Health Information Management

Take the time to comment on 2016 OPPS proposed rule

APCs Insider, July 31, 2015

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By Steven Andrews
If healthcare workers lack one thing right now, it’s probably free time. Dealing with normal workloads, staff vacations, various ongoing initiatives, and, oh yeah, ICD-10 implementation is likely keeping everyone busy.
But I strongly recommend you add commenting on the 2016 OPPS proposed rule to that list, if only for the amount of time, operational burden, and money it could save you and your facility in the future.
For example, CMS is proposing a new HCPCS modifier that providers would report with every code that’s adjunctive to a comprehensive (J1) service but billed on a different claim. This policy raises some questions for providers, such as what does CMS consider adjunctive and how can the process be operationalized?
If you think this could cause you problems, or have suggestions on how CMS could implement it in a way that’s easier for facilities to report, then submit a comment.
CMS takes these comments seriously and has nixed or delayed proposed changes because of comments. For example, provider comments in response to the 2014 OPPS proposed rule convinced CMS not to collapse Type A and B ED E/M levels to once level for each and to delay comprehensive APC implementation until further study.
Comments don’t have to be lengthy and can be easily submitted here. Look for a link called Comment Now 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.
If you're planning on submitting comments electronically, Jugna Shah, MPH, president and founder of Nimitt Consulting, based in Washington, D.C., and Spicer, Minnesota, recommends 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.
Alternatively, you can submit your comments in hard copy. CMS provides addresses in the proposed rule for regular mail submissions and express or overnight mail submissions. You can also hand deliver comments to CMS' offices in Washington, D.C., or Baltimore.
For more on CMS’ proposed changes, visit Shah and Valerie A. Rinkle, MPA, will analyze the 2016 OPPS proposed rule and give a comprehensive overview of the changes and what providers may want to comment on in HCPro’s annual OPPS proposed rule webcast from 1-2:30 p.m. (Eastern) Tuesday, August 18. Look for more in-depth coverage of the 2016 OPPS proposed rule in the September 2016 issue of Briefings on APCs, scheduled to publish August 13.

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