursement which will result absent Congressional action due to implementation of the conversion factor reduction required by the SGR formula, will negatively impact Medicare beneficiaries on a global basis. In November 2011, when physicians were facing a similar cut in Medicare reimbursement absent a Congressional fix, the Medical Group Management Association released the results of a survey of 2,176 medical groups representing more than 93,000 physicians assessing the impact of a potential decrease in Medicare reimbursement on physician group practice management. 4 In response to this survey, 51 percent of medical groups surveyed indicated they would reducee the number of appointments for new Medicaree patients in response to the projected decrease in Medicare reimbursement. In addition, the annual threat of a drastic reduction in Medicare reimbursement due to the SGR formula and the uncertainty stemming from such potential reimbursement reductions have taken a toll on the potential quality of care available to patients at physicians practices. According to the Medical Group Management Association survey, 64.7 percent of physician groups surveyed indicate 3 Beyer V, Wolverton DE, Recent Trends in Systemic Psoriasis Treatment Costs. Archives of Dermatology. 2010: 146(1): A summary of the survey results is available at
4 they delayed purchasing new clinical equipment or upgrading facilities because of a potential cut in Medicare reimbursement while 31 percent of physician groups indicated they delayed purchasing electronic medical record software because of the anticipated decrease in Medicare reimbursement. As evidenced by the 2011 Medical Care Management Association survey, even the threat of a dramatic decrease in Medicare reimbursement due to implementation of the conversion factor reduction under the SGR formula has a negative impact on Medicare beneficiary access. For instance, as the survey results indicated, many physicians had actually already put off acquiring needed diagnostic machines and other clinical equipment. We urge CMS to continue to support Congressional efforts to permanently repeal the SGR formula for the benefit of all Medicare beneficiaries, and to ensure that this repeal is not funded by reducing funds to other important aspects of patient health such as the Prevention and Public Health Fund. REAP members believe that until Congress enacts a new, more appropriate methodology for regulating the growth in Medicare payments to physicians, patients will continue to face challenges in physician access for both primary and specialty care. The estimated 24.4 percent cut in physician s payment rates, in addition to payment reductions due to sequestration, simply cannot be implemented without dire consequences to patient care. Until such permanent reform is enacted, CMS should do everything possible to mitigate these cuts and ensure that Medicare patients continue to have access to high quality care. Failure to do so will not only impact patient care but potentially could contribute to the increasing costs of caring for this vulnerable population. Proposals focused on rewarding providers for the provision of quality care to Medicare beneficiaries Chronic Care Management In the Proposed Rule, CMS proposes establishing a new G-code for ongoing chronic care management and coordination. Many of the member organizations which comprise REAP focus their advocacy efforts related to one or more chronic conditions; REAP s member organizations know first-hand the impact of proper management of such conditions on an individual s overall quality of life. REAP applauds CMS for its commitment to the management of chronic conditions by qualified health care professionals evidenced through its proposed G-code for chronic care management and coordination. By providing adequate Medicare reimbursement for the management of chronic conditions, CMS will ensure that physicians dedicate sufficient resources to effectively managing their chronic conditions. CMS has proposed defining a chronic condition via reference to the list of chronic conditions in the CMS 2012 Medicare Chronic Conditions Chartbook. The World Health Organization (WHO) defines a chronic disease as a disease of long duration and generally slow progression. 5 As example of the Chartbook s limitation, while Multiple Sclerosis (MS) and Amyotrophic Lateral Sclerosis (ALS) would certainly meet that WHO s definition of a chronic disease, they are absent from the chronic conditions listed in the CMS 2012 Medicare Chronic Conditions Chartbook. We encourage CMS to adopt the WHO s definition of chronic disease or condition and work with the WHO, other global health organizations and federal government agencies to obtain, or if necessary, compile a more thorough and comprehensive list of chronic conditions. Furthermore, according to the Proposed Rule, in order for a physician to receive Medicare reimbursement for chronic care management for a given patient, the patient must have at least two 5 See WHO definition of chronic disease at (last visited Aug. 28, 2013). 4
5 significant chronic conditions whichh are listed in the CMS 2012 Medicare Chronic Conditions Chartbook. REAP recommends that CMS eliminate the dual chronic condition requirement. Depending on the chronic disease, the patient s lifestyle and individual characteristics of the patient, managing even one chronic condition can result in extensive care coordination, distress screenings and patient education and counseling on the part of a treating physician. Physicians managing such a chronic condition should be properly compensated for their management and coordination activities. In addition, we believe that the proposed requirement that a physician have an annual wellness visit with a given patient in order to bill Medicare for chronic care management using the designated G-code limits the types of physicians eligible to bill for chronic care management to internistss and primary care physicians because annual wellness visit is already defined as a general, preventative health assessment under the Medicare program. 