IMPORTANT NOTICE MAY CHANGE YOUR ACCESS TO LYMPHEDEMA CARE

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IMPORTANT NOTICE MAY CHANGE YOUR ACCESS TO LYMPHEDEMA CARE

Postby patoco » Wed Aug 29, 2012 9:23 pm

WE HAVE ONLY UNTIL SEPT 4, 2012 TO RESPOND ON THIS - Pat

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IMPORTANT NOTICE WHICH MAY CHANGE YOUR ACCESS TO LYMPHEDEMA SERVICES IN 2014

Medicare Part B

CLAIMS-BASED DATA COLLECTION STRATEGY FOR THERAPY SERVICES PROPOSED

CMS issued proposed rule, CMS1590P, on July 6 that includes a proposal to
collect data on patient function related to physical and occupational therapy,
and speech language pathology services. Section 3005(g) of the Middle Class Tax
Relief and Jobs Creation Act (MCTRJCA) requires CMS to implement, beginning on
January 1, 2013, ". . . a claims based data collection strategy that is designed
to assist in reforming the Medicare payment system for outpatient therapy
services subject to the limitations of section 1833(g) of the Act.

Such strategy shall be designed to provide for the collection of data on patient
function during the course of therapy services in order to better understand
patient condition and outcomes."

The proposed appeared in the July 30, 2012 Federal Register. CMS will accept
comments on the proposed rule until September 04, 2012, and will respond to them
in a final rule with comment period to be issued by November 1, 2012.

The Problem:
1. New non-payable data collection codes for reporting functional limitations
for each claim;
2. Goal is new therapist reimbursement based on improvement of function and
complexity of services;
3. Proposed criteria for evaluating improvement of functional limitations are
all physical measuresâ€" There are no measures proposed that would measure
lymphedema severity or improvement of lymphatic function;

Action:

Write a letter to CMS pointing out the impact the new rule will have to you, as
a lymphedema patient, if there are no quality measures appropriate to describe
the severity/complexity of the “functional limitation” of lymphedema, and
therefore neither the severity/complexity of the functional limitation, nor the
progress attained by the therapist. This lack of means of describing and
evaluating the improvement achieved by lymphedema therapy could result in the
incorrect conclusion that the therapy is of no medical value and disapproved.

To be assured consideration, comments must be received at one of the addresses
provided below, no later than 5 p.m. on September 4, 2012.

ADDRESSES: In commenting, please refer to file code CMS–1590–P. Because of staff
and resource limitations, we cannot accept comments by facsimile (FAX)
transmission. You may submit comments in one of four ways (please choose only
one of the ways listed):

1. Electronically. You may submit electronic comments on this regulation to
http://www.regulations.gov. Follow the instructions for ``submitting a
comment.''

2. 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.

Please allow sufficient time for mailed comments to be received before the close
of the comment period.

3. 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.

4. By hand or courier. If you prefer, you may deliver (by hand or courier) your
written comments before the close of the comment period to either of the
following addresses:

a. For delivery in Washington, DC— Centers for Medicare & Medicaid Services,
Department of Health and Human Services, Room 445–G, Hubert H. Humphrey
Building, 200 Independence Avenue SW., Washington, DC 20201. (Because access to
the interior of the Hubert H. Humphrey Building is not readily available to
persons without Federal government identification, commenters are encouraged to
leave their comments in the CMS drop slots located in the main lobby of the
building. A stamp-in clock is available for persons wishing to retain a proof of
filing by stamping in and retaining an extra copy of the comments being filed.)

b. For delivery in Baltimore, MD— Centers for Medicare & Medicaid Services,
Department of Health and Human Services, 7500 Security Boulevard, Baltimore, MD
21244–1850. If you intend to deliver your comments to the Baltimore address,
please call telephone number (410) 786– 7195 in advance to schedule your arrival
with one of our staff members. Comments mailed to the addresses indicated as
appropriate for hand or courier delivery may be delayed and received after the
comment period.

Robert Weiss, M.S.
Lymphedema Patient Advocate
National Lymphedema Network
patoco
Site Admin
 
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