Last Chance to Submit Comments on the 2017 OPPS Proposed Rule
CMS wants your thoughts on its 2017 OPPS proposed changes. In various places in the proposed rule, CMS specifically asks providers to comment on the proposals. You may submit comments to the agency until September 6.
"It's important for providers to weigh in on the proposed changes, especially ones that might create administrative or operational burden," says Jugna Shah, MPH, president and founder of Nimitt Consulting. The task of commenting doesn't necessarily have to be time- or labor-intensive, says Shah. What’s critical is the message behind the issue and the rationale supporting why a proposed change isn’t feasible – the more providers are able to help CMS understand the situation, the better chance they’ll reconsider it.
Telling CMS what your organization thinks in its own words is important, so Shah suggests starting with what you are hearing from others and then sitting down with staff and picking a few topics to focus on. Zeroing in on topics that are likely to cause operational impact without any added benefit or improvement for providers is a great place to start, because CMS needs to hear from providers about operational issues, says Shah. You can also highlight areas of financial impact that are of concern, such as in cases where CMS proposes to reconfigure or consolidate existing APCs.
Comments may be brief and to the point. They can express opposition to some of CMS' proposals. Alternatively, your comments may express support for certain proposed changes.
What’s key is making data-driven arguments and providing CMS with clear examples of provider-related issues.
Tips for preparing your electronic submission
If you're planning on submitting comments electronically, consider the following:
Type out your comments beforehand in a word processing program, then copy and paste as appropriate. This will make commenting easier and faster, and it can help ensure that you haven't omitted anything important.
Forward your comments to your compliance and/or legal department for its review before submitting them to CMS.
After you have everything typed out, uploading it is the easiest part. Visit www.regulations.gov and enter "2017 OPPS" in the search field. Select the appropriate link from the list of search results.
Look for a link called Submit Comment above the name of the document. Click on this link, input the requested information, and click Submit. This completes the process and provides a tracking number for comments.
Paper submissions
Alternatively, you can submit your comments in hard copy. CMS provides addresses in the proposed rule for regular mail submissions and express or overnight mail submissions.
Comments may be hand-delivered to CMS' offices in Washington, D.C., or Baltimore, Maryland. Because access to the interior of the Hubert H. Humphrey building in Washington is not readily available to people without federal government identification, CMS advises leaving comments in the CMS drop slots located in the main lobby of the building.
Commenters who plan to deliver their remarks to the Baltimore office should call in advance to schedule their arrival with a CMS staff member.