Health Information Management

Take advantage of CMS’ requests for OPPS proposed rule comments

APCs Insider, July 25, 2014

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By Steven Andrews, Editor
 
The government often passes major laws without giving the public time to respond, or offering any feedback for its decisions (see the latest ICD-10 delay for a recent example). But that's not the case with the annual OPPS proposed rules.
 
In fact, CMS often asks for provider input on a variety of topics and will respond to many of the comments in the final rule. This year's proposed rule includes several proposals that would have major financial and administrative implications for providers if finalized, including:
  • Comprehensive APCs with complexity adjustments
  • Expanded packaging
  • Data collection using a new modifier for off-campus provider based locations
  • Changes to physician certification under the IPPS
Individual hospitals often rely on their advocacy and membership organizations to help steer the direction of their comments to CMS, but in the end each provider’s voice matters. Commenting doesn’t necessarily have to be time-or labor-intensive, according to Jugna Shah, MPH, president and founder of Nimitt Consulting.
 
Comments may be brief and to the point. They can be positive and express support for proposed changes. Alternatively, your comments may express opposition to some of CMS' proposals. These comments should be clear, and as data-driven as possible, whether that is hard data in the form of numbers or more qualitative information that helps explain your perspective to CMS. 
 
You may submit comments electronically, via first-class or express mail, or in person.
If you’re planning on submitting comments electronically, consider the following:
  • Type out your comments beforehand in a word processing program, then copy and paste as appropriate. This will make commenting easier and faster, and it can help ensure that you haven't omitted anything important.
  • Ask someone to read your comments. This individual can catch typographical errors and missing words, and might even suggest adding information that you forgot to include.
  • Forward your comments to your compliance department for its review before submitting them to CMS.
  • Organize staff to discuss your organization's topics of interest. Ensure that all group members have an opportunity to review the comments before you post them.
 After you have everything typed out, uploading it is the easiest part.
 
On the OPPS proposed rule's page on regulation.gov, look for a link called Submit Comment above the name of the document. Click on this link, input the requested information, and click Submit. This completes the process and provides a tracking number for comments.
 
Alternatively, you can submit your comments in hard copy. CMS provides addresses in the proposed rule for paper submissions. Comments are due by September 2, no matter the method of submission.
 
Shah will join Valerie A. Rinkle, MPA, for HCPro's annual OPPS proposed rule webcast August 13, reviewing all of the major proposals and the potential impact to providers.



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