6 In order to avoid such a limitation on the use of the chronic care management G-code, REAP urges CMS to expand the scope of the annual wellness visit requirement to include a face-to-facdistress screening of the patient, related to the chronic condition within the past year in order for the visit with the patient, including a physical examination and physician to bill Medicare for chronic care management under the new G-code. As discussed above, specialists, and particularly oncologists in the case of cancer patients, often play a vital role in managing certain chronic conditions. Giving particular attention to these chronic conditions should not preclude an examination from being considered an annual wellness visit for Medicare billing purposes, if it includes services otherwise required within the definition of annual wellness visit. Value-Based Payment Modifier REAP members are strong advocates for reimbursement systems which promote and reward quality patient care. We support CMS in its continued implementation of the value-based payment modifier required under the Affordable Care Act, and appreciate the methodical approach CMS has taken in introducing value-based elements into the cost-based Medicare reimbursement system; such an approach has allowed physicians to slowly adapt to reimbursement changes over a period of years. For 2016, CMS has proposed a downward 2 percent adjustment for physicians who fail to report Physician Quality Reporting System (PQRS) data. In addition, CMS has proposed narrowing the options for PQRS submission by eliminating the claims-based option. REAP urges CMS to retain the claims-based submission option. While we understand that most larger physician groups are able to submit PQRS data through the Registry, Electronic Health Records or Group Practice options, many smaller, rural practices that are less technologically advanced cannot and do not employ such options. Absent the 6 See the description of yearly wellness visits on medicare.gov at a personalized yearly-wellness-exams.html (explaining that annual wellness visits are aimed at developing or updating prevention plan for a given patient to prevent disease and disability based on the patient s current health and risk factors. The annual wellness visit includes: a review of a patient s medical and family history; developing or updating of the patient s list of current providers and prescriptions; height, weight, blood pressure, and other routine measurements; detection of any cognitive impairment; personalized health advice; a discussion of risk factors and treatment options for the given patient; and a screening schedule for appropriate preventive services).
6 claims-based submission process, such smaller, rural physicians practices will not be able to submit PQRS data and will receive a 2 percent reduction in Medicare reimbursement. REAP members are concerned that smaller, accumulating decreases in Medicare reimbursement can result in beneficiary access issues with many physicians offices choosing to close completely or consolidate with hospital systems in the face of such declining reimbursement or simply cease accepting Medicare patients. CMS has proposed basing the 2016 value-based payment modifier adjustment on PQRS data submitted 2 years prior. In other words, the 2016 value-based payment would be based on PQRS data submitted for the 2014 calendar year. REAP urges CMS to attempt to reduce the 2-year lag between PQRS data collection and the use of such data in establishing the value-based modifier adjustment for physicians. A lag between PQRS data measurement and the resulting payment adjustment does not reward improvements in quality of care made by physicians practices during the current year. Furthermore, with physicians facing a 4 percent decrease in Medicare reimbursement across the board due to sequestration beginning in 2014, the provision of a 2 percent value-based modifier payment is more critical than ever. Physicians should be entitled to such 2 percent payments if their current PQRS measures evidence the provision of quality of care to patients. Lastly, CMS has proposed (1) allowing physicians to include patient experience data collected via the voluntary Clinical and Group Consumer Assistance of Healthcare Providers and Systems (CG-CAHPS) survey in their PQRS data and (2) including efficiency measures focused on total Medicare spending per beneficiary into the PQRS data. REAP members believe a positive patient experience is indicative of quality healthcare and commend CMS for proposing to include patient experience measures into the PQRS data. REAP urges CMS to continue exploring means of further incorporating patient experience into the value-based payment modifier system. Proposals focused on transparency in Medicare coverage and quality of care provided The Physician Compare Website REAP members are excited to see that, under the Proposed Rule, CMS continues to expand the types of physician-specific data that CMS will make publicly available on the Physician Compare Website. Furthermore, CMS has proposed publishing such data for small and large physicians practices alike. 7 REAP members value and support patient choice as to the selection of their health care providers. The publication of data regarding outcomes, quality of care and patient experiences with health care providers, including physicians, is useful to health care consumers generally in the comparison and selection of a health care provider. We commend CMS for making such data available to the public at large and not just the Medicare population, and we urge CMS to ensure that all data published on the Physician Compare Website is fair, accurate, impartial and presented in plain English at a 6 th grade reading level. We also recommend that the Website be designed to automatically translate into languages other than English which are commonly spoken throughout the United States, such as Spanish, for use by those with limited English proficiency. We recommend that CMS utilize the 5 percent threshold as it does for Medicare Part D plan marketing materials when determining a language commonly spoken throughout the United States. 8 In addition, as not all physicians report on the same 7 In the Proposed Rule, CMS proposes to expand the publication of the Physician Quality Reporting System (PQRS) data for physicians group practices that not only report via the Group Practice Reporting Option (GPRO) but also through the Registry or EHR reporting options. The result will be the publication of PQRS data for a smaller physician practices in addition to large group practices. 8 See Chapter 2 of the Medicare Prescription Drug Benefit Manual Section
