May 22, 2017
Washington Healthcare Update
This Week: Chronic care gets attention…FDA user fee legislation continues to move toward reauthorization…more on repeal and replace.
4. State Activities
5. Regulations Open for Comment
House Energy and Commerce Subcommittee Advances FDA User Fee Bill
On May 18, the House Energy and Commerce Health Subcommittee moved forward,
on a voice vote, a
reauthorizing FDA user fee programs for drugs and medical devices.
The subcommittee approved four bipartisan amendments, including
designed to increase generic drug competition to address price hikes of
older drugs like Mylan’s EpiPen. Among other things, the amendment would
reward new generic competitors with 180 days of marketing exclusivity.
The panel also approved an
that would increase penalties for selling or distributing counterfeit drugs
that would update FDA’s medical device inspection process to a risk-based
Finally, lawmakers approved an
that would establish a category of FDA-approved over-the-counter hearing
aids. The idea is to increase access to and affordability of hearing aids
for those with mild to moderate hearing loss.
Days before the House marked up the FDA user fee reauthorization bill, HHS
Secretary Tom Price was pushing lawmakers to increase the fees paid by
industry to cover 100 percent of medical product reviews, as proposed in
President Donald Trump’s skinny budget. In the Senate, where the committee
has already moved on legislation, the reaction was that the proposal was
too late. The Senate HELP Committee marked up its version of the user fee
package to the Senate floor, 21-2, on May 11. Riders attached to the Senate
version of the bill address drug importation and counterfeiting,
over-the-counter hearing aids, risk-based device inspections, real-world
evidence and pediatric drug development, among other things. User fees
account for about half of the FDA’s annual budget.
The subcommittee also advanced on a voice vote
H.R. 1222, a bill that would enhance research and surveillance at CDC for congenital
heart disease and award grants for further study on the condition. And it
H.R. 2410, which would increase research, surveillance and prevention for sickle
Director Collins Urges Congress to Continue Stable Funding for NIH
In testimony before the House Appropriations Subcommittee on Health on May
17, NIH Director Francis Collins said that stable funding for his agency is
essential to continue vital research, hinting that looming cuts in the
Trump administration’s budget could create a roller coaster effect.
Collins’ remarks came a month after President Donald Trump proposed
slashing spending on the agency by $5.8 billion.
Rep. Tom Cole, chairman of the House appropriations subcommittee that
oversees the NIH budget, reiterated his opposition to the proposed
cuts—calling them “penny wise and pound foolish.” Cole said they would
stall progress on recent investments and could potentially discourage
promising scientists from entering or remaining in biomedical research.
Senate Finance Committee Approves the CHRONIC Care Act
On May 18, the Senate Finance Committee unanimously approved a bipartisan
bill that would alter the way Medicare treats chronic illnesses.
The CHRONIC Care Act (S. 870) provides more home care options by extending Medicare’s Independence at
Home program, enhances team-based care by making changes to accountable
care organizations and allows greater flexibility for Medicare and Medicare
Advantage plans to pay for telemedicine services, including stroke care.
The legislation, more than two years in the making, allows Medicare to pay
for remote stroke diagnosis and treatment, accountable care organizations
to provide telemedicine and Medicare Advantage plans to offer telemedicine
as a supplemental benefit, as well as pays for dialysis treatment at home
The measure would allow patients to be assigned to ACOs at the beginning of
a year and let providers pay patients $20 to receive certain primary care
services with them.
The four telemedicine-related sections of the bill would increase Medicare
spending by $150 million over a decade, according to a preliminary
CBO estimate. In the past, high CBO scores prevented similar efforts from advancing.
It is unclear when the bill will be considered on the Senate floor or how
the House will address the matter.
Sens. Isakson, Casey Propose Sweeping Changes to OTC Drug Regulation
Sens. Johnny Isakson (R-GA) and Bob Casey (D-PA) are circulating a draft
bipartisan plan that proposes the most sweeping changes in more than four
decades to the FDA’s process for regulating over-the-counter drugs.
FDA, industry groups and health experts say the current regulatory regime
is out of date. Under the
new proposal, product
approvals would be streamlined so FDA would no longer be required to do
rulemaking for each therapeutic class. Instead, the HHS secretary could
administratively establish standards for each OTC drug type.
The change is expected to not only speed up the process for creating OTC
drug standards but could improve the safety of products already being
marketed. Under the current rulemaking approach, it may take FDA several
years to update standards or labeling of an OTC drug even if the agency
identifies a safety or efficacy problem or pulls medicines off the market.
