Comments

Items Related to CMS

September 24, 2018

Comments to CMS CY 2019 Hospital Outpatient Prospective Payment System (OPPS)

The Coalition submitted comments to CMS in response to its proposed CY 2019 Hospital Outpatient Prospective Payment System (PPS) and Ambulatory Surgical Center Payment Systems.  Comments focused on provisions related to packaging and payment methodology for cellular and tissue-based products for wounds (CTPs), and pass through status for CTPs. The Coalition recommended that CMS:
  • move quickly in establishing the CTP payment reforms 
  • work with wound care stakeholders in creating whatever methodology is ultimately chosen 
  • be transparent in providing the data utilized 
  •  support reduced copays for Medicare beneficiaries. 
  • utilize the correct CTP cost information 
  • ensure that facilities are billing correctly for CTPs 
  • ensure that patients come first and they continue to have access to this valuable adjunctive therapy
  • conduct an impact analysis and provide its results in a transparent manner. 
  • take into consideration that there are a wide variety of patients with chronic wounds, that wounds heal differently and that treatment is individualized

Read Coalition comment
September 9, 2018

Comments to CMS DME/ESRD Prospective Payment System (PPS)

The Coalition submitted comments to CMS's End-Stage Renal Disease Prospective Payment System, which also covers the DMEPOS competitive bidding program. Comments focused on concerns surrounding the proposed calculation of single payment amounts (SPAs) and the gap-filling pricing methodology that applies when new technologies receive a new HCPCS code and CMS must establish a fee schedule amount for these new items.

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July 22, 2018

Comments on CMS Pre-Claim Review Demonstration Project for Home Health Services

The Coalition submitted comments to CMS in response to the agency's request for comments on its “Pre-Claim Review Demonstration for Home Health Services.”  The Coalition urged CMS to withdraw the policy. Coalition comments expressed concern with about access issues and disruptions in patient care and noted the overall lack of implantation detail provided. “While it appears that CMS is trying to curb what it perceives is fraud and abuse in the home health sector, CMS should simply utilize data and resources it already has on hand to target specific types home health agencies whose behavior indicates that there may be fraudulent activity rather than implement a widespread demonstration project which will overburden and penalize home health agencies that have no record or patterns of fraud and abuse,” wrote the Coalition.

Read Coalition comment.
July 9, 2018

Comments to Interim Final Rule on Durable Medical Equipment Fee Schedule Adjustments

The Coalition submitted comments to CMS on the agency's DME Interim Final Rule- which addresses competitive bidding issues. Within the interim final rule, published in May, CMS temporarily increases the fee schedule rates from June 1, 2018, through December 31, 2018, for certain durable medical equipment (DME) items and services and enteral nutrition furnished in rural and non-contiguous areas (Alaska, Hawaii, and U.S. territories) of the country not subject to the Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) Competitive Bidding Program. 

Read Coalition Comment
September 11, 2017

Comments to CMS on the proposed CY 2018 Hospital Outpatient Prospective Payment System

The Coalition submitted comments to CMS on “CMS 1678-P, the Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems and Quality Reporting Programs.” Coalition comments addressed:
  • Issues with the methodology for packaging of skin substitutes (Cellular and/or Tissue Based Product for Skin Wounds, or CTPs)
  • Support for grandfathering in eight CTP products to the high-cost bucket of the newly established threshold between low and high costs
  • Request for CMS to work with stakeholders to obtain the proper data for creating appropriate APCs for the application of CTP products.
  • In response to CMS’s request for information on flexibility and efficiency opportunities to increase care, reduce costs and reduce burdens for clinicians and patients, the Coalition asked the agency to consider reform of the process it uses to assign new Healthcare Common Procedure Coding System (HCPCS) Level II billing codes to durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS).
View Coalition Comment
September 11, 2017

Comments to CMS on the proposed CY 2018 Physician Fee Schedule

The Coalition submitted comments to CMS on “CMS 1676-P: Medicare Program; Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2018.” The Coalition comments requested that CMS consider establishing office-based PE RUV’s for disposable Negative Pressure Wound Therapy (dNPWT). Comments also noted issues with codes and payment rates for NPWT services. The Coalition recommended that CMS assign direct cost inputs to disposable negative pressure wound therapy, which would allow the establishment of national payment rates for CPT codes 97607 and 97608 in the final Physician Fee Schedule (PFS) rule for CY 2018. In response to CMS’s request for information on flexibility and efficiency opportunities to increase care, reduce costs and reduce burdens for clinicians and patients, the Coalition asked the agency to consider reform of the process it uses to assign new Healthcare Common Procedure Coding System (HCPCS) Level II billing codes to durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS).
View Coalition Comment
December 25, 2016

Comments to CMS on Interim Final Rule with Comment Period on Hospital Outpatient Prospective Payment Systems (OPPS)

The Coalition submitted comments to CMS on the Interim Final Rule for the Hospital Outpatient Prospective Payment Systems, CMS-1656-IFC. The Coalition states that under this payment model, hospitals would lose the ability to provide cellular/ tissue based products (CTPs) and Negative Pressure Wound Therapy (NPWT) products to patients. The Coalition recommends that CMS reconsider their choice to adopt the Medicare Physicians Fee Schedule (MPFS) so that hospitals may have the ability to provide NPWT and CTP products. 
view coalition comment
September 6, 2016

