Aug 192011

You have until August 30, 2011, to comment on a proposed change to CMS rules that will affect care transitions. The Center for Medicare and Medicaid Services recently issued proposed changes to the Medicare Physician Fee Schedule (“physicians” here includes all practitioners paid by Medicare – MDs, NPs, SWs, etc.). The proposed rule provides a unique opportunity to encourage CMS to work toward coordinated care for Medicare beneficiaries. CMS is seeking comments on whether physician activities should seek to ensure effective care coordination surrounding a hospital discharge, including whether hospital discharge care coordination services are appropriately valued. Getting comments to encourage CMS to undertake regulatory and developmental work on continuity and standards would greatly help very sick people who must move around in the health care system.

The important thing is to encourage CMS to get into this field and work on continuity and care planning, at least for high-risk beneficiaries. Please write your own comment or be in touch if you want to recycle and modify the comment developed by the Center for Elder Care and Advanced Illness at the Altarum Institute ( The Center will post additional comments on the proposed rule next week on their blog at ( You may download the Center’s comments as a PDF file:

Comments are due by August 30, 2011.

To make it easier for you to find the text of the proposed rule change we have extracted it from the larger document of which it is a part and put it into the following PDF file that you can download directly:

You may make comments via the Federal eRulemaking Portal at (refer to file code CMS-1524-P). The public access point for the proposed rule is at:!documentDetail;D=CMS-2011-0131-0002

Section K, “Hospital Discharge Care Coordination”, begins on page 510.

You may also send comments by surface mail to CMS, Department of Health and Human Services, Attention: CMS-1524-P, P.O. Box 8013, Baltimore, MD 21244-8013. CMS will respond to all comments in a final rule scheduled to be issued by Nov. 1, 2011.

Keywords: Medicare rule, Medicare Physician Fee Schedule, CMS-1524-P

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  One Response to “Comments needed on proposed rule: Encourage CMS to value continuity and smooth care transitions”

  1. I am opposed to the Center for Medicare and Medicaid Services porposals to apply the multiple procedure payment reduction (MPPR) to the professional component of advanced diagnostic imaging services.

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