Public Comment: 1k2-9159-fleh

1/31/2018

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PUBLIC SUBMISSION

As of: 1/31/18 1:20 PM
Received: January 26, 2018
Status: Draft
Tracking No. 1k2-9159-fleh
Comments Due: January 29, 2018
Submission Type: Web

Docket: CMS-2017-0167
PRA Notices (Misc. 2016-2017)
Comment On: CMS-2017-0167-0030
Agency Information Collection Activities; Proposals, Submissions, and Approvals
Document: CMS-2017-0167-DRAFT-0084
MI

Submitter Information
Name: Anonymous Anonymous
Address:
Lansing, MI, 48909

General Comment
Document Identifier: CMS-10661
I respectfully request that the HCPCS used beginning 2019 be the same HCPCS codes CMS released for
States to run through the aggregate tool. The tool is helpful to States; however, not providing a definitive
list places States at a disadvantage . Upon reviewing the preliminary list I found various codes that the
State's policy and pricing methodology is completely different than Medicare. For negative pressure
wound pumps, my State uses a daily rate (Medicare uses a monthly rate) with a max daily unit count
typically up to 14 days. The preparation for implementation is more than submitting tribal notices, public
notices and State Plan Amendments; States need to review State laws, approach State Legislatures in the
event rates decline necessitating increased State funds for services, provider education, policy
promulgation, potential MMIS changes, etc. If the list of codes will not be the same I ask that CMS
consider delaying the reporting requirements to the 2nd or 3rd quarter of 2019 and perhaps only using the
3rd and 4th quarter 2018 aggregate reports. Guidance on this regulation was not provided to the States in
a timely fashion, one month prior to the effective date of 1/1/2018. While the guidance is appreciated it
does not give States time to research, analyze potential outcomes, current State laws and impact on
providers as well as beneficiaries. There is potential for States to lose providers due to rate changes and
provider associations have indicated many businesses have already closed in the State due to the
Medicare Competitive Bid.

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