My Comment on CMS Proposed Rule Change

Today is the last day to comment on the Center for Medicare and Medicaid Services (CMS) proposed rule change described in an earlier blog post and given below:

Medicare Program: Cancellation of Advancing Care Coordination through Episode Payment and Cardiac Rehabilitation Incentive Payment Models; Changes to Comprehensive Care for Joint Replacement Payment Model (CMS-5524-P)   

Earlier this morning I added my comment on the government’s website in opposition to the cancellation or severe cutting back of several bundled payments programs.  This is the first time I have ever officially provided a comment on any proposed federal government regulation and must admit that I was a bit intimidated by the organization I was going up against.  Most of the comments already in the system were from healthcare industry insiders.

Will My Comment Count?

I found myself wondered whether anyone would even read my comment or simply toss it aside because it was from someone unimportant and uninfluential.  Is the proposed rule change already a done deal and the result of the new political agenda on health care? Is the comment phase simply a requirement set by law and no matter how persuasive the argument, nothing will change the proposed rule change?   It is very easy to convince oneself that these conditions exist and one voice does not matter, so why make the effort.

Last night while I was watching the 60 Minutes and was appalled and moved to action by the  DEA whistleblower exposé.  In addition, the story about Shon Hopwood’s journey from convicted bank robber to Georgetown law professor, inspired me with thoughts that maybe one voice can make a difference in Washington.  I may be a very weak David fighting a bureaucratic Goliath, but if everyone stood by waiting for someone else to act, then it would never get done.

trying to comment and up against Goliath CMS bureaucracyIn my comment on the CMS proposed rule change, I forwarded several recommendations that are outlined below:

  • It is time to stop asking healthcare businesses’ permission to make the switch from fee-for service to value-based reimbursement models.
  • Immediately take the CJR model  for mandatory reimbursement nationwide with a one year phase-in before fee-for-service medical codes for hip/knee replacement cease to exist.
  • Advancing Care Coordination Through Episode Payment and Cardiac Rehabilitation Incentive Payment Models should continue with mandatory application across the country to follow in a timely fashion.
  • Our government needs to take action to increase the number of orthopedic surgeons (and other medical doctors in short supply) in the United States in the United States so that rural (and vulnerable) hospitals will have a ready supply that can be hired under a competitive salary environment.

My full text comment is available in the pdf file link given at the end of this blog post.  Remember you too can add your comment for the record.  You have until 11:59 p.m. tonight to be heard.

BB’s CMS-5524-P Comment

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