Hospital Association of Pennsylvania > Advocacy > Federal Advocacy > PFS Proposed Rule 2017 Comment Letter


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HAP Comment Letter to CMS on Physician Fee Schedule Proposed Rule 2017

September 6, 2016

Andy 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-1654-P. Medicare Program; Revisions to Payment Policies Under the Physician Fee Schedule and Other Revisions to Part B for CY 2017; Proposed Rule, July 15, 2016

Dear Mr. Slavitt:

On behalf of The Hospital and Healthsystem Association of Pennsylvania (HAP), which represents approximately 240 member institutions, we appreciate the opportunity to comment on the Centers for Medicare & Medicaid Services’ (CMS) Medicare Physician Fee Schedule proposed rule for calendar year (CY) 2017.

HAP supports many of the payment and policy proposals contained within the proposed rule and looks forward to working with CMS to continue to improve access to care and drive quality improvement.

Key areas included in the attached comments are:

  • Expansion of payment policies for telehealth services
  • New payment for primary care, care management, and behavioral health
  • Appropriate use criteria for advanced diagnostic imaging implementation
  • Changes to the quality programs

Thank you for your consideration of HAP’s comments regarding this proposed rule. If you have any questions, contact Kate Slatt, senior director, health care finance policy.


Jeffrey Bechtel
Senior Vice President, Health Economics and Policy


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