7 PQRS measures, consumers might misinterpret the absence of certain PQRS measures or patient experience data generally for a given physician as a negative outcome or review of such physician. We recommend that CMS include clear explanations for such unreported measures so that consumers will understand that the absence of a reported measure is not indicative of negative performance. We further encourage CMS to ensure that information published on the Physician Compare Website be in a simple format, easy to navigate and unencumbered with graphics that will slow down Internet operations so consumers will be able to view such information on smartphones or other mobile devices, which are often utilized by lower-income individuals as personal computers. ********* Again, we appreciate the opportunity to share our perspective on the Proposed Rule with you. REAP members stand ready to answer questions and provide any additional information about the patient groups for whom we advocate. Sincerely, Alpha-1 Association Alpha-1 Foundation American Kidney Fund Cancer Support Community C-Change COPD Foundation Cutaneous Lymphoma Foundation Epilepsy Foundation HealthHIV Kidney Cancer Association Leukemia & Lymphoma Society LUNGevity Foundation National Osteoporosis Foundation National Patient Advocate Foundation Prevent Cancer Foundation Retiresafe Sisters Network Susan G. Komen for the Cure Us TOO International Prostate Cancer Education and Support Network Zero - The Project to End Prostate Cancer
2014 CMS PROPOSED PHYSICIAN FEE SCHEDULE OVERVIEW & ANALYSIS
2014 CMS PROPOSED PHYSICIAN FEE SCHEDULE OVERVIEW & ANALYSIS OVERVIEW: The Centers for Medicare and Medicaid Services (CMS) released the proposed 2014 Medicare Physician Fee Schedule in July. Final code
More informationRe: Payment Policies under the Physician Fee Schedule Proposed Rule for CY 2014; 78 Fed. Reg. 43,281 (July 19, 2013); CMS-1600; RIN 0938-AR56
September 6, 2013 Marilyn B. Tavenner Administrator Centers for Medicare and Medicaid Services Department of Health and Human Services Hubert H. Humphrey Building, Room 445-G 200 Independence Avenue, SW
More informationHighlights of the 2018 Medicare Physician Fee Schedule (MPFS) Final Rule
Highlights of the 2018 Medicare Physician Fee Schedule (MPFS) Final Rule Physician Payment Update & Misvalued Codes Target The update to payments under the PFS in 2018 will be +0.31 percent. This reflects
More informationTexas Society of Clinical Oncology
Texas Society of Clinical Oncology President William Jordan, DO Fort Worth President-Elect Gladys Rodriguez, MD San Antonio Secretary Ray Page, DO, PhD Weatherford Treasurer Gary Gross, MD Tyler Immediate
More informationOur comments focus on the following components of the proposed rule: - Site Neutral Payments,
Mr. Andy Slavitt Acting Administrator Centers for Medicare & Medicaid Services Department of Health & Human Services Hubert H. Humphrey Building 200 Independence Ave., S.W. Room 445-G Washington, DC 20201
More informationAssignment of Medicare Fee-for-Service Beneficiaries
February 6, 2015 Ms. Marilyn B. Tavenner, Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services Attention: CMS-1461-P Room 445-G, Hubert H. Humphrey Building 200
More informationSeptember 11, 2017 REF: CMS-1676-P
Ms. Seema Verma Administrator Centers for Medicare & Medicaid Services Department of Health & Human Services Room 445-G Herbert H. Humphrey Building 200 Independence Avenue, SW Washington, DC 20201 REF:
More informationICD-10 is Financially Disastrous for Physicians
Kathleen Sebelius Secretary US Department of Health and Human Services Hubert H Humphrey Building, Room 445-G 200 Independence Avenue, SW Washington, DC 20201 Dear Secretary Sebelius: On behalf of the
More informationJune 25, Dear Administrator Verma,
June 25, 2018 Seema Verma Administrator Centers for Medicare and Medicaid Services U.S. Department of Health and Human Services Room 445 G, Hubert H. Humphrey Building 200 Independence Avenue SW Washington,
More informationAmerican Health Lawyers Association Institute on Medicare and Medicaid Payment Issues. History of the Physician Fee Schedule
American Health Lawyers Association Institute on Medicare and Medicaid Payment Issues March 20-22, 2013 Baltimore, Maryland Sidney S. Welch, Esq. 1 History of the Physician Fee Schedule Prior to 1992,
More informationDivision C: Increasing Choice, Access, and Quality in Health Care for Americans TITLE XV: Provisions Relating to Medicare Part A
Division C: Increasing Choice, Access, and Quality in Health Care for Americans TITLE XV: Provisions Relating to Medicare Part A Sec. 15001. Development of Medicare study for HCPCS versions of MS-DRG codes
More informationCANCER LEADERSHIP COUNCIL
CANCER LEADERSHIP COUNCIL A PATIENT-CENTERED FORUM OF NATIONAL ADVOCACY ORGANIZATIONS ADDRESSING PUBLIC POLICY ISSUES IN CANCER April 10, 2014 Patrick Conway, M.D. Deputy Administrator for Innovation and
More informationMarch 28, Dear Dr. Yong:
March 28, 2018 Pierre Yong, MD Director Quality Measurement and Value-Based Incentives Group Centers for Medicare and Medicaid Services 7500 Security Boulevard Baltimore, MD 21244 Dear Dr. Yong: The American
More informationThe three proposed options for the use of CEHRT editions are as follows:
July 21, 2014 Marilyn B. Tavenner Administrator Centers for Medicare & Medicaid Services Karen B. DeSalvo, MD, MPH, MSc National Coordinator Office of the National Coordinator for Health Information Technology
More informationDecember 30, Dear Administrator Tavenner:
Ms. Marilyn Tavenner Administrator Centers for Medicare and Medicaid Services Department of Health and Human Services Attention: CMS-1612-FC P.O. Box 8013 7500 Security Boulevard Baltimore, MD 21244-8013
More informationSeptember 2, Dear Administrator Tavenner:
September 2, 2014 Marilyn B. Tavenner, MHA, BSN, RN Administrator Centers for Medicare and Medicaid Services Department of Health and Human Services P. O. Box 8013 Baltimore, MD 21244-8013 RE: Medicare
More informationCMS-0044-P; Proposed Rule: Medicare and Medicaid Programs; Electronic Health Record Incentive Program Stage 2
May 7, 2012 Submitted Electronically Ms. Marilyn Tavenner Acting Administrator Centers for Medicare and Medicaid Services Department of Health and Human Services Room 445-G, Hubert H. Humphrey Building
More informationStatement for the Record. American College of Physicians. Hearing before the House Energy & Commerce Subcommittee on Health
Statement for the Record American College of Physicians Hearing before the House Energy & Commerce Subcommittee on Health A Permanent Solution to the SGR: The Time Is Now January 21-22, 2015 The American
More informationHere is what we know. Here is what you can do. Here is what we are doing.
