DHPA provided a comment letter to the Centers for Medicare and Medicaid Services (CMS) on the Medicare Physician Fee Schedule (MPFS) Proposed Rule for Calendar Year 2023, that focused on five issues impacting Medicare beneficiaries’ access to high quality, affordable care for gastrointestinal conditions and diseases.
- DHPA asked that CMS finalize its proposals to expand Medicare coverage of CRC screening tests, while making clear in the Final Rule that colonoscopy is a critical first-line screening test, particularly in Medicare-age patients.
- DHPA urged CMS to compel Medicare Administrative Contractors to discontinue the inappropriate use of Local Coverage Articles (LCAs) to down-code certain complex biologic drugs, including drugs used to treat patients with serious gastrointestinal diseases such as Crohn’s disease or ulcerative colitis, and to insure that any such LCAs currently in effect are invalidated.
- DHPA asked CMS to make permanent CMS’s definition of “substantive portion” for split (shared) visits in the facility setting that is in effect for CY 2022 or, at the very least, redefine “substantive portion” to include either more than 50 percent of the medical decision-making by the physician or nonphysician practitioner (NPP) or more than 50 percent of the time spent by the physician or NPP.
- Starting with the year following the end of the COVID-19 Public Health Emergency (PHE), DHPA asked that CMS make permanent the flexibility to meet the “immediate availability” requirement for direct supervision through virtual presence using real-time, audio/video technology.
- DHPA requested that CMS support Congressional efforts to provide the physician community with relief from the impending payment cuts set to take effect on January 1, 2023.
Click here to read the full letter >>