The bill would also create a new user fee program for OTC drugs, which
would be analogous to the fees used to help fund prescription drug
approvals. The new fees would help FDA cut down on a backlog of reviews it
has to perform on ingredients in products that have been on the market for
House Energy and Commerce Committee members have also been working on
Senators Propose Expansion of Substance Abuse Care
On May 17, senators unveiled bipartisan legislation that would ease
longstanding federal restrictions on Medicaid reimbursement for substance
abuse treatment centers in an effort to expand access to care amid a
nationwide opioid epidemic. The bill, the Medicaid Coverage for Addiction
Recovery Expansion (CARE) Act, was introduced by Sens. Rob Portman (R-OH),
Shelley Moore Capito (R-WV) and Dick Durbin (D-IL), among others.
The proposal would allow substance abuse treatment centers with up to 40
beds to be reimbursed by Medicaid for up to 60 consecutive days. The
proposal would roll back a law prohibiting Medicaid from paying for patient
care at facilities with more than 16 beds. That law, known as the
Institutes for Mental Diseases exclusion, was originally meant to
discourage institutionalization, but health experts say it has created a
major barrier to care and a severe nationwide shortage of psychiatric beds.
Under the bill, Medicaid would reimburse these facilities only for patients
being treated specifically for substance abuse at credentialed residential
addiction treatment facilities.
Lawmakers Reintroduce the Fair Drug Pricing Act
Sen. Tammy Baldwin (D-WI), Sen. John McCain (R-AZ) and Rep. Jan Schakowsky
(D-IL) are resurrecting the Fair Drug Pricing Act, which would require drug
makers to submit a report 30 days before they raise the prices, by more
than 10 percent in one year or 25 percent in three years, of certain drugs
that cost at least $100; and to disclose manufacturing, R&D and
marketing costs, as well as net profits associated with the drugs.
The legislation includes new requirements to target loopholes. For
instance, some drug makers have openly discussed plans to keep price hikes
just below 10 percent to avoid triggering similar thresholds—hence the
U.S. prescription drug spending reached a record high of $425 billion in
2015, accounting for almost 16.7 percent of all U.S. health care spending,
with expectations that spending will surpass $600 billion by 2020.
For more information,
Senate Health Care Working Group Focusing on Ways to Stabilize Individual Marketplace
On May 16, Sen. Ron Johnson (R-WI) said that the Senate’s health care
working group is focusing on ways to immediately stabilize the individual
marketplace, such as continuing the ACA’s cost-sharing reduction (CSR)
payments, in advance of a long-term solution to replace the Affordable Care
The Trump administration has not committed to making the CSR payments
beyond this month, and many insurers have threatened to exit the exchanges
in 2018 if the CSRs are not guaranteed.
Johnson said the working group is zoning in on a short-term solution
because insurers need to file rates soon for 2018.
In addition to demanding continued funding of the CSRs, health plans have
also called for an extension of the ACA’s reinsurance program, which ended
in 2016; payment by the federal government of the risk corridor money owed
to insurers; and changes to the risk adjustment program, including allowing
states to calculate payments by region rather than statewide. Insurers have
also lobbied Congress to permanently repeal the health insurance tax, and
to revise or repeal the so-called Cadillac tax on high-cost plans.
Sen. John Thune (R-SD) said a health bill will not pass the Senate unless
the tax credits in the House version are redesigned to help lower-income
and older individuals. Thune said senators have discussed designing tax
credits that are geographically adjusted in addition to being age and
income adjusted, a policy called for by various stakeholders, including
AARP, multiple insurance plan lobbies and the American Medical Association.
Thune said Republicans are waiting on an updated Congressional Budget
Office score of the House-passed American Health Care Act to drive their
changes to the tax credits. He said individuals need more choices for using
their tax credit than what the ACA subsidy allows and tying the credits to
age or income is a better way to design them.
Senators Urge OMB to Take Action on Drug Importation
In a May 15
letter to OMB Director Mick Mulvaney, a bipartisan group of senators encouraged executive or
administrative action to reduce the financial burden of prescription drugs.
Sens. Chuck Grassley, Amy Klobuchar and John McCain said the administration
can make use of a 2003 law that allows the FDA to green light importation
of less costly medications from Canada if the HHS secretary certifies the
practice would not pose added public health risks while resulting in a
significant reduction in costs.
