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Webinars ACA/SGR Repeal (Jan. 16) Medicare Incentive Programs in 2014 (w/ Scientific
Affairs, Feb. 5) Medicare Advantage (March 4)
Videos (From CAC-PIAC 2013) Medicare Policy Issues for DPMs - Henry Desmarais, MD, MPA Responding to Government Audits and Enforcement Actions -
Gina Simms, JD, and Howard Sollins, JD Working With Carrier Medical Directors and Novitas Update -
Mitchell Resnick, DO
Member Resources
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Available online
Member Resources
www.apma.org/aco www.apma.org/healthcarereform
www.apma.org/cacpiac www.apma.org/reimbursement
www.apma.org/dme www.apma.org/sunshineact
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Successfully working toward integration of HPC and HSC, with monthly calls established to guide APMA health policy leaders through the transition and to set strategic and achievable goals for the committee.
Coordinated multi-departmental and multi-stakeholder efforts
(including Legislative Advocacy, CPA, Scientific Affairs, Development, and CPME) utilizing regulatory, legislative, and litigious strategies to address CMS’ omission of the CPME from the reporting exemption for indirect payments made to speakers at continuing medical education (CME) programs referenced in the final rule. APMA met with CMS officials and held numerous meetings with Congressional legislative staff to build support and to gain insight into CMS’ actions. APMA has also proactively communicated with the state leaders to apprise them of our progress.
Key Accomplishments
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Actively involved in sustainable growth rate (SGR) repeal and Medicare physician payment reform advocacy efforts, writing comment letters to congressional committees and attending Q&A sessions to ensure that our Medicaid and Diabetic Therapeutic Shoes reform elements get included.
Established a network of DME Representatives to monitor
DME issues more closely through access to the Provider Outreach and Education (POE) Advisory Groups (PCOM) and Region D DAC. HPC has assigned two representatives to each DMAC jurisdiction and has requested that these representatives report back to APMA any issues that may arise so that HPC can help coordinate a response.
Key Accomplishments
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FTC Health Care Competition Comments (April 30, 2014) • APMA provided comments to FTC on professional regulations; innovations
in health care delivery; advancements in health care technology; measuring and assessing health care quality; and price transparency for health care services.
ROI Specialty Practitioner Payment Model Opportunities (April 10, 2014) • APMA provided comments to CMS on their request for information on
specialty practitioner payment model opportunities. APMA Comments on Medicare Advantage and Medicare Part D Proposed Rule (March 7, 2014) • APMA provided comments to CMS, US Department of Health and
Human Services, regarding its proposed rule published January 10, 2014, proposing changes to Medicare Advantage and Medicare Prescription Drug Program for contract year 2015.
Comment Letters
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Medicare Program Revisions to Payment Policies (Jan. 27, 2014) • APMA provided comments to CMS, US Department of Health and Human
Services, regarding the final rule published December 10, 2013 finalizing changes to the Medicare physician fee schedule (PFS) and other Medicare Part B policies for calendar year 2014.
Medicare and Medicaid Programs: Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payments Systems and Quality Reporting Programs; and Other Matters (Jan. 27, 2014) • APMA provided comments to CMS, US Department of Health and Human
Services, regarding the final rule published December 10, 2013, relating to Medicare's hospital outpatient prospective payment system (OPPS) and the ambulatory surgical center (ASC) payment system for calendar year 2014.
Medicare Advantage Organization Termination of Provider Contracts (Dec. 18, 2013) • APMA provided comments to the Centers for Medicare and Medicaid Services,
US Department of Health and Human Services, regarding the Medicare Advantage Organizations' (MAO) termination of provider contracts.
Comment Letters
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Senate Finance and House Ways and Means Committees' Discussion Draft Addressing SGR Repeal and Medicare Physician Payment Reform (Nov. 12, 2013) • APMA provided comments to the Senate Finance and House Ways
and Means committees regarding the committees' discussion draft addressing sustainable growth rate (SGR) repeal and Medicare physician payment reform.
