By Sheila M. Sferrella, CRA, FAHRA and Melody W. Mulaik, MSHS, CRA, FAHRA, RCC, CPC, CPC-H
AHRA is continuing its focus on participating in and shaping the healthcare industry in regulatory issues that impact our members. Every year, CMS issues Proposed Rules for all types of services (hospital outpatient, physician, inpatient, etc) with proposed regulatory changes for the coming year. The industry is allowed to submit comments on these changes to help guide implementation.
This year, the AHRA Regulatory Affairs Committee selected two key issues from the Hospital Outpatient Prospective Payment System (HOPPS) Proposed Rule to comment on to guide CMS’s understanding and perspective. On August 31, AHRA submitted our letter to CMS to address the NEMA Standard XR-29 and Low-Dose CT Lung Screening billing requirements.
In the past, AHRA has followed some of our colleague associations in their response letters. With the addition of Capitol Associates to our regulatory affairs team in July, we proactively engaged with several organizations (ACR, HFMA, and RBMA) to lead the request for a one year delay in the enforcement of XR-29. The Regulatory Affairs Committee felt that a one year delay is necessary to adequately address all of the operational issues in ensuring accurate reporting of a new modifier to identify exams performed on non-compliant XR-29 CT scanners. As part of this initiative, AHRA worked collaboratively with key industry partners to communicate and coordinate this response.
For Low-Dose CT Lung Cancer Screening, AHRA asked CMS for clarification on the requirement of the assessment by the ordering physician and payment to the imaging provider. We will also be submitting comments on the Medicare Physician Fee Schedule (MPFS) Proposed Rule in regards to Clinical Decision Support (CDS), and we will share that information with you, as well.
At this point, we wait for CMS’s response in the Final Rule due to be published around November 1, 2015.
The Regulatory Affairs Committee members are:
Chair: Sheila Sferrella, CRA, FAHRA
Luann Culbreth, CRA, FAHRA
Jim Miller, CRA
Melody Mulaik, CRA, FAHRA
Penny Olivi, CRA, FAHRA
Jacqui Rose, CRA, FAHRA
Carlos Vasquez, CRA, FAHRA
If you have any questions, please email or call. Thanks. Take care.
- Sheila and Melody
Sheila M. Sferrella, CRA, FAHRA is senior vice president, Regents Health Resources, Franklin, TN. She can be contacted at firstname.lastname@example.org.
Melody W. Mulaik is president and co-founder of Coding Strategies, Inc. She may be contacted at email@example.com.