The lawmakers said Mulvaney should work with HHS Secretary Tom Price to
immediately begin allowing importation of prescription drugs from Canada in
instances in which a drug is off patent or no longer marketed in the United
States by the innovator company, has undergone a significant and
unexplained price increase, has no direct competitor on the market and is
produced abroad by a brand-name company that developed the drug or by a
well-known generic company that commonly sells pharmaceuticals in the
The lawmakers said the policy could be limited so it does not hurt
companies that developed the new medications. They also urged Mulvaney to
explore other options for executive actions on drug pricing.
The letter came after the OMB director suggested that the government should
look at increasing the levels of discounts drug companies provide to
patients in Medicare Part D to make those rebates more on par with those
provided to Medicaid.
HHS Further Delays Medicare Bundled Payments, 340B Drug Program Changes
HHS is postponing a pair of Medicare bundled payment programs for the
second time, according to a
posted May 18.
The notice delays the start of payment models for knee and hip replacements
and cardiac care until Jan. 1, and hints at the possibility of making more
policy changes to the efforts.
HHS initially delayed the bundled payments in March, citing the Trump
administration’s freeze on pending Obama-era rules and regulations. This
additional delay gives providers more time to prepare and allows the agency
to consider any final tweaks. HHS Secretary Tom Price has in the past
criticized mandatory demonstration projects like bundled payments for hip
and knee replacements.
In a separate
final rule, HHS also postponed changes to the 340B Drug Program. The new
parameters—which were tentatively scheduled to take effect on May 22—set a
ceiling price for participating drug companies and clarified how civil
monetary penalties would be imposed. Those policies will now start on Oct.
CMS Releases Federal Funding Methodology for Basic Health Program
On May 17, CMS released an informational bulletin to states providing more
information specifying the final values for the factors needed to calculate
the federal BHP payment rates for 2018 that were not included in the 2017
and 2018 BHP Payment Notice. It does not alter the payment methodology or
definitions of any of the factors. In addition, the bulletin reminds states
operating a BHP for 2018 of the need to make two decisions: (1) whether to
develop a retrospective population health factor (PHF) adjustment
methodology; and (2) whether to use the 2017 or 2018 qualified health plan
(QHP) premiums as the basis for calculating the 2018 BHP federal payments.
The informational bulletin can be accessed on
For more information on BHP,
CMS Announces Regions for CPC+ Round 2
Strengthening primary care is critical to promoting high-quality,
patient-centered care and reducing overall health care costs in the U.S.
Comprehensive Primary Care Plus
(CPC+) model is an advanced primary care medical home model that rewards
value and quality by offering an innovative payment structure to support
primary care practices to improve quality, access and efficiency. The model
offers two tracks with different care delivery requirements and payment
methodologies to meet the diverse needs of primary care practices.
On May 17, CMS announced the four regions it has selected for the
Comprehensive Primary Care Plus (CPC+) Round 2 and the health insurance
companies that will participate. They join the 54 payers in 14 regions that
were selected for Round 1 last year. The goal with the payment design model
is to improve health outcomes while lowering costs.
Following payer applications and selections, the following four regions
were selected for CPC+ Round 2:
North Dakota: Statewide
New York: Greater Buffalo Region (Erie and Niagara Counties)
Eligible practices located in these regions may apply from May 18, 2017, to
July 13, 2017, to participate in CPC+ Round 2.
For more information,
CMS Announces Streamlined Direct Enrollment Process for Consumers Seeking Exchange Coverage
On May 17, CMS announced a new streamlined and simplified direct enrollment
process for consumers signing up for individual market coverage through
exchanges that use HealthCare.gov. Consumers applying for individual market
coverage during the upcoming open enrollment period through direct
enrollment partners will now be able to complete their application using
one website. This reduces needless regulatory burden for businesses that
provide direct enrollment services and offers consumers easier access to
health care comparisons and shopping experiences for coverage offered
In prior years, consumers who signed up for health coverage using a
third-party website were redirected to HealthCare.gov to complete their
application. Consumer feedback showed that the process was confusing and
made it harder to finish the application. The new process allows consumers
to start and finish their application through the third-party website of
direct enrollment partners approved to use the proxy direct enrollment
For more information,
CMS Offering New Health Coverage Enrollment Option for Small Businesses
On May 15, CMS announced a plan to change the way that small businesses
enroll in insurance coverage through the federal exchanges, offering
employers the help they need to find affordable insurance for their
The Federally-Facilitated Small Business Health Options Program (FF-SHOP)
was mandated under the ACA but failed to sign up significant numbers of
small employers. Out of the nearly 30 million small businesses in the
country, less than 8,000, just 0.1 percent, of small businesses currently
participate in the FF-SHOPs in 33 states, which cover less than 40,000
individuals nationwide. SHOP programs are now defunct and do not provide
needed insurance coverage for small businesses.