With the repeal of the sustainable growth rate (SGR) behind us, we are moving into a new era of Medicare physician payment under the Medicare Access and CHIP Reauthorization Act (MACRA). Introducing the
More informationApril 26, Ms. Seema Verma, MPH Administrator Centers for Medicare & Medicaid Services. Dear Secretary Price and Administrator Verma:
April 26, 2017 Thomas E. Price, MD Secretary Department of Health and Human Services Hubert H. Humphrey Building 200 Independence Avenue, SW Washington, DC 20201 Ms. Seema Verma, MPH Administrator Centers
More informationCalendar Year 2014 Medicare Physician Fee Schedule Final Rule
Calendar Year 2014 Medicare Physician Fee Schedule Final Rule Non-Facility Cap After receiving many negative comments on this issue from physician groups, along with the House GOP Doctors Caucus letter
More informationThe Evolving Landscape of Healthcare Payment: Incentive Programs and ACO Model Optimization. Quality Forum August 19, 2015
The Evolving Landscape of Healthcare Payment: Incentive Programs and ACO Model Optimization Quality Forum August 19, 2015 Ross Manson rmanson@eidebailly.com 701.239.8634 Barb Pritchard bpritchard@eidebailly.com
More informationComments on Request for Information on Specialty Practitioner Payment Model Opportunities
American Cancer Society Cancer Action Network 555 11 th Street, NW Suite 300 Washington, DC 20004 202.661.5700 Dr. Patrick Conway, MD, MSc Acting Director Center for Medicare & Medicaid Innovation Centers
More informationCAPPING NON-FACILITY PHYSICIAN FEE SCHEDULE PAYMENT RATES AT OUTPATIENT/AMBULATORY SURGICAL CENTER PROSPECTIVE PAYMENT RATES FOR CERTAIN SERVICES
September 4, 2013 Marilyn Tavenner Administrator Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1600-P, P.O. Box 8016, Baltimore, MD 21244-8016 Subject:
More informationHere is what we know. Here is what you can do. Here is what we are doing.
With the repeal of the sustainable growth rate (SGR) behind us, we are moving into a new era of Medicare physician payment under the Medicare Access and CHIP Reauthorization Act (MACRA). Introducing the
More informationSeptember 25, Via Regulations.gov
September 25, 2017 Via Regulations.gov The Honorable Seema Verma Administrator Centers for Medicare & Medicaid Services 7500 Security Boulevard Baltimore, MD 21244-1850 RE: Medicare and Medicaid Programs;
More informationCANCER LEADERSHIP COUNCIL
CANCER LEADERSHIP COUNCIL A PATIENT-CENTERED FORUM OF NATIONAL ADVOCACY ORGANIZATIONS ADDRESSING PUBLIC POLICY ISSUES IN CANCER November 20, 2017 Seema Verma Administrator Centers for Medicare & Medicaid
More informationRe: CMS Patient Relationship Categories and Codes Second Request for Information
January 6, 2017 Andrew Slavitt Acting Administrator Centers for Medicare & Medicaid Services 7500 Security Boulevard Baltimore, MD 21244 Re: CMS Patient Relationship Categories and Codes Second Request
More informationOverview of the EHR Incentive Program Stage 2 Final Rule published August, 2012
I. Executive Summary and Overview (Pre-Publication Page 12) A. Executive Summary (Page 12) 1. Purpose of Regulatory Action (Page 12) a. Need for the Regulatory Action (Page 12) b. Legal Authority for the
More informationThe Healthcare Roundtable
The Healthcare Roundtable MACRA Update Jayme R. Matchinski Greensfelder, Hemker & Gale, P.C. April 7, 2017 New Orleans, Louisiana This presentation and outline are limited to a discussion of general principles
More informationMarch 5, March 6, 2014
William Lamb, President Richard Gelula, Executive Director March 5, 2012 Ph: 202.332.2275 Fax: 866.230.9789 www.theconsumervoice.org March 6, 2014 Marilyn B. Tavenner Administrator Centers for Medicare
More informationMACRA Quality Payment Program
The American College of Surgeons Resources for the New Medicare Physician System Table of Contents Simple Steps to Determine If MIPS Applies to Your Practice Situation... 3 5 Understanding the... 6 7 Big
More informationSeptember 2, Dear Mr. Slavitt:
Andrew M. Slavitt Acting Administrator Centers for Medicare & Medicaid Services Hubert H. Humphrey Building 200 Independence Avenue, S.W., Room 445-G Washington, DC 20201 RE: CMS-1656-P, Medicare Program;
More informationSummary of U.S. Senate Finance Committee Health Reform Bill
Summary of U.S. Senate Finance Committee Health Reform Bill September 2009 The following is a summary of the major hospital and health system provisions included in the Finance Committee bill, the America