Support for Sunshine Act Reporting Exemption for Medical Textbooks and Medical Journals (Oct. 28, 2013) • APMA signed a letter with other physician groups in support of a
Sunshine Act reporting exemption for textbooks and scientific peer reviewed medical journal reprints, supplements, and abstracts as these materials are educational materials that directly benefit patients or are intended for patient use.
Comment Letters
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Physician Payment Sunshine Act (Open Payments) The Physician Payment Sunshine Act (PPSA) requires drug and medical device companies to report
publicly payments and other gifts made to physicians, including podiatrists. It also requires companies to report information on ownership or investment interests held by physicians.
Of particular concernsis CMS’ omission of CPME from the reporting exemption for indirect payments made to speakers at CME programs set forth in the Sunshine Act final rule.
Under 42 CFR § 403.904(g)(1), indirect payments made to speakers at continuing medical education programs sponsored by accrediting and certifying entities are exempt from reporting requirements.
Due to collaboration with Chris Mahaffey, DPM (ACFAS) APMA was able to schedule a meeting with CMS staff. The BOT has provided tentative approval for legal action, provided that all other avenues have been exhausted and that APMA can partner with other stakeholders to share costs and resources.
www.apma.org/sunshineact Medicare Physician Payment Reform/SGR Repeal APMA’s Health Policy and Practice and Legislative Departments have been actively involved in
sustainable growth rate (SGR) repeal and Medicare physician payment reform advocacy efforts, writing comment letters to congressional committees and attending Q&A sessions.
In Progress
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DME Representation / MAC outreach With BOT approval at the November 2013 meeting, HPC through the
DME subcommittee is currently implementing a plan to monitor DME issues more closely through access to the Provider Outreach and Education (POE) Advisory Groups (PCOM) and Region D DAC.
HPC has assigned two representatives to each DMAC jurisdiction and has requested that these representatives report back to APMA any issues that may arise so that HPC can help coordinate a response.
Accountable Care Organizations (ACOs) APMA has created many ACO resources, including webinars and policy
briefs, to educate members, which are located at www.apma.org/aco. HPC encourages any interested members to join the ACO Liaison
Network. HPC has drafted a white paper on ACO involvement for members, as
well as identifying gaps where APMA should dedicate more resources toward member education and advocacy.
In Progress
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Health Care Reform Implementation HPC continues to monitor health care reform and how implementation will
impact podiatric physicians, including the exchange plans and advanced alternative payment models, such as ACOs. APMA activities related to health care reform implementation are available at www.apma.org/healthcarereform.
Diabetic Therapeutic Shoes and Inserts This issue continues to plague APMA’s membership. Recently, APMA’s
HELLPP Act solution has been incorporated into draft versions of the SGR reform proposed legislation. In 2013, HR 1761, the HELLPP Act was introduced in the 113th Congress by US Rep. Lee Terry (R-NE).
Unlike previous DPM access legislation that has focused solely on rectifying the exclusion of podiatrists from Medicaid, the HELLPP Act includes multiple comprehensive reforms and goes further to ensure podiatric physicians will continue to save lives, limbs, and health-care dollars. HPC helped create a provision that would clarify the role of a prescribing podiatric physician in terms of establishing medical necessity, and consequently ease the reporting burden on all physicians involved in the TSD program.
Unresolved
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TRICARE APMA continues to await the final rule due on DPM’s ability to
prescribe and dispense DME. On August 8, 2013, the Department of Defense (DoD) released a new proposed rule that will allow all DPMs to prescribe and dispense durable medical equipment (DME) to TRICARE patients.
Routine Footcare: CMS Medicare Benefit Policy and Claims Processing Manuals This issue continues to be a lesser priority issue for CMS, which
explains why it continues to be pushed further back by likely reprioritization of issues by CMS.
APMA most recently met with CMS in Baltimore im 2103 to address this issue. At that point, APMA officials met with Kathy Bryant, Director of the Division of Practitioner Services; Edith Hambrick, MD, and Regina Walker-Wrenn among others.
Unresolved
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