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MDMA Files Comments to CMS on CY 2021 OPPS and PFS Proposed Rules

Tuesday, October 13, 2020  
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MDMA Files Comments to CMS on CY 2021 OPPS and PFS Proposed Rules
MDMA recently submitted our comment letters to the Centers for Medicare and Medicaid Services (CMS) on the Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System and the Physician Fee Schedule (PFS) proposed rules for calendar year (CY) 2021.
 
In our OPPS comment letter, we urged CMS to allow an extension of separate payment for devices with transitional pass-through status due to the Public Health Emergency, revise the process for determining and applying appropriate offset amounts for devices seeking and/or receiving transitional pass-through payment and ensure that the process for adding new procedures to ASC Covered Procedures List is transparent and deliberate. Additionally we encouraged CMS to delay implementation of the elimination of the Inpatient Only (IPO) procedures list until the agency has had the opportunity to consult with appropriate specialty societies and stakeholders, and better articulate its methodology for assigning previously IPO procedures to APCs in the outpatient hospital setting. Our complete comment letter and full list of recommendations is available here.
 
In our PFS comments letter, we pressed CMS to use its authority to avert or mitigate the budget neutrality adjustments to the Conversion Factor resulting from evaluation and management (E/M) coding changes, to reconsider the value of post-operative E/M visits for surgical codes with a global period and to make permanent certain flexibilities that have been implemented during the Public Health Emergency (PHE) for telehealth and remote physiologic monitoring. Our complete comment letter and full list of recommendations is available here.
 
MDMA remains at the forefront of fighting for fair coding coverage and payments for medtech innovators and we look forward to continuing to work with CMS, the Administration, Congress and all stakeholders to improve the reimbursement landscape so that patients throughout the United States get timely access to medical technology innovation.