Comments to CMS on Hospital Outpatient Prospective Payment System (PPS)

The Coalition submitted comments to CMS on the CMS on Hospital Outpatient Prospective Payment System (OPPS) proposed rule, CMS-1656-P, on issues regarding the packing of CTPs. The Coalition states that CMS has been using flawed data to calculate the setting rate for CTPs, something the Coalition has informed CMS about for years. The Coalition states that CMS needs to require correct coding for CTPs, ensuring that claims forms reflect the correct number of units being billed for. Furthermore, the Coalition recommends that whether or not a product falls into the low cost bucket or high cost bucket should be a function solely of the size of the CTP, regardless of its anatomic location.
view coalition comment
August 26, 2016

Comments to CMS on CY 2017 Home Health Prospective Payment System Rate Update; Home Health Value-Based Purchasing Model; and Home Health Quality Reporting Requirements

The Coalition submitted comments to CMS on the CY 2017 Home Health Prospective Payment System (PPS) Rate Update; Home Health Value-Based Purchasing Model; and Home Health Quality Reporting Requirements. The Coalition noted that its members had been involved and closely monitoring the creation of the Patient Access to Disposable Medical Technology Act of 2016. That Act became section 504 of the Consolidated Appropriations Act of 2016. Because Coalition members were so closely monitoring that process, the Coalition was very aware of the original congressional intent of these statutes as they relate to add-on payments to home health agencies (HHAs) and Negative Pressure Wound Therapy (NPWT). The Coalition clarified in comments that the intent of these statues was not for home health agencies to absorb to entire cost of care for a patient requiring NPWT in the home. The Coalition recommended that CMS revise their proposal to match the Congressional intent and language revolving around disposable NPWT devices in home health settings. 
view coalition comment
August 22, 2016

Comments to CMS regarding Medicare Program; Changes to the Medicare Claims and Entitlement, Medicare Advantage Organization Determination, and Medicare Prescription Drug Coverage Determination Appeals Procedures; Proposed Rule

The Coalition submitted comments to CMS regarding Medicare Program; Changes to the Medicare Claims and Entitlement, Medicare Advantage Organization Determination, and Medicare Prescription Drug Coverage Determination Appeals Procedures; Proposed Rule, recommending that CMS address their backlogged appeals process and minimize improper denials of Medicare contractor appeals. The Coalition suggested accomplishing this by means of proposals to improve broad audits and contractor reviews. Further, the Coalition advocated for a prohibition on contractors collecting provider overpayments until the appeals process has been exhausted on all levels. The Coalition also supported:
  • Mandatory education and training for all providers and Medicare contractors
  • The creation of a process for interested stakeholders to challenge published case precedent
  • The assurance that attorney adjudicators will have experience in Medicare coverage, coding, and payment and that those attorneys, too, receive continuous education and training on these issues. 
view coalition comment

August 22, 2016

Comments to CMS on Medicare Program Durable Medical Equipment Prosthetics, Orthotics, and Supplies (DMEPOS) Competitive Bidding Program Bid Surety Bonds, State Licensure and Appeals Process for Breach of Contract Actions, Durable Medical Equipment, Prosth

The Coalition submitted comments to CMS on CMS-1651-P: Medicare Program Durable Medical Equipment Prosthetics, Orthotics, and Supplies (DMEPOS) Competitive Bidding Program Bid Surety Bonds, State Licensure and Appeals Process for Breach of Contract Actions, Durable Medical Equipment, Prosthetics, Orthotics and Supplies Competitive Bidding Program and Fee Schedule Adjustments, Access to Care Issues for Durable Medical Equipment, stating that while the Coalition agrees with some provisions that CMS has adopted regarding the competitive bidding program, significant problems remain. Specifically, the Coalition is concerned that CMS does not do a sufficient job vetting vendors for the competitive bidding program or ensuring the implementation of quality standards and products. The Coalition also takes issue with CMS’s decrease in reimbursement for NPWT, as the ramifications of that decrease can have devastating impacts on rural communities.  
view coalition comment
May 9, 2016

Comments to CMS on Medicare Program; Part B Drug Payment Model

The Coalition submitted comments to CMS on to CMS on CMS -1670-P -Medicare Program; Part B Drug Payment Models, requesting that CMS withdraw the proposal entirely. The Coalition believes that the payment model lacks any evidence supporting its methodology. Furthermore, the regulation was proposed without taking stakeholder input into account. The Coalition believes that CMS has not sufficiently proved that their methodology will save costs or improve the quality of care, citing many gaps in the proposal. 
view coalition comment
February 19, 2016

Comments to CMS regarding Medicare Administrative Contractors contracting process

The Coalition submitted comments to CMS on the Medicare Administrative Contractors (MAC) contracting process, as per CMS’ request for information regarding the “Awarding and the Administration of Medicare Administrative Contractor Contracts (CMS 1653-NC).” The Coalition cites past and present accountability and transparency issues with the MACs/PDAC. The Coalition advocates for the extension of this request for information to the PDAC, instead of just the MACs. The Coalition outlines possible incentive systems for exceptional MAC performance, specific metrics or evaluation criteria to measure the quality of MAC service, and the level of information regarding MAC performance that should be public record. 
view coalition comment
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