2006 Reimbursement Updates
MDMA Comments on Ambulatory Surgical Center (ASC) Payment System Proposal
November 9th—MDMA recently submitted comments to CMS regarding the proposed rule on the ASC payment system and calendar year 2008 payment rates. MDMA emphasized the importance of appropriately setting the conversion factor so that procedures and the products used in those procedures would be adequately reimbursed. Click here to read MDMA's comments.
CMS Issues Outpatient Prospective Payment System Final Rules
November 1st -- The Centers for Medicare and Medicaid Services (CMS) issued three Final Rules pertaining to the payment for outpatient services, physician payment rates, home health services and certain durable medical equipment for calendar year 2007. The OPPS Final Rule provides for a 3.4 percent market basket update and the home health final rule provides for a 3.3 percent market basket update to Medicare payment rates for services paid in 2007. In addition, the OPPS rule ties outpatient rate increases to the reporting of quality measures beginning in 2009. To read each of the rules please click on the corresponding links below:
- 42 CFR Parts 410, 416, 419, 421, 485, and 488
- 42 CFR Parts 405, 410, 411, 414, 415, and 424
- 42 CFR Parts 414 and 484
MDMA Submits Comments on the 2007 Hospital Outpatient Prospective Payment System Proposed Rule
October 6th -- MDMA submitted comments to the Centers for Medicare and Medicaid Services (CMS) on the Outpatient Prospective Payment System (OPPS) proposed rule. In our comments we discussed the importance of the mandatory use of C-codes and the need to use correctly coded claims when determining the payment rates for device-dependent ambulatory payment classifications (APCs). In addition, we recommended that CMS implement a payment floor to moderate for decreases in median costs from 2006 to 2007 and to use external data to validate costs determined by CMS' claims data.
To read MDMA's comment letter, please click here.
MDMA Submits Comments on CMS's CED Guidance Document
October 6th -- MDMA submitted comments to the CMS on its Guidance for the Public, Industry and CMS Staff: National Coverage Determinations with Data Collection as a Condition of Coverage: Coverage with Evidence Development (CED). Although CMS has communicated that CED will only be used as an alternative vehicle for procedures to receive coverage which otherwise would be denied coverage, CED is still an avenue which the device industry has not fully embraced. MDMA strongly articulated to CMS that it must collect, aggregate and disclose research data collected through CED in a manner that minimizes the burden on patients, providers and manufacturers.
To read MDMA's comment letter please click here.
MDMA Submits Comments on CMS’s Reconsideration of its Clinical Trial Policy
August 8th -- MDMA believes that Medicare patients deserve early access to innovative medical technology as it can contribute to their enhanced quality of life. As such, MDMA made six key recommendations to CMS regarding refining criteria for the coverage of routine patient care costs of Medicare patients enrolled in clinical trials.
Click here to read MDMA’s comments.
CMS Releases Hospital Inpatient Final Rule
August 1st -- Today, the Centers for Medicare & Medicaid Services (CMS) issued the final rule that provides changes to Medicare's hospital inpatient payment system for fiscal year 2007. MDMA is still in the process of reviewing the rule, but generally we are pleased that no DRG's were reduced by more than 5.4% and that some payments were increased. This will help ensure that patients are not denied access to critical care. We look forward to working with CMS throughout the three year phase-in period to preserve beneficiary access and encourage a smooth transition.
Click here to read the IPPS Final Rule
To read CMS’s press release, please click here.
CMS Issues Revised Guidance on CED
July 12 -- CMS released the long awaited revised guidance document on Coverage with Evidence Development (CED). The revised guidance released today follows a draft document, which was posted for public comment on April 7, 2005. CMS received a large number of comments on the draft guidance and considered them in developing this revision. The revision clarifies particular applications of CED as well as the legal bases for incorporating CED into the larger NCD process. In particular, the revision identifies two sub-types of CED including (1) coverage conditioned on specific data collection to ensure patients are receiving care consistent with the parameters of the NCD (referred to as Coverage with Appropriateness Determination), and (2) coverage conditioned on patient participation in a clinical study (referred to as Coverage with Study Participation). MDMA remains concerned that additional data collection requirements may be an impediment to the diffusion of new medical technology and we will be submitting comments on this important issue.
To read CED II, please click here.
To read CMS’s press release, please click here.
Take Action on IPPS and ICD-10 Today
July 11 -- To truly affect change in Washington, industry must make its voice heard with lawmakers and regulators. MDMA has posted action alerts on two important topics affecting the device sector – the proposed IPPS rule and ICD-10. Letters already have been written and all you need to do is fill in your information to contact decision-makers. It’ll only take a moment. MDMA recently submitted comments on the IPPS proposed rule, which could dramatically change how Medicare reimburses hospitals for patient hospitalizations. The association also has been closely monitoring the issue of ICD-10 and proposed legislation on Capitol Hill. MDMA believes that the expanded ICD-10 code set will allow a more precise and an expedient recognition of procedures and technologies, helping to improve patient safety and more accurate payment for services in the future.
