Health Care Reform is an Ongoing Process
Day on the Hill – March 3 & 4‚ 2010
Thank you to those of you who participated in yet another successful Day on the Hill.
DOTH 2010 – TALKING POINTS
Critical Access Hospitals (CAHs) and the potential loss of patient access to CR and PR programs in those facilities due to CMS rules pertaining to physician availability
- Current Medicare policy defines CAHs as hospitals smaller than 25 beds; CAHs are not required to have a physician immediately available and staffing is generally provided by non physician practitioners (NPPs) such as physician assistants and nurse practitioners.
- CMS has determined through the rulemaking process that CAHs that do not have a physician immediately available cannot provide either cardiac or pulmonary rehab through their outpatient departments.
- The impact of this decision limits beneficiary access to both cardiac and pulmonary rehabilitation, contrary to Congressional intent.
Non Physician Practitioners are not permitted to function as physician extenders for cardiac or pulmonary rehab while they are authorized to do so for other hospital outpatient services!
- Current Medicare policy permits NPPs to function as physician extenders in the hospital outpatient (and other) settings. CMS has made a very narrow, strict interpretation of the new statute, claiming that physician supervision requirements must be met by physicians, not NPPs.
- As physician supervision is a non billable service, permitting NPPs to work in this capacity has no financial impact on the Medicare program.
Inadequate Medicare reimbursement amount for cardiac rehab based on CMS research
- A CMS commissioned study in July 2008 by RTI concluded that reimbursement calculations for CR services were flawed and significantly lower than actual costs to provide the service.
- CMS has made corrective coding changes to collect more accurate data.
- AACVPR and fellow professional societies will be tracking this to make sure CMS reviews the data in a timely manner and makes any consequent appropriate payment corrections.
2010 - Year of the Lung Proclamation to be supported by Congress
- House Resolution 1122 introduced by John Lewis (D-GA)
- Identical Senate Resolution to follow very soon with introduction by Senators Crapo and Lincoln
Medicare Advantage exorbitant co-payments for CR/PR services are a barrier to utilization
- Medicare beneficiaries selecting a Medicare Advantage managed plan are often unaware of what questions to ask and how high co-payments for certain services will be.
- CR/PR is an example of co-payment amounts double what Medicare fee-for-service even reimburses for these services ($25-50 co-payment for service that reimburses $25).
- While 36-session course is covered by Med Adv plan, co-payment is deterrent to utilization.
- Study done at Brown University (funded by Pfizer and federal government) recently published in NEJM found this causes patients to defer beneficial treatments.
- 900,000 seniors in 36 Medicare managed-care plans from 2001-2006
Ave co-pay for MD doubled in these plans
- Conclusion: raising copays to contain costs is counterproductive
- Study supports previous similar findings
- Outpatient care for Medicare patients with chronic diseases is valuable and shouldn't be discouraged by having large copayments
DOTH Resources