More informationSeptember 2, Dear Secretary Burwell,
20555 VICTOR PARKWAY LIVONIA, MI 48152 p 734-343-1000 newhealthministry.org September 2, 2014 The Honorable Sylvia Burwell Centers for Medicare & Medicaid Services Department of Health and Human Services
More informationSubmitted electronically:
Mr. Andy Slavitt Acting Administrator Centers for Medicare and Medicaid Services Department of Health and Human Services Attention: CMS-5517-FC P.O. Box 8013 7500 Security Boulevard Baltimore, MD 21244-8013
More informationCMS Quality Payment Program: Performance and Reporting Requirements
CMS Quality Payment Program: Performance and Reporting Requirements Session #QU1, February 19, 2017 Kristine Martin Anderson, Executive Vice President, Booz Allen Hamilton Colleen Bruce, Lead Associate,
More informationSeptember 6, Submitted electronically at
9312 Old Georgetown Road Bethesda, MD 20814-1621 Tel: 301-571-9200 Fax: 301-530-2752 www.apma.org September 6, 2013 Marilyn B. Tavenner Administrator Centers for Medicare & Medicaid Services Department
More informationRodney M. Wiseman, DO, FACOFP dist. ACOFP President
November 20, 2017 VIA ELECTRONIC SUBMISSION (CMMI_NewDirection@cms.hhs.gov) Seema Verma, Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services Attention: CMMI Request
More informationStatement for the Record. American College of Physicians. U.S. House Committee on Ways and Means Subcommittee on Health
Statement for the Record American College of Physicians U.S. House Committee on Ways and Means Subcommittee on Health Hearing on Implementation of MACRA s Physician Payment Policies March 21, 2018 The
More informationCenters for Medicare & Medicaid Services: Innovation Center New Direction
Centers for Medicare & Medicaid Services: Innovation Center New Direction I. Background One of the most important goals at CMS is fostering an affordable, accessible healthcare system that puts patients
More informationRe: Medicare Program; Medicare Shared Savings Program: Accountable Care Organizations
BY ELECTRONIC DELIVERY Marilyn Tavenner Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services Room 445-G Hubert H. Humphrey Building 200 Independence Avenue, S.W.
More informationMedicare Physician Fee Schedule. September 10, 2018
September 10, 2018 Ms. Seema Verma, MPH Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services Attention: CMS-1694-P P.O. Box 8011 Baltimore, MD 21244-1850 Submitted
More informationREPORT OF THE COUNCIL ON MEDICAL SERVICE. Hospital-Based Physicians and the Value-Based Payment Modifier (Resolution 813-I-12)
REPORT OF THE COUNCIL ON MEDICAL SERVICE CMS Report -I- Subject: Presented by: Referred to: Hospital-Based Physicians and the Value-Based Payment Modifier (Resolution -I-) Charles F. Willson, MD, Chair
More informationSeptember 22, 2017 VIA ELECTRONIC SUBMISSION
September 22, 2017 VIA ELECTRONIC SUBMISSION The Honorable Seema Verma Administrator Centers for Medicare and Medicaid Services Department of Health and Human Services 7500 Security Boulevard Baltimore,
More informationTCS FAQ s. How will the implementation of national standard code sets reduce burden on the health care industry?
TCS FAQ s What is a code set? Under HIPAA, a code set is any set of codes used for encoding data elements, such as tables of terms, medical concepts, medical diagnosis codes, or medical procedure codes.
More informationSeptember 2, Dear Administrator Tavenner:
September 2, 2014 Marilynn Tavenner Administrator Centers for Medicare and Medicaid Services Department of Health and Human Services Attention: CMS -1612-P Mail Stop 7500 Security Boulevard Baltimore,
More informationAugust 31, Dear Mr. Slavitt:
August 31, 2016 Mr. Andrew Slavitt, Acting Administrator Centers for Medicare and Medicaid Services Department of Health and Human Services 200 Independence Avenue, SW Washington, DC 20201 RE: CMS-1656-P:
More informationMental Health Liaison Group
Mental Health Liaison Group The Honorable Nancy Pelosi The Honorable Harry Reid Speaker Majority Leader United States House of Representatives United States Senate Washington, DC 20515 Washington, DC 20510
More informationMACRA MACRA MACRA 9/30/2015. From the Congress: A New Medicare Payment System. The Future of Medicare: A Move Toward Value Driven Healthcare W20.
