DJP Update 3-2-2011 Regulations for PPACA, the new health care law, are coming your way; Lagniappe: Host weekly radio show soon
With laws come regulations. With a law that is more than 2400 pages long, there will be lots of regulations. And subsequent laws passed sometimes add in other provisions that affect the PPACA law. The average medical doctor is too busy to monitor the proposed regulations, offer comments in the comment period, or testify. It is hoped that your medical association or specialty society is up to date on all of these proposed regulations and takes steps to preserve ethical science-based medicine. You can bet the final regulations for PPACA will exceed the length of the law. As I wrote in the editorial published in the Journal of the Louisiana State Medical Society, think Gulliver:
Imagine Gulliver tied down by the Lilliputians! Swift relates how Gulliver tried to break the stands that bound him to the ground, “But the harder he fought for freedom, the more the little men shot arrows into him, and some of them even tried to run their spears into his sides.”
Complete article at: http://journal.lsms.org/images/stories/Editorial.pdf
If you were too busy to notice Federal Government announcement about PCORI (Patient-Centered Outcomes Research Institute), there is a public hearing in St. Louis on March 7-8.
Complete schedule and more about PCORI: Go to: http://pcori.org/
Note: This PCORI is NOT the IPAB (Independent Payment Advisory Board) IPAB is a new price-fixing group. One summary of IPAB is at: http://healthreformstat.com/2010/06/08/independent-payment-advisory-board/
Most medical organizations oppose IPAB. As for PCORI, one has to monitor it carefully to make sure it doesn’t lose the educational purpose and turn into a rationing board.
PCORI: Public Comments are allowed for 30 minutes on Monday March 7 and again for 30 minutes on Tuesday March 8. Note that 30 minutes each day are for the entire universe of those who wish to comment. Not 30 minutes per person.
PATIENT-CENTERED OUTCOMES RESEARCH INSTITUTE
Board of Governors Meeting
March 7-8, 2011 (starts at 1 p.m. on Monday and 8 a.m. on Tuesday; all times Central)
The Westin St. Louis Hotel
811 Spruce Street, St. Louis, MO 63102
Below you will find some activity in health system reform. Here are a few excerpts taken from the Louisiana Hospital Association mailing to its members (LHA Health Reform Resource Weekly Update – March 2, 2011). You will note the links and you can visit the links to see the letters written or view the regulation.
For example, look at the comparative effectiveness. Clicking on the link will take you deeper into the issues raised by the proposed regulations as well as the goal of the regulations.
Here is one excerpt from the Comparative Effectiveness Research and continuing education link below that takes you to this Web address:
http://edocket.access.gpo.gov/2011/pdf/2011-4130.pdf
“AHRQ is expanding its continuing education to include nurses, nurse practitioners, physician assistants, medical assistants, pharmacists, respiratory therapists, and other allied health professionals, as well as physicians. In addition, AHRQ wants to assess the impact continuing education has on clinician behavior, its perceived value, and whether or not education on comparative effectiveness research made a difference in a clinician’s confidence in applying comparative effectiveness research in practice, understanding the application of such research, and improved ability to counsel patients on treatment and management alternatives.”
EXCERPTS FROM LOUISIANA HOSPITAL ASSOCIATION NEWSLETTER
LHA & AHA RESOURCES
· Letter to Secretary Sebelius regarding Proposed Rule for Rate Increase Disclosure and Review under the PPACA: OCIIO -9999-P, American Hospital Association
· Letter to Director Berwick regarding Medicare Program; Solicitation of Comments Regarding Development of a RAC Program for the Medicare Part C and D Programs; File Code CMS-6041-NC, American Hospital Association
- LHA Letter to HHS/CMS regarding Medicare Program; Solicitation of Comments Regarding Development of a RAC Program for the Medicare Part C and D Programs; File Code CMS-6041-NC
- AHA Letter to Office of the National Coordinator HIT regarding HIT Policy Committee: Meaningful Use Workgroup Request for Comments Regarding Meaningful Use Stage 2
- America’s Hospitals and Health Systems Letter to Secretary Sebelius regarding Maintenance of Effort (MOE) provisions in ACA, AHA
· AHA Comment Letter Regarding CMS-3239-P, Medicare Program; Hospital Inpatient Value-Based Purchasing Program; Proposed Rule (Vol. 76, No. 9), January 13, 2011
· AHA Letter to Agency for Healthcare Research and Quality regarding RE: CMS-2420-NC, Medicaid Program; Initial Core Set of Health Quality Measures for Medicaid-Eligible Adults; Notice (Vol. 75, No. 250), December 30, 2010
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RULES & REGULATIONS
- Final Rule: Regulation for the Enforcement of Federal Health Care Provider Conscience Protection Laws, Effective March 25, 2011, HHS
- Announcement 2011-20: Delayed Filing Season for Certain Tax-Exempt Hospitals, IRS
- Schedule H (Hospital) filers: Do not file 2010 Form 990 before July 1, 2011, IRS
- Proposed Rule: Community First Choice Option, Comments due 5 pm EST April 26, 2011, HHS/CMS
- Comment Request regarding Comparative Effectiveness Research— Continuing Education; implements TeamSTEPPS, an evidence based framework to optimize team performance across the healthcare delivery system with the goal of improving patient safety, Comments due March 30, 2011, HHS
- Improving Patient Safety System Implementation for Patients with Limited English Proficiency, Comments due March 30, 2011, HHS
· Guidance on the “maintenance of effort” (MOE) provisions in the Patient Protection and Affordable Care Act, P.L. 111-148, as amended by the Health Care and Education Reconciliation Act of 2010; P.L. 111-152 (together known as the ACA), HHS/CMS
- Comment Request regarding Rate Increase Disclosure and Review Reporting Requirements (45 CFR Part 154) Use: Under the Section 1003 of the ACA (Section 2794 of the Public Health Service Act), the Secretary, in conjunction with the States, is required to establish a process for the annual review, beginning with the 2010 plan year, of unreasonable increases in premiums for health insurance coverage; Comments due May 2, 2011, HHS/CMS
- Comment Request; ACA Internal Claims and Appeals and External Review Procedures for Non-Grandfathered Plans, Comments due March 31, 2011, DOL
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LAGNIAPPE: Later this month, I will start hosting a weekly one-hour radio show. More details to come.
Stay well,
Donald
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Donald J. Palmisano, MD, JD
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