As part of the changes CMS intends to propose, employers would still obtain
a determination of SHOP eligibility through HealthCare.gov. The move would
reduce the federal government’s role in health care coverage decisions and
make it easier for issuers to use their own enrollment systems for SHOP
plans. Online enrollment would be removed from HealthCare.gov and small
employers would access coverage through an agent or broker, or an issuer of
their choice, for plan years beginning on or after Jan. 1, 2018.
The FF-SHOPs exist in states where the SHOP program is operated by the
federal government. Small businesses with SHOP coverage that took effect in
2017 would be able to continue using HealthCare.gov for enrollment and
premium payment until their current plan year ends. Some employers that
purchase SHOP coverage are also able to access the Small Business Health
Care Tax Credit. This option will still be available to small employers who
purchase coverage under the new enrollment approach.
Under the intended approach, state-based SHOPs not using HealthCare.gov
could continue to operate as they have previously.
For more information,
States File a Motion to Intervene in Obamacare Subsidy Lawsuit
More than a dozen states are trying to intervene in a lawsuit to save a key
piece of Obamacare—cost-sharing subsidies that insurers receive to reduce
costs for their customers. The states argue that the Trump administration
is no longer representing their interests in the case, because the
president has repeatedly threatened to kill the subsidies.
“Immediate loss of CSR funding, with any future funding subject to the
myriad uncertainties of the appropriations process, would harm millions of
state residents and the States themselves,” the states’ motion contends.
The effort is led by New York Attorney General Eric Schneiderman and
California Attorney General Xavier Becerra. All of the states seeking to
intervene are led by Democratic attorneys general.
House Republicans sued last year to block funding for the subsidies,
arguing that it amounted to an illegal appropriation. They prevailed at the
lower court level, but the Obama administration appealed that decision.
The Trump administration has given mixed signals about how it intends to
proceed. The White House faces a May 22 deadline to tell the court if the
administration will press forward with the appeal.
If the appeal is dropped, it’s anticipated that the subsidies would go away
immediately. That could cause insurers to drop out of the Obamacare
exchange markets, wreaking havoc for individuals who get coverage through
To read the motion to intervene, click
Insurance Commissioners Urge Funding for Obamacare Subsidies
State insurance commissioners are urging the White House and Congress to
fund Obamacare’s cost-sharing subsidies ahead of a May 22 legal deadline
for how to proceed on the issue.
The National Association of Insurance Commissioners sent
letters to OMB Director Mick Mulvaney and Senate leaders warning
that the Obamacare markets could collapse if the government doesn’t keep
making the payments and provide stable funding to help cover the health
law’s low-income customers.
“Your immediate action is critical to the viability of the individual
health insurance markets in a significant number of states across the
country,” reads the letter to Senate leaders.
Last year, House Republicans successfully challenged the legality of
funding. The lower-court decision was appealed by the Obama administration.
A judge has set a deadline of May 22 for the parties to decide how to
proceed in the House lawsuit. If the Trump administration decides to drop
the appeal, it’s expected that the payments to insurers would cease
Insurance commissioners are also calling on the Senate to provide funding
to help stabilize the individual market. They’re seeking funds that states
can use to create either reinsurance programs or high-risk pools to protect
insurers from the costs of particularly expensive customers.
Earlier this month, the House passed the American Health Care Act, which
includes $138 billion over a decade in part to help states take care of
residents with chronic, costly medical needs. The Senate is in the process
of drafting its own bill.
Coalition Unveils Package of Proposals to Lower Drug Prices
On May 16, a coalition of insurers, drug makers and pharmacy benefit
managers unveiled a package of proposals that they say will lower drug
prices. Some of the proposals include: pushing FDA to issue guidelines on
preapproval communication between industry and payers; creating a priority
review voucher for certain generics coupled with expedited FDA review of
these drugs; exempting value-based arrangements from price reporting
requirements; shielding value-based arrangements from anti-kickback and
Stark laws; and encouraging data sharing.
The reforms would save taxpayers between $2.6 and $5.6 billion over 10
years, while reducing national health expenditures by as much as $36-71
billion by 2026, according to the Council for Affordable Health Coverage.
