Will reason reign?
I don’t know if I’m cranky this morning or what (I am disappointed with myself for breaking a week of caffeine-free living yesterday), but CMS’s handing of this new PMD demo is really rubbing me the wrong way.
Let me start with the one thing that CMS has done right. The agency has hosted more than a handful of Special Open Door Forums (or ODFs as officials like to call them) on the demo, updating stakeholders on the various versions of the operational guide that provides instructions for the project.
Associate Editor Elizabeth Deprey has listened to each of these forums, diligently reporting on the changes made and stakeholder reaction. Just plug in “PMD demo” into the search function on our website and you can catch up on all of the fun.
(An aside: CMS never put this much effort into education and feedback for competitive bidding—a much bigger project that affects way more stakeholders. No, the agency has offered webcasts, but not forums, keeping interactions to a minimum—but that’s a blog for another day.)
From here, though, things get ugly, to play off the lead of Managing Editor Theresa Flaherty’s story this week on the Round 1 re-compete.
How, in you know who’s name, can CMS ask providers to participate in a project in a few days when it hasn’t released all of the instructions for said project? Want some examples of what’s still missing? Here’s an excerpt from one of Elizabeth’s most recent stories:
Other placeholders in the guide refer to accessories (will they or won’t they be included in the demo?), upgrades (how will prior authorizations work when patients want more expensive PMDs than Medicare will agree to cover?), and a definition for late entries (review contractors will consider late entries to be part of a medical record if they are made within "a few days" of the visit, but providers want to know what "a few days" means).
That’s not to mention the placeholder that refers to a pending change to the program integrity manual regarding an electronic clinical template for physicians. Will there be a template for use in the demo? Because that’d be a huge help.
Let’s just say that CMS answers all of these questions and more during tomorrow’s Special ODF on the PMD demo. That still gives stakeholders only two days—two days before a holiday weekend, no less—to educate themselves and educate referring physicians and beneficiaries.
Which is why AAHomecare is asking CMS to delay implementation of the demo until 30 days after it has released the final instructions.
Now, I know that the industry has been asking for a lot of things lately. But unlike those other things—replacing competitive bidding with the market-pricing program, for example—this would be a pretty easy request to fulfill on CMS’s part.
Let’s see what happens tomorrow. My fingers are crossed that reason will reign.