AHA Submits Comments on 2012 Physician Fee Schedule, OPPS

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The American Hospital Association has submitted comments, requesting changes to CMS' proposed 2012 physician fee schedule as well as its proposed rule for the 2012 hospital outpatient prospective payment system.

As part of its comments to CMS on the proposed physician fee schedule, the AHA urged CMS to work with Congress to fix the sustainable growth rate formula before a scheduled Jan. 1, 2012, payment cut of 29.5 percent. The AHA also asked the agency to withdraw a proposed rule that would reduce the professional component of payments for multiple-procedure advanced imaging services, saying CMS does not provide data to support the change, according to an AHA News Now report.

Additionally, the AHA rejected the agency's definition of a group practice under the Physician Quality Reporting System as a practice with 25 or more physicians. Previously, groups as small as two physicians could be considered group practices and therefore submit data through the group reporting option, which the AHA calls "the most user-friendly method of data submission." The AHA also urged CMS to use only those measures endorsed by the National Quality Forum for the Physician Feedback and Value-Based Purchasing programs. CMS had proposed to use two quality measures as well as efficiency measures not yet endorsed by the NQF.

In a separate letter to CMS, the AHA commented on the 2012 proposed rule for hospital outpatient prospective payment systems, ambulatory surgical centers and physician self referral. The AHA expressed concerns on a variety of issues, including CMS' default requirement of direct supervision of therapeutic services and its proposed electronic quality reporting pilot, among other issues, according to a separate AHA News Now report.

The AHA said it plans to submit separate comments on the hospital value-based purchasing portion of the OPPS proposed rule.

View the 2012 Proposed Rules:

CMS Issues Physician Fee Schedule Proposed Rule
CMS Issues CY 2012 Outpatient Prospective Payment System Proposed Rule

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