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May 17, 2016
AMA, CAP Advocate for Changes to New Medicare Enrollment Rules
The Centers for Medicare & Medicaid Services (CMS) should take steps to reduce regulatory burdens under a proposed program integrity rule, the CAP, AMA, and several other physician associations said in a letter to the agency.
The Affordable Care Act of 2010 included additional safeguards for the Medicare program. The intent of those safeguards that are the subject of the proposed program integrity rule is to keep out or remove individuals and entities who pose risk to the Medicare program and patients. The proposed rule requires reenrolling physicians to document any current or previous affiliation with a provider or supplier who has had certain disclosable events, such as uncollected debt, payment suspension under a federal health care program, Medicare or Medicaid exclusion, or billing revocation.
While the organizations support CMS efforts to protect its trust funds against improper payments, physicians are concerned that certain provisions in the proposed Program Integrity Enhancements to Provider Enrollment Process rule would significantly increase regulatory burden without efficiently targeting enforcement toward higher-risk enrollees. Physicians also are concerned about using Medicare's audit contractors to implement tougher enrollment requirements. The proposed rule would allow the CMS to remove or prevent the enrollment of physicians and health professionals that attempt to circumvent Medicare requirements.
The rule also seeks to address cases where providers and suppliers avoid repaying debts by reenrolling in Medicare as a different entity. For instance, the CMS proposed a "look-back" period of five years to report disclosable events, but an event triggering the disclosure is not subject to limitation.
The physician organizations recommended that the CMS:
- Establish a finite look-back period for disclosable events
- Reconsider mandating the reporting of disclosable events when appeals are pending or when other parties have yet to agree to a repayment plan for uncollected debt
- Set a reasonableness standard based on good faith instead of a standard based on when a provider "knew or should reasonably have known" about a disclosable event
- Avoid incentivizing audit contractors to engage in 'bounty-hunter" behaviors
"We appreciate and support CMS' efforts to prevent its programs from assuming undue risks of fraud, waste, and abuse, while simultaneously urging the CMS to adopt a more targeted approach that minimizes regulatory burden and focuses its enforcement efforts on the sources of greatest risk," the letter said. "Our organizations look forward to working further with the CMS to ensure that program integrity vulnerabilities are adequately addressed, physicians are treated equitably, and patients are afforded access to the highest quality health care."
Pathologists to Lead Blood Drive at AMA House of Delegates Meeting
At the upcoming American Medical Association (AMA) meeting, the Pathology Section Council in the AMA House of Delegates will raise awareness about the pathologist role in managing the nation's blood supply in addition to the importance of blood donation.
Pathologists oversee the collection, testing and administration of blood components. Blood donation is an important part of this process. Due to challenges of supplying blood with the new Zika virus donor deferrals, the Pathology Section Council organized a blood drive at the AMA Annual Meeting to highlight Pathologist role in blood donation. The Pathology Section Council has joined with Chicago's local blood center, Lifesource, who will be conducting the drive. The blood drive will be on June 10 from 12-6 PM at the Hyatt Hotel in the exhibit hall near the AMA Headquarters.
There is concern regarding the effect of a Zika virus outbreak on the nation's blood supply. In February, the Food and Drug Administration (FDA) issued recommendations for donor screening, deferral, and product management to reduce the risk of transfusion or transmission of Zika virus. Recommendations include a four-week deferral for donors at risk of Zika virus infection. Four weeks provides a margin of safety in excess of the known incubation period of three to 12 days, plus 14 days of viremia post symptom onset, according to the FDA.
"This blood drive helps to highlight the pathologist role in overseeing the safety of our nation's blood supply and shows the dedication of all physicians who are willing to give their blood to help take care of patients" Jean E. Forsberg, MD, FCAP, Member , Pathology Section Council.
Members of the Pathology Section Council are the American Society for Clinical Pathology, American Society of Cytopathology, College of American Pathologists, National Association of Medical Examiners, and United States and Canadian Academy of Pathology.
The CAP will provide additional coverage of its advocacy at AMA meetings in future issue of STATLINE.
CAP Webinar: Medicare's 60-Day Repayment Rule
Is your pathology practice prepared for the new Medicare repayment rule? Register for the CAP's webinar to understand the demand placed on your practice and develop a system to identify overpayments is your responsibility.
Presenters Jared Abbott, MD, PhD, FCAP and Moira P. Larsen, MD, MBA, FCAP will lead the discussion to focus on major provisions of the final Medicare repayment rule and include clarifications of overpayment identification, the required “look back” period for overpayment identification, and the methods available for reporting and returning identified overpayments.
The webinar will be May 24 at 1PM CT. Learn about these and the many other factors that may impact your practice. Registration for this complimentary webinar is open to CAP members.