Please click here to weigh in on these important issues.
MDMA Submits Comments on DME Competitive Bidding
June 30th -- MDMA submitted comments on the Competitive Acquisition for Certain Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) proposed rule released by the Centers for Medicare and Medicaid Services (CMS). MDMA is concerned that the proposed program will introduce anti-competitive elements into the Medicare program – potentially shutting out innovative technologies produced by small manufacturers.
To read MDMA’s comments please click here.
MDMA Submits Comments on CMS Inpatient Prospective Payment System (IPPS) Proposed Rule
June 12th -- MDMA submitted comments on the Inpatient proposed rule. In April, CMS issued the IPPS proposed rule, which seeks to dramatically change how Medicare reimburses hospitals for patient hospitalizations. The changes largely stem from CMS’s attempt to refine the DRG system using hospital costs rather than the current system, which is based on hospital charges. Adopted as is, the changes will negatively impact surgical- and device-dependent Diagnosis Related Groups (DRGs) by significantly reducing their reimbursement rates. MDMA has recommended that CMS maintain a charge-based system and delay implementation of the proposed shift to cost-based weights and severity-adjusted DRGs that incorporate the complexity of care, particularly for device-dependent DRGs, until 2010. "MDMA is extremely concerned about the negative impact that prematurely implementing the IPPS changes would have on innovation and patient care. We look forward to working with CMS as it moves forward with the changes in a responsible and thoughtful manner,” said Mark Leahey, Executive Director of MDMA.
To read MDMA’s comments please click here.
CMS Issues Proposed Rule for DME Competitive Bidding
April 24, 2006 – The Centers for Medicare & Medicaid Services (CMS) released the proposed rule for competitive bidding for certain durable medical equipment, prosthetics, orthotics and supplies (DMEPOS). The new competitive acquisition program, required by the Medicare Modernization Act (MMA), is designed to replace the current DMEPOS fee schedule payment amounts for selected items in selected areas. According to the CMS press release "suppliers in a competitive bidding area would submit bids for selected items, and CMS would use these bids to establish Medicare payment amounts for these items. Under the proposed rule, the Medicare payment amounts would be the median of the winning suppliers’ bids for selected items. Suppliers whose bids are lower than the Medicare payment amounts set under the competitive bidding program could offer a rebate to beneficiaries, lowering their costs for acquiring the DME items they need." Comments on the proposed rule are due by June 23, 2006.
To read the proposed rule, please click here.
To read the CMS press release, please click here.
To read the CMS Backgrounder, please click here.
CMS Releases the Proposed Inpatient Prospective Payment System (IPPS) Rule
April 12, 2006 - CMS released the proposed Inpatient Prospective Payment System (IPPS) rule for FY 2007 with an estimated market basket increase of 3.4 percent. Included in the notice of proposed rulemaking, CMS announced its intent to begin the transition to the first significant revision of the IPPS since its implementation in 1983. CMS states that the revision should improve the accuracy of payment rates for inpatient stays by basing the weights assigned to DRGs on hospital costs rather than charges and adjusting the DRGs for patient severity. MDMA will be submitting comments by June 12th.
To read the proposed rule click here.
To read CMS’s press release click here.
CMS IPPS Fact Sheet
CMS Fact Sheet on DRG refinements
First Biannual Meeting of the Advisory Panel on Ambulatory Payment Classification (APC) Groups: March 1-3, 2006
The first biannual meeting of the APC Advisory Panel for 2006 will be March 1-3, 2006 at CMS headquarters in Baltimore, MD. The Panel will review the APC groups and associated weights to advise the Secretary of HHS and the CMS Administrator about the clinical integrity of the APC groups and their associated weights. The Panel's advice will be considered by CMS as it prepares updates to the hospital Outpatient Prospective Payment System through rulemaking. For those planning to present, the comment deadline is Wednesday, February 1, 2006 and the attendee registration deadline is Wednesday, February 8, 2006. Agenda items for the March meeting include:
- Reconfiguration of APCs
- Evaluation of APC weights
- Packaging devices and drug costs into APCs
- Removal of procedures from the inpatient list for payment under the OPPS
- Use of single and multiple procedure claims data
- Packaging of HCPCS codes
- Other technical issues concerning APC structure
For more information about the meeting please click here.
White House’s ’07 Budget Proposes Significant Medicare Cuts
On February 6th, President Bush released his $2.77 trillion dollar budget for fiscal year 2007. Included in the budget is an extension of the research and development tax credit and a pledge to double the federal government’s spending on basic science. A permanent extension of the tax credit would allow companies to continue to write off certain research expenses. However, despite those gains, the budget also proposes a $36 billion cut to Medicare over five years.
"MDMA supports the President’s call to make the R&D tax credit permanent. This is an issue on which MDMA has been actively involved for many years. Providing these incentives will ensure that the vibrant technological advances produced by the medical technology industry will continue," said Mark B. Leahey, Esq., Executive Director of MDMA. "We also will work to make certain that any cuts to Medicare will not adversely impact patient care or beneficiary access to appropriate therapies."