Aug 272012
 

Each year, Medicare releases a schedule of physician payment rules, which set the amounts doctors are paid for Medicare beneficiaries. The public is always invited to comment on those rules. This year, for the first time, Medicare is considering allowing physicians to bill for services rendered in the course of managing hospital discharge. For those new to this world, now is an opportunity to comment on those rules—and to let the Centers for Medicare and Medicaid hear your voice. Comments can be positive or negative—but every comment counts. Don’t be intimidated or put off by the bureaucracy of the effort. Medicaring is here to help you through!

The rule can be found in Section H of the “Medicare Program; Revisions to Payment Policies Under the Physician Fee Schedule, DME Face to Face Encounters, Elimination of the Requirement for Termination of Non-Random Prepayment Complex Medical Review and Other Revisions to Part B for CY2013 [CMS-1590-P]”. It proposes to pay doctors to coordinate care for beneficiaries following a discharge from a hospital or nursing facility.

This would be the first time Medicare would explicitly pay physicians for the care required to help a beneficiary transition back to the community following a discharge from a hospital or nursing facility.

This “postdischarge transitional care management” code would be added to the fee schedule.  The service would include telephone or electronic communication with a beneficiary within two business days of discharge, medical decision-making of moderate or high-complexity, and face-to-face visit with the beneficiary 30 days prior to the transition of care or 14 business days following the transition.

The rule compares the new service to hospital discharge and high-level evaluation and management care that is currently covered.  The fee for the new services would be approximately $95 using current rates for 2013.

MediCaring suggests that folks comment on a few key provisions of the rule, especially on:

  1. 1.     The post-discharge transitional care management section,  for which: CMS seeks comment about the best ways to ensure that all the activities of the discharge day management codes for hospital and nursing facility discharge, including the care coordination activities, are understood and furnished by the physicians or qualified nonphysician practitioners who bill these services, noting that potential ways could include physician education or MEDLEARN articles.

 

  1. 2.     Whether and how the visit needs to be face-to-face, for which: CMS seeks comment about whether it should require a face-to-face visit when billing for the post-discharge transitional care management services, and how it might incorporate such a required visit into the payment for the proposed G-code.

 

CMS must receive comments on for before September 4, 2012. Full text of the Regulation, along with information on how to comment, can be found at: http://www.gpo.gov/fdsys/search/pagedetails.action?granuleId=2012-16814&packageId=FR-2012-07-30&acCode=FR Here’s how and where to submit comments:

Comments must be received by CMS on for before September 4, 2012. In commenting refer to file code CMS-1590-P. Comments may be submitted to CMS in the following ways:

  • · Electronically. You may submit electronic comments on this regulation to http://www.regulations.gov. Follow the instructions for “submitting a comment.”
  • · By regular mail. You may mail written comments to the following address ONLY:

Centers for Medicare & Medicaid Services

Department of Health and Human Services

Attention: CMS-1590-P

P.O. Box 8013

Baltimore, MD 21244-8013

  • · By express or overnight mail. You may send written comments to the following address ONLY:

Centers for Medicare & Medicaid Services

Department of Health and Human Services

Attention: CMS-1590-P

Mail Stop C4-26-05

7500 Security Boulevard,

Baltimore, MD 21244-1850

 

If you’d like a hand preparing your comment for submission, feel free to contact us at [email protected].

 

 

 

Key words: care transitions, CMS, Centers for Medicare and Medicaid, Physician Payment Rules, comment period

 

 

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