Among those in the coalition are the Biotechnology Innovation Organization,
Sanofi and GlaxoSmithKline; PBM interests including the Pharmaceutical Care
Management Association, Express Scripts and CVS Health; insurers Aetna and
Cigna; and business groups including the U.S. Chamber of Commerce.
The group’s white paper “Prescriptions for Competition, Value, and
Innovation: Positive Reforms to Increase Access and Affordability for
Prescription Drugs” describes their recommendations.
4. State Activities
California: Covered California to Hold Three-Month Open Enrollment Period
Covered California is preparing for a three-month open enrollment period
this fall. The open enrollment period for 2018 coverage will run from Nov.
15, 2017, to Jan. 31, 2018—the same as last year—despite the federal
government’s plans to shorten HealthCare.gov’s enrollment period to six
weeks, Peter Lee, the exchange’s executive director, said at a recent
very clearly provide that the state-based marketplaces will be given
discretion to do what’s right in their states,” Lee said, adding that his
plan to extend California’s enrollment period has received support from CMS
Covered California officials presented the board with a proposed $314
that includes $105 million for marketing and outreach, as well as nearly
$86 million to run the exchange’s service center. The plan also provides
for an 11-month operating reserve of $289 million, which would allow for
some flexibility given the uncertain political climate.
Covered California’s operation is funded primarily by charging health plans
a 4 percent assessment on premiums for the 1.4 million people covered in
the exchange. The exchange relies on no state or federal money, other than
the federal subsidies.
Covered California recently released a paper outlining the
for its success. A day earlier, the exchange released
of its healthy risk pool mix.
5. Regulations Open for Comment
FDA Considers Establishing New Office of Patient Affairs
The FDA is considering establishing a new Office of Patient Affairs that
would centralize its work on patient involvement in the review and approval
of drugs and medical devices, according to a
March 14 notice
in the Federal Register.
Comments on the new office are due by June 12, 2017.
FDA Submits Interim Final Rule on Long-Delayed Menu Labeling Rule
On April 27, FDA submitted an
interim final rule
to the White House Office of Management and Budget concerning a
long-delayed menu labeling rule. By submitting an interim final rule to OMB
they are delaying its existing final rule, slated to take effect May 5. The
apparent change in course follows a
by the National Association of Convenience Stores and the National Grocers
Association asking FDA to push back the final rule’s effective date.
The move to submit the interim final rule follows years of controversy and
debate about the menu labeling requirements, which stem from a
little-noticed provision in the Affordable Care Act that calls for
mandatory calorie disclosure on menus at chains that have 20 or more
The agency’s notice to OMB offers no detail about whether it is seeking
other changes to the rule, but says FDA will be taking comments.
CMS Releases Proposed Hospital Pay Rule
In a new proposed
2018 Medicare payment rule, CMS
says it will look to cut hospital industry regulations and streamline
oversight, and it’s asking hospitals themselves for help. The agency is
soliciting ideas for changes to rules and procedures governing acute-care
and long-term care hospitals. The initiative aims to “relieve regulatory
burdens for providers,” as well as promote flexibility and innovation, CMS
said in a statement.
The new proposed rule would suspend for one year a provision penalizing
long-term care hospitals that receive more than 25 percent of patients from
a single acute-care hospital. It would also reduce certain quality
reporting requirements for hospitals that have implemented electronic
CMS projects the rule would increase Medicare spending on inpatient
hospital services by $3.1 billion in 2018, with operating payments to
hospitals increasing 2.9 percent. Long-term care hospitals’ Medicare
payments are projected to decrease by $173 million, or 3.75 percent, over
the same period.
Comments on the rule must be submitted no later than 5 p.m. EDT on June 13,
CMS Proposes 2018 Payment and Policy Updates for Medicare Hospital
CMS is offering hospitals a 90-day meaningful use reporting period in 2018,
according to a
proposed payment rule
released April 14.
The first major payment regulation released under HHS Secretary Tom Price
marks a change from the back-and-forth over electronic health records
meaningful use requirements seen under the Obama White House. The previous
administration would typically propose a yearlong reporting period, then
scale it back at the last minute after intense lobbying pressure. As a
Republican congressman from Georgia, Price often pushed the Obama
administration hard for 90-day meaningful use reporting periods.
In connection with the 21st Century Cures Act, CMS also is
to remove from meaningful use clinicians who see most of their patients at
ambulatory surgery centers.
