In two separate letters to the Centers for Medicare and Medicaid Services, the American Hospital Association has recommended changes to the 2010 proposed Medicare payment rates.
AHA Executive Vice President Rick Pollack signed both comment letters, which specifically target the Hospital Outpatient Prospective Payment System, Ambulatory Surgical Center Payment System and Clinical Laboratory Fee Schedule.
One letter suggests several changes to Medicare's proposed policy for supervision of outpatient therapeutic and diagnostic services in calendar year 2010 to better fit the way that care is provided across the spectrum of hospitals.
The AHA said CMS should revise its proposed definition of "direct supervision" and permit non-physician practitioners and clinical social workers to supervise some of these outpatient services.
The letter on the proposed hospital outpatient prospective payment system and ambulatory surgical center rule also objects to CMS' proposal to publicly report outpatient quality data that has not been validated, suggests changes to the proposed payment rate for separately covered outpatient drugs and calls on CMS to require ASC quality and cost reporting.
In a second letter to CMS, the AHA called for a consistent Medicare policy for laboratory tests.
Pollack wrote that Medicare should establish a single policy for requesting clinical diagnostic laboratory tests and make clear that a physician's signature is not required on any request for laboratory services.
"Doing so will eliminate confusion about Medicare policy, ensure timely provision of laboratory testing and minimize unnecessary disputes between hospital laboratories and Medicare contractors, such as those who operate the CERT (Comprehensive Error Rate Testing) program and the RACs (Recovery Audit Contractors)," Pollack wrote.