The Committee on Ways & Means has requested per Pete Stark’s announcement that the Subcommittee is requesting written comments for the record on Medicare’s payment policy for outpatient therapy services and research needed to inform development of refined and alternative payment methodologies.

This was announced June 26th and the short turnaround time to submit is July 10th. They request electronic submission using Word or Wordperfect (who still uses wordperfect?  Wonder if they would take a wang processor submission?) and it cannot exceed 10 pages (perhaps a missprint-10 words would work for me).

You submit (this is my absolutely favorite part and I have not in any way altered this including the all caps) by going to http://waysandmeans.house.gov, select “110th Congress” from the menu entitled “committee Hearings” (http://waysandmeans.house.gov/Hearings.asp?congress=18).  Select the hearing for which you would like to submit, and click on the link entitled, “click here to provide a submission for the record”.  Once you have followed the online instructions, completing all informational forms and clicking “submit” on the final page, an email will be sent to the address which you supply confirming your interest in providing a submission for the record.  You MUST REPLY to the email and ATTACH your submission as a Word or WordPerfect document, in compliance due to the change in House mail policy, the U.S. Capitol Police will refuse sealed-package deliveries to all House Office Buildings.  For questions, or if you encounter technical problems, please call (202) 225–1721.

What are the odds of having technical difficulties, calling, and being dumped in voice mail?

Here are some random recommendations:

1.  End the cap and its exception process-it is useless and everyone and their 2nd cousin knows how to work around it thru the exception process (especially our SNF brethren who can simply tack an altzheimer’s diagnoses on the other 5 dx for those patients).  Therefore the cap does nothing but increase cost to CMS and decrease reimbursement (thru our increased cost of working around this junk) to us.

2.  Cap by dx related groups.

3.  Separate cap for outpatient settings versus SNF.

4. Put the hospitals in the same boat as the rest of us and end this discrimination and advantage.

One final note. CMS estimates that 12% of medicare beneficiaries utilize PT (at the tune of 3.8 billion in 2004–forget the fact that the stat is a few years old).  I suggest that they increase this number on musculoskeletal dx patients (both in percent and dollars) and utilize PT as a front line screener for all of them-especially LBP.  It will significantly decrease cost of imaging and surgery on the medicare expenditures.

Ok, forget that last suggestion which is currently being utilized by some employer coalitions. It makes too much sense.

Almost as much sense as a “for comments on therapy cap click here and submit by July 10th” would be on their website.

Thoughts?

Larry