W20.8XXA The Future of Medicare: A Move Toward Value Driven Healthcare Emily L. Graham, RHIA, CCS-P VP, Regulatory Affairs, Hart Health Strategies Consultant, Coalition of State Rheumatology Organizations
More informationOverview of Quality Payment Program
Overview of Quality Payment Program Policies for 2017 & 2018 Performance Years The Medicare program has transformed how it reimburses psychiatrists and other clinicians for providing services, under the
More informationP C R C. Physician Clinical Registry Coalition. [Submitted online at: https://www.regulations.gov/document?d=cms ]
P C R C Physician Clinical Registry Coalition Mr. Andrew Slavitt Acting Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services Attention: CMS-5517-FC P.O. Box 8013
More informationThird Party Payer Days. IMGMA February 25, 2015
Third Party Payer Days IMGMA February 25, 2015 Agenda 2015 Medicare Physician Fee Schedule Medicare Physician Fee Schedule Database Transitional Care Management - Reminder Medicare - Coverage Guidelines
More informationReimbursement Models of the Future A Look at Proposed Models
Experience the Eide Bailly Difference Reimbursement Models of the Future A Look at Proposed Models Ralph J. Llewellyn, CPA, CHFP Partner rllewellyn@eidebailly.com 701.239.8594 Introduction CAH reimbursement
More informationSeptember 11, Submitted electronically through
September 11, 2017 The Honorable Seema Verma Administrator Centers for Medicare & Medicaid Services Hubert H. Humphrey Building 200 Independence Avenue, S.W., Room 445-G Washington, DC 20201 Submitted
More informationEvaluation & Management ( E/M ) Payment and Documentation Requirements
National Partnership for Hospice Innovation 1299 Pennsylvania Ave., Suite 1175 Washington DC, 20004 September 10, 2017 Seema Verma Administrator Centers for Medicare & Medicaid Services, Department of
More informationRE: Medicare Program; CY 2018 Updates to the Quality Payment Program (CMS P)
Seema Verma Administrator Centers for Medicare and Medicaid Services U.S. Department of Health and Human Services Hubert H. Humphrey Building 200 Independence Ave, SW Washington, DC 20201 RE: Medicare
More informationCMS Incentive Programs: Timeline And Reporting Requirements. Webcast Association of Northern California Oncologists May 21, 2013
CMS Incentive Programs: Timeline And Reporting Requirements Webcast Association of Northern California Oncologists May 21, 2013 Objective This webcast will address CMS s Incentive Program reporting requirements
More informationMACRA Frequently Asked Questions
Following the release of the Quality Payment Program Interim Final Rule, the American Medical Association (AMA) conducted numerous informational and training sessions for physicians and medical societies.
More informationREGULATION, ACCREDITATION, AND PAYMENT PRACTICE GROUP (June, July, August 2004)
REGULATION, ACCREDITATION, AND PAYMENT PRACTICE GROUP (June, July, August 2004) Lester J. Perling Broad and Cassel Fort Lauderdale, Florida I. Case Summaries CMNs Document Medical Necessity In Maximum
More informationPolitical and Legislative Environment
- 2-208 Washington Update Drew Voytal, MPA Associate Director MGMA Government Affairs Agenda Political and legislative environment Federal physician payment landscape Other Trending topics MGMA Advocacy
More informationSeptember 27, RE: Medicaid Primary Care Rate Increase. Dear Administrator Tavenner:
September 27, 2013 Marilyn Tavenner, Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services Room 445 G, Hubert H. Humphrey Building 200 Independence Avenue SW Washington,
More informationMedicare Quality Payment Program: Deep Dive FAQs for 2017 Performance Year Hospital-Employed Physicians
Medicare Quality Payment Program: Deep Dive FAQs for 2017 Performance Year Hospital-Employed Physicians This document supplements the AMA s MIPS Action Plan 10 Key Steps for 2017 and provides additional
More informationMedicare 101. Lisa Satterfield, ASHA director, health care regulatory advocacy Neela Swanson, ASHA director, health care coding policy
Medicare 101 Lisa Satterfield, ASHA director, health care regulatory advocacy Neela Swanson, ASHA director, health care coding policy Neela Swanson Director, Health Care Coding Policy, ASHA Disclosure
More information2018 Medicare Advantage Dual Eligible Special Needs Plan (DSNP) & Model of Care (MOC) Overview
2018 Medicare Advantage Dual Eligible Special Needs Plan (DSNP) & Model of Care (MOC) Overview Medicare Advantage (MA) Program Part C Medicare Advantage Medicare Part A and B benefits are administered
More informationCMS Ignored Congressional Intent in Implementing New Clinical Lab Payment System Under PAMA, ACLA Charges in Suit
FOR RELEASE Media Contacts: December 11, 2017 Erin Schmidt, (703) 548-0019 eschmidt@schmidtpa.com Rebecca Reid, (410) 212-3843 rreid@schmidtpa.com CMS Ignored Congressional Intent in Implementing New Clinical
More informationRe: Medicare Program; Medicare Shared Savings Program: Accountable Care Organizations, Proposed rule.
