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MDMA Submits PFS and OPPS Comments

Tuesday, September 6, 2016  
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MDMA submitted comments today for the proposed revisions under the Medicare Physician Fee Schedule (PFS) for calendar year (CY) 2017, as well as the Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System for calendar year (CY) 2017.

Regarding the PFS proposed revisions, MDMA expressed concern regarding several key areas of interest to manufacturers of life-saving medical technologies. MDMA urged CMS to exercise caution while reviewing new codes proposed as potentially misvalued under the PFS and that Medicare reimbursement for each service adequately accounts for the equipment, supplies, and all other costs related to the service. You may view our comments in full here.

Additionally, MDMA called upon CMS to be judicious and consistent while applying methodologies for adjusting work relative value unites (RVUs) to account for significant changes in time. CMS should also establish a transparent public process for Medicare Administrative Contractors (MACs) to follow in order to develop fair and equitable payment for Category III Current Procedural Terminology (CPT