MGMA to CMS: Don’t extend no-pay policy to practices

The Medical Group Management Association (MGMA) would be “extremely concerned” if CMS extended its non-payment strategy for preventable conditions to physician practices. This is according to a letter that the association submitted to CMS during the comment period for the FY2009 Inpatient Prospective Payment System proposed rule that was published in April. In addition, MGMA also used the comment letter to “raise concerns regarding any rapid timeline for adopting the ICD-10 code sets.”

Within its proposed rule, CMS requested comments from the industry on both of these issues. The last day to submit comments to CMS on the proposed rule was Friday, June 13.

Regarding MGMA’s stance on preventable conditions, the association stated the following in its comment letter:

"Not only is the physician payment system different from the hospital setting, but the attribution issues alone would make this approach nearly impossible to accurately and fairly implement at the physician level. We believe this punitive policy is totally contrary to current efforts to implement a lasting patient safety system in this country as envisioned in the Patient Safety and Quality Improvement Act of 2005."

As far as its position on the roll out of ICD-10, MGMA stated that the "complex software and business process changes" that must be completed before the implementation are extremely challenging and costly for industry. In addition, the comment letter stated:

"Transitioning too rapidly to ICD-10 would create significant problems for the entire health care industry, especially providers. Before any move to ICD-10, there must be a national implementation plan, a cost-benefit analysis, code set crosswalks, and full implementation of the HIPAA 5010 standards."

A Health Data Management online article about MGMA's position can be accessed here (free registration required).

MGMA’s comment letter can be accessed here.