June 3, 2011 Donald Berwick, MD Administrator Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1345-P, Mail Stop C4-26-05, 7500 Security Boulevard, Baltimore,
More informationPopulation Health and the Accelerating Leap to Outcomes-Based Reimbursement. Craig J. Wilson
Population Health and the Accelerating Leap to Outcomes-Based Reimbursement Craig J. Wilson Agenda / Goals Define Population Health Management Review emerging reimbursement landscape eg MACRA Review why
More informationSeptember 6, Dear Ms. Tavenner:
September 6, 2013 Marilyn Tavenner Acting Administrator and Chief Operating Officer Centers for Medicare and Medicaid Services Department of Health and Human Services P. O. Box 8013 Baltimore, MD 21244-8013
More informationChronic Care Management. Sharon A. Shover, CPC, CEMC 2650 Eastpoint Parkway, Suite 300 Louisville, Kentucky
Chronic Care Management Sharon A. Shover, CPC, CEMC 2650 Eastpoint Parkway, Suite 300 Louisville, Kentucky 40223 502.992.3511 sshover@blueandco.com Agenda Chronic Care Management (CCM) History Define Requirements
More informationComments to the CMS Request for Information, Merit-based Incentive Payment System and Promotion of Alternative Payment Models
November 16, 2015 Centers for Medicare & Medicaid Services Department of Health and Human Services Hubert H. Humphrey Building 200 Independence Ave., SW Washington, DC 20201 Attention: CMS 3321- NC Comments
More informationMedicare Physician Payment Reform:
Medicare Physician Payment Reform: Implications and Options for Physicians and Hospitals Background The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) was signed into law on April 14, 2015.
More informationValue-Based Reimbursements are Here: Are you Ready?
Value-Based Reimbursements are Here: Are you Ready? White Paper ELLIS MAC KNIGHT, MD Senior Vice President/CMO Published by Becker s Hospital Review April 2016 White Paper Value-Based Reimbursements are
More informationHospice Program Integrity Recommendations
Hospice Program Integrity Recommendations Projected increases in the elderly population and the number of Medicare beneficiaries will likely result in continued growth in utilization of hospice services.
More informationProtecting Access to Medicare Act of 2014
Protecting Access to Medicare Act of 2014 Protects Current Medicare Beneficiaries Doc Fix : Prevents the 24% cut in reimbursement to doctors who treat Medicare patients on April 1, 2014 and replaces it
More informationMedPAC June 2013 Report to Congress: Medicare and the Health Care Delivery System
MedPAC June 2013 Report to Congress: Medicare and the Health Care Delivery System STEPHANIE KENNAN, SENIOR VICE PRESIDENT 202.857.2922 skennan@mwcllc.com 2001 K Street N.W. Suite 400 Washington, DC 20006-1040
More informationDecember 23, Dear Mr. Slavitt:
December 23, 2016 Mr. Andrew Slavitt Acting Administrator Centers for Medicare & Medicaid Services U.S. Department of Health and Human Services Hubert H. Humphrey Building, Room 445-G 200 Independence
More information2017 Home Health PPS Rate Update
2017 Home Health PPS Rate Update On November 3, 2016, CMS issued the Final Rule to update the Home Health Prospective Payment System (HH PPS) rates for Calendar Year (CY) 2017. In summary, this final rule:
More informationCY2015 Final Rule Summary Medical Oncology
CY2015 Final Rule Summary Medical Oncology Medicare Physician Fee Schedule (MPFS) Prepared By: Revenue Cycle Inc. Prepared On: October 31, 2014 http://www.revenuecycleinc.com/disclaimer. 1817 West By using
More informationP C R C. Physician Clinical Registry Coalition. January 1, [Submitted online at: https://www.regulations.gov/document?d=cms ]
Ms. Seema Verma, MPH Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services Attention: CMS-5522-FC P.O. Box 8016 Baltimore, MD 21244-8016 P C R C Physician Clinical
More informationPassage of Medicare Access and CHIP Reauthorization Act of 2015 (MACRA): The Doc Fix
April, 2015 Passage of Medicare Access and CHIP Reauthorization Act of 2015 (MACRA): The Doc Fix Author: Annemarie Wouters, Senior Advisor The President has signed into law the bipartisan bill H.R. 2,
More informationRE: Medicare Program; Request for Information Regarding the Physician Self-Referral Law
1055 N. Fairfax Street, Suite 204, Alexandria, VA 22314, TEL (703) 299-2410, (800) 517-1167 FAX (703) 299-2411 WEBSITE www.ppsapta.org August 24, 2018 Seema Verma, MPH Administrator Centers for Medicare
More informationRe: California Health+ Advocates opposes the proposed state budget changes to the 340B program
May 2, 2017 René Mollow, Deputy Director Health Care Benefits and Eligibility Department of Health Care Services 1501 Capitol Avenues, MS 0007 P.O. Box 997413 Sacramento, CA 95899-7413 Re: California Health+
More informationGetting Ready for the Post-SGR World. Presented by: Sybil R. Green, JD, RPh, MHA. West Virginia Oncology Society Spring Meeting May 5, 2016
