The Alliance today submitted comments to CMS on the proposed changes to the Medicare PPS rates for 2013 and the proposed new alternative sanctions in the survey enforcement process. Specific issues that the Alliance addressed include the case mix creep adjustment, wage index concerns, proposed changes to the face-to-face and therapy reassessment requirements, and proposed Alternative sanctions—including civil money penalties – for agencies with condition-level deficiencies. The Alliance’s comments are available on our website here.
Alliance members are strongly encouraged to submit their own comments on the federal Regulations website. Enter “CMS-1358-P” in the search box to find the PPS regulation, and follow the instructions to submit your comments. Comments are due by September 4.