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CMSRulemakingCMS-2012-0083

Medicare Program; Revisions to Payment Policies Under the Physician Fee Schedule, DME Face-to-Face Encounters, Elimination of the Requirement for Termination of Non-Random Prepayment Complex Medical Review and Other Revisions to Part B for CY 2013 (CMS-1590-P)

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American Health Care Association (AHCA/NCAL) filings
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American Health Care Association (AHCA/NCAL) filed 2 comments on this docket between Sep 4, 2012 and Sep 4, 2012. 516 other organizations filed here. The comment window closed 4957d ago.

What American Health Care Association (AHCA/NCAL) filed (2)

Sep 4, 2012· American Health Care Association (AHCA)· CMS-2012-0083-2374

Dear Administrator Tavenner: The American Health Care Association (AHCA) appreciates the opportunity to comment on Updating Existing Standards for E-prescribing under Medicare Part D and Lifting the LTC Exemption (Section III.M) of the Centers for Medicare & Medicaid Services (CMS) proposed rule, Medicare Program; Revisions to Payment Policies Under the Physician Fee Schedule, DME Face-to-Face Encounters, Elimination of the Requirement for Termination of Non-Random Prepayment Complex Medical Review and Other Revisions to Part B for CY 2013 (77 Federal Register, 45011). AHCA supports the retirement of NCPDP SCRIPT 8.1 on October 31, 2013 and the adoption of NCPDP SCRIPT 10.6 as the official Part D e-prescribing standard effective November 1, 2013. AHCA further supports the adoption of NCPDP SCRIPT 10.6 as the official Part D e-prescribing standard in LTPAC settings, but recommends that the lifting of the LTPAC exemption be delayed by an additional year to November 1, 2014 to allow sufficient time for LTPAC vendors to modify the necessary software, for LTPAC providers to upgrade their systems to implement the NCPDP SCRIPT 10.6 standard, and for state Boards of Pharmacy and Drug Enforcement Administration (DEA) related regulatory issues to be overcome. Please see our attached memo for our detailed comments and recommendations. Sincerely, Peter Gruhn Director of Research

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Sep 4, 2012· American Health Care Association (AHCA)· CMS-2012-0083-2381

Dear Administrator Tavenner: The American Health Care Association (AHCA) appreciates the opportunity to comment on Therapy Services (Section II.G) of the Centers for Medicare & Medicaid Services (CMS) proposed rule, Medicare Program; Revisions to Payment Policies Under the Physician Fee Schedule, DME Face-to-Face Encounters, Elimination of the Requirement for Termination of Non-Random Prepayment Complex Medical Review and Other Revisions to Part B for CY 2013 (77 Federal Register, 45011). AHCA supports the concept and need to collect additional data on patient function, condition, and outcomes. CMS' proposed solution however is inappropriate, unreliable, untested, and likely to generate invalid and distorted data that CMS will use to base its payment policy proposals for Medicare Part B therapy services. AHCA proposes that CMS should instead develop an incremental approach that is based on reliable and tested tools, would generate valid though less detailed data over an interim period, and that would inform and support the development of more refined tools that could in turn generate the data needed to design an alternative payment policy for Medicare Part B therapy services. Please see our attached letter for our detailed comments and recommendations. Sincerely, Peter Gruhn Director of Research

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Abstract

This major proposed rule addresses changes to the physician fee schedule, payments for Part B drugs, and other Medicare Part B payment policies to ensure that our payment systems are updated to reflect changes in medical practice and the relative value of services. It would also implement provisions of the Affordable Care Act by establishing a faceto- face encounter as a condition of payment for certain durable medical equipment (DME) items. In addition, it would implement statutory changes regarding the termination of non-random prepayment review under the Medicare Prescription Drug, Improvement, and Modernization Act of 2003. Finally, this proposed rule also includes a discussion regarding the Chiropractic Services Demonstration program.

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Co-filers (516)

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Medicare Program; Revisions to Payment Policies Under the Physician Fee Schedule, DME Face-to-Face Encounters, Elimination of the Requirement for Termination of Non-Random Prepayment Complex Medical Review and Other Revisions to Part B for CY 2013 (CMS-1590-P) (CMS) — American Health Care Association (AHCA/NCAL) | OpenPolis