Last week, APMA responded to the Department of Health and Human Services’ (HHS) “Request for Information (RFI): Ensuring Lawful Regulation and Unleashing Innovation To Make American Healthy Again,” calling on HHS to remove or reduce burdens related to same or similar requirements for durable medical equipment (DME), duplicative certification requirements for the Medicare Therapeutic Shoes for Diabetics (TSD) program, and the Merit-based Incentive Payment System. Specifically, APMA urged HHS to undertake the following actions:
Instruct the DME Medicare Administrative Contractors (MACs) to allow coverage of medically necessary “same or similar” items when the claim is submitted using the KX Modifier.
Instruct the DME MACs to remove the following sentence from “Therapeutic Shoes for Persons with Diabetes - Policy Article” (A52501):
"Obtain, initial, date (prior to signing the certification statement), and indicate agreement with information from the medical records of an in-person visit with a podiatrist, other M.D or D.O., physician assistant, nurse practitioner, or clinical nurse specialist that is within 6 months prior to delivery of the shoes/inserts, and that documents one of more of criteria a – f."
Remove unnecessary regulatory requirements from MIPS and provide clinicians with more flexibility to demonstrate high value care in a way that makes sense for their specific patient populations.
Members can read this letter and other past advocacy letters at www.apma.org/CommentLetters. Contact the APMA Advocacy Department with any questions or concerns.