January 6, 2004
The Honorable Dennis Smith
Centers for Medicare & Medicaid Services
Department of Health and Human Services
P.O. Box 8018
Baltimore, MD 21244-8018
December 30, 2003
Dear Mr. Smith:
We are writing in response to the final 2004 Hospital Outpatient Prospective Payment System (HOPPS) rule published in the November 7, 2003 (68 Fed. Reg. 63398). The Nuclear Medicine APC Task Force (Task Force) is pleased with the consideration and attention given to our detailed comments to the proposed rule, which resulted in the further refinement of the Nuclear Medicine APCs.
Specifically, we appreciate the restructuring of the newly proposed organ-based Nuclear Medicine APCs for 2004. We believe this refined structure is more homogeneous, consistent with congressional standards and will allow improved access to high quality care for Medicare recipients. We agree with CMS and recognize that some APCs still violate the two-times rule. We will continue to work with CMS regarding recommendations for additional refining changes for 2005. The Task Force is pleased to submit these additional comments and recommendations to assist the Centers for Medicare and Medicaid Services (CMS) in refining the ambulatory payment classification (APC) system. . . .
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NOTE: Attached to the comments are the first three pages of NUBC committee minutes