NAPH Submits Comments on OPPS Proposed Rule - Sept. 5, 2012

NAPH submitted comments Sept. 4 to the Centers for Medicare & Medicaid Services (CMS) on the calendar year (CY) 2013 outpatient prospective payment system (OPPS) proposed rule. The proposed rule includes provisions on observational services payment policy, the outpatient quality reporting (OQR) program, the Medicare electronic health record (EHR) incentive program reporting pilot, separately payable drugs and biological and supervision policy for physical therapy, speech-language pathology, and occupational therapy. In its comments, NAPH recommended that CMS eliminate inappropriate measures from the OQR program and expressed support for CMS’ new statutory default for separately payable drugs and biologicals. NAPH also urged CMS to consider the unique nature of providing care in the safety net setting before it proposes any new observational services payment policies in the future.