Submitted Comments

Items Related to Physician Fee Schedules

September 10, 2018

Comments to CMS CY 2019 Physician Fee Schedule

The Alliance submitted comments to CMS' proposed CY 2019 Physician Fee Schedule supporting specific provisions to ease paperwork/documentation burdens, including:
  • Changing the required documentation of the patient’s history to focus only on the interval history since the previous visit; 
  • Eliminating the requirement for physicians to re-document information that has already been documented in the patient’s record by practice staff or by the patient; 
  • Allowing physicians to choose between current documentation guidelines, documenting by time only, or documenting by medical decision making only; 
  • Removing the need to justify providing a home visit instead of an office visit. 
However,  the Alliance also used its comments to voice its strong opposition to the consolidation of Evaluation and Management codes and the corresponding reduction in payment for E/M services for those that provide the most complex care. The Alliance submitted a series of examples of unintended consequences that the proposal would create and urged CMS not to move forward with that provision. 
Read Alliance Comment
September 11, 2017

Comment on the proposed CY 2018 Physician Fee Schedule

The Alliance submitted comments to CMS on the proposed CY2017 Physician Fee Schedule. Comment focused on:
  • The under estimation and erroneous valuation of 2 CPT codes: CPT 29580 (Strapping of Unna Boot), and CPT 29581 (Application of multi-layer compression system).
  • Supporting the decision to update the equipment items and the amount of oxygen for hyperbaric oxygen therapy (HBOT) so that the amount of oxygen conforms to the RUC recommended value.
  • Requesting national payment rate for CPT Codes 97607 and 97608 - describing negative pressure wound therapy (NPWT) services using a disposable device - similar to the rate proposed in the CY2018 hospital outpatient proposed rule.
  • 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 Alliance 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 Alliance Comment
December 19, 2016

Comments on MACRA final rule guiding MIPS and APMs

The Alliance submitted comments to CMS on its rule: Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive Under the Physician Fee Schedule, and Criteria for Physician-Focused Payment Models. Comments focused on ensuring that CMS considered of the impacts of the evolving value-based care/payment reform policies to wound care. The Alliance submitted comments to MACRA's quality physician payment proposed rule as well as on the "quality measures development plan," "patient relationships categories and codes," and "episode groups" draft policies.
View Alliance Comment 
September 6, 2016

Comments on the CY2017 Physician Fee Schedule

The Alliance submitted comments to CMS on its proposed Physician Fee Schedule update: "CMS-1654-P: Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2017; Medicare Advantage Pricing Data Release; Medicare Advantage and Part D Medical Low Ratio Data Release; Medicare Advantage Provider Network Requirements; Expansion of Medicare Diabetes Prevention Program Model." Alliance comments focused on wound care services it viewed as improperly/inaccurately valued by the fee schedule. The Alliance also called for increased transparency on how CMS will use global service data. Additional, the Alliance requested that CMS review its criteria for the expansions of the upcoming Diabetes Prevention Program model as the Medicare Diabetes Prevention Program (MDPP).
View Alliance Comment 
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