NAPH Submits Comments on Equal Access Proposed Rule - July 6, 2011

NAPH on July 5 submitted its comments on the equal access proposed rule to the federal Centers for Medicare & Medicaid Services (CMS). In its comments, NAPH urged CMS to compare payment rates to other payers and/or costs as part of the access analysis. NAPH recommended that CMS require an access review for every State Plan Amendment that would result in reduced provider rates and approve the review prior to implementation of any reductions. NAPH asked that CMS provide guidance in the final rule on appropriate measures for access and, if possible, include standardized measures that can be reported across all states. NAPH also urged CMS to provide an outlet for providers to directly share their concerns on access and any proposed rate changes. The full NAPH comment letter can be found online.

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