Hospital Association of Pennsylvania > Advocacy > Federal Advocacy > HAP Comment Letter to CMS on 2016 Physician Fee Schedule Proposed Rule


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HAP Comment Letter to CMS on 2016 Physician Fee Schedule and Other Revisions for Part B Proposed Rule

September 8, 2015

Andrew Slavitt
Acting Administrator
Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
Hubert H. Humphrey Building
200 Independence Avenue, S.W., Room 445-G
Washington, DC 20201

SUBJECT: CMS-1631-P. Medicare Program; Revisions to Payment Policies Under the Physician Fee Schedule and Other Revisions to Part B for CY 2016; Proposed Rule, July 8, 2015

Dear Acting Administrator Slavitt:

On behalf of The Hospital & Healthsystem Association of Pennsylvania (HAP), which represents approximately 240 member institutions, we appreciate the opportunity to comment about the Centers for Medicare & Medicaid Services’ (CMS) Medicare Physician Fee Schedule proposed rule for calendar year (CY) 2016.

HAP commends this proposal for its action related to advance care planning, the expansion of payment for telehealth services for select services, and the two Stark exclusions.

Key areas of concern include:

  • The expansion of the Clinician and Group-Consumer Assessment and Healthcare Providers and Systems (CAHPS) survey
  • The application of appropriate use criteria for select imaging services
  • The application of the value modifier to participants in the Medicare Shared Savings Program

Thank you for your consideration of HAP’s comments regarding this proposed rule. If you have anyquestions, contact Laura Stevens Kent, vice president, federal advocacy, at (202) 863-9287, or Kate Slatt, senior director, health care finance policy, at (717) 561-5317.


Jeffrey W. Bechtel
Senior Vice President, Health Economics and Policy

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