Price and CMS are also changing previously finalized requirements from
electronic clinical quality measures. Under the proposed rule, hospitals
can select six measures and report on them for the first three quarters of
For more information,
CMS is Accepting Measure Submissions for the Advancing Care Information
Performance Category until June 30
CMS is still accepting measures for the Advancing Care Information
performance category of the Merit-based Incentive Payment System (MIPS).
The Annual Call for Measures and Activities ends June 30, 2017.
CMS encourages providers to identify and submit measures for the MIPS
Advancing Care Information performance category. To be considered,
proposals must include specific criteria including, but not limited to,
measure description, measure type and numerator and denominator
CMS requests that stakeholders consider outcome-based measures, patient
safety measures and cross-cutting measures that use certified EHR
technology to support the improvement activities and quality performance
categories of MIPS.
Advancing Care Information Submission Form
to propose measures for inclusion, and send the form to
To learn more about the process for submitting measures, please visit the
Call for Measures
webpage, and review the
Call for Measures and Activities fact sheet.
CMS Looks to Boost Medicare Payments to Rehab Hospitals, Nursing
Facilities and Hospices
CMS could boost Medicare payments to a swath of rehabilitation hospitals,
nursing facilities and hospices under a trio of new proposed rules.
On April 27, the agency floated a
$390 million bump
in federal payments to skilled nursing facilities in 2018—or roughly 1
percent higher than this year. Hospices, meanwhile,
a 1 percent increase worth $180 million.
to increase reimbursement to rehab hospitals by $80 million for 2018, in
addition to eliminating a penalty on facilities that don’t submit certain
data to the federal government on time.
proposed payment rules for other
providers, CMS is asking the industries for input on regulations it should
overhaul or eliminate. CMS Administrator Seema Verma and HHS Secretary Tom
Price have pledged to review all of the agency’s rules in a bid to cut
unnecessary or burdensome regulations.
Comments on the trio of rules must be received no later than 5 p.m. on June
CMS Seeking Comments on Data Elements in IMPACT Act
CMS has contracted with the RAND Corporation to develop standardized
patient/resident assessment data elements in alignment with the Improving
Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act).
CMS seeks comments from stakeholders on data elements that meet the IMPACT
Act domains of cognitive function and mental status; medical conditions and
co-morbidities; impairments; medication reconciliation; and care
preferences. The public comment period opens on April 26, 2017, and closes
on June 26, 2017.
For more information, view the
CMS Issues 2018 IPPS Proposed Rule
CMS issued the FY 2018 Inpatient Prospective Payment System (IPPS) and Long
Term Acute Care Hospital (LTCH) rule on April 14, which proposes a number
of changes to the Medicare and Medicaid Electronic Health Record (EHR)
The proposals include:
For CY 2018, modifying the EHR reporting period from the full calendar
year to a minimum of any continuous 90-day period for new and returning
participants in the Medicare and Medicaid EHR Incentive programs.
Adding a new exception from the Medicare payment adjustments for
Eligible Professionals (EPs), Eligible Hospitals and Critical Access
Hospitals (CAHs) that demonstrate through an application process that
complying with the requirement for being a meaningful EHR user is not
possible because their certified EHR technology has been decertified
under ONC’s Health IT Certification Program.
Implementing a policy in which no payment adjustments will be made for
EPs who furnish “substantially all” of their covered professional
services in an ambulatory surgical center (ASC); applicable for the
2017 and 2018 Medicare payment adjustments.
Using Place of Service (POS) code 24 to identify services furnished in
an ASC as well as requesting public comment on whether other POS codes
or mechanisms should be used to identify sites of service in addition
to or in lieu of POS code 24.
Comments must be submitted by 5 p.m. on June 13, 2017.
To learn more, review the
CMS Publishes Post-Acute Care Proposed Rules
On May 11, CMS published the following proposed rules:
GAO: PTSD, Traumatic Brain Injury Need to be Considered in Misconduct Separations
In a new report, GAO says actions are needed to ensure post-traumatic
stress disorder and traumatic brain injury are considered in misconduct
PTSD and traumatic brain injury can affect the behavior of service members
in the armed forces and may lead to separations for misconduct. GAO
examined misconduct separations and found that service members diagnosed
with PTSD, TBI or certain other conditions can receive an “other than
honorable” discharge—making them potentially ineligible for VA health
However, not all of the military services have consistent policies in place
to address the impact of these disorders on misconduct separations. GAO
recommended that DOD direct the military services to address
inconsistencies in their separation policies.
To read the report,
If you have any questions, contact the following individuals at
Kennan, Senior Vice President
Charlie Iovino, Vice
Caroline Perrin, Research Assistant
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