Getting Ready for the Post-SGR World Presented by: Sybil R. Green, JD, RPh, MHA West Virginia Oncology Society Spring Meeting May 5, 2016 CME/CE Information For Physicians: This activity has been planned
More informationVALUE BASED ORTHOPEDIC CARE
VALUE BASED ORTHOPEDIC CARE Becker's 14th Annual Spine, Orthopedic and Pain Management- Driven ASC Conference + The Future of Spine June 9-11, 2016 Swissotel, Chicago, IL LES JEBSON Administrator, Adjunct
More informationHOT ISSUES FACING HOME HEALTH & HOSPICE AGENCIES. Luke James Chief Strategy Officer Encompass Home Health & Hospice
HOT ISSUES FACING HOME HEALTH & HOSPICE AGENCIES Luke James Chief Strategy Officer Encompass Home Health & Hospice Hospice Challenges Past & Present Face-to-Face (F2F) Implementation Sequestration Cuts
More informationStatement on the HCFA Medicare Physician Fee Schedule Proposed Rule
Statement on the HCFA Medicare Physician Fee Schedule Proposed Rule September 20, 1999 Attention: HCFA-1065-P RIN 0938-AJ61 Full Title: Medicare Program; Revisions to Payment Policies Under the Physician
More informationPrior to implementation of the episode groups for use in resource measurement under MACRA, CMS should:
Via Electronic Submission (www.regulations.gov) March 1, 2016 Andrew M. Slavitt Acting Administrator Centers for Medicare and Medicaid Services 7500 Security Boulevard Baltimore, MD episodegroups@cms.hhs.gov
More informationAugust 25, Dear Ms. Verma:
Seema Verma Administrator Centers for Medicare & Medicaid Services Hubert H. Humphrey Building 200 Independence Avenue, S.W. Room 445-G Washington, DC 20201 CMS 1686 ANPRM, Medicare Program; Prospective
More informationRe: CMS 3244 P (42 CFR Parts 482 and 485: Medicare and Medicaid Programs; Reform of Hospital and Critical Access Hospital Conditions of Participation)
December 21, 2011 SUBMITTED ELECTRONICALLY Marilyn Tavenner Acting Administrator Centers for Medicare & Medicaid Services Hubert H. Humphrey Building 200 Independence Ave, SW Room 445-G Washington, DC
More informationDecember 3, 2010 BY COURIER AND ELECTRONIC MAIL
Charles N. Kahn III President & CEO December 3, 2010 BY COURIER AND ELECTRONIC MAIL Donald Berwick, M.D. Administrator Centers for Medicare & Medicaid Services Attention: CMS-6028-P Hubert H. Humphrey
More informationRE: CMS-1677-P; Medicare Program; Request for Information on CMS Flexibilities and Efficiencies
June 13, 2017 Ms. Seema Verma Administrator Centers for Medicare and Medicaid Services Department of Health and Human Services Attention: CMS-1677-P P.O. Box 8011 Baltimore, MD 21244-1850 RE: CMS-1677-P;
More informationModernizing Medicaid DSH: Policy Options To Ensure Vital Support for Essential Hospitals
Modernizing Medicaid DSH: Policy Options To Ensure Vital Support for Essential Hospitals Medicaid disproportionate share hospital (DSH) payments support hospitals that provide care to Medicaid and low-income
More informationOMC Strategic Plan Final Draft. Dear Community, Working together to provide excellence in health care.
Dear Community, Working together to provide excellence in health care. This mission statement, established nearly two decades ago, continues to be fulfilled by our employees and medical staff. This mission
More information1965-1969 1970-1974 1975-1979 1980-1984 1985-1989 1990-1994 1995-1999 2000-2004 2005-2009 Intro Entire Timeline Displaying: 1965-2009 1965-2009 1965: President Johnson signed H.R. 6675 to establish Medicare
More informationDecember 19, Dear Acting Administrator Slavitt:
December 19, 2016 Andrew M. Slavitt Acting Administrator, Centers for Medicare & Medicaid Services Department of Health and Human Services Attention: CMS-5517-FC Submitted electronically via http://www.regulations.gov
More informationSubmitted electronically to and by mail to:
Submitted electronically to http://www.regulations.gov, and by mail to: 12255 El Camino Real Suite 100 San Diego, CA 92130 T 858 481 2727 F 858 481 8919 2320 Cascade Pointe Blvd (28208) P.O. Box 668800
More informationSeptember 8, 2015 EXECUTIVE SUMMARY
AMERICAN ASSOCIATION OF NEUROLOGICAL SURGEONS THOMAS A. MARSHALL, Executive Director 5550 Meadowbrook Drive Rolling Meadows, IL 60008 Phone: 888-566-AANS Fax: 847-378-0600 info@aans.org President H. HUNT
More informationOverview of Select Health Provisions FY 2015 Administration Budget Proposal
Overview of Select Health Provisions FY 2015 Administration Budget Proposal On March 4, 2014, President Obama released his Administration s FY 2015 budget proposal to Congress. The budget contains a number
More informationQuality Payment Program Year 2: 2018 MIPS Participation. An Introductory Guide for CRNAs in 2018
Quality Payment Program Year 2: 2018 MIPS Participation An Introductory Guide for CRNAs in 2018 Quality Payment Program (QPP) The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) established
More information