TX-Belinda Murray

The proposal to cap outlier payments at 10% per agencyis penalizing agencies that have accepted patients and provided legitimate services to insulin dependent diabetics throughout PPS when other agencies would not accept these patients. I understand the concern with fraud, but please don't penalize all agencies because of a few bad apples. CMS should look at an agency's adverse events histoy for hypoglycemia/hyperglycemia hospitalizations and only penalize those agencies that have increased numbers of these hospitalizations. Our agency had zero last year! In the long run thisproposal will end up costing Medicare more due to an increase indiabetic related complications and an incrase in hospitalizations due to mismanagement of insulin dependent diabetics. CMS has always given exception to insulin dependent diabetics, with good reason, and is now jeopardizing those same patient's lives with this proposal. How can it possibly be in the best interest of the patient to deny life-sustaining treatment to them? This proposal denies treatment to the group of people we should be most concerned about caring for...our elderly. I would like to offer the following alternatives: 1) grandfather in current patients as a home ehlth agency cannot abandon patients already on service, 2) grandfather in each agency's current percentage rate of outliers and do not allow the agency to exceed that percentage, 3) when setting caps on outlier payment percentages take into account the population of the county (i.e. Harris county), 4) allow higher percentages to counties with high concentrations of insulin dependent diabetics (i.e. counties with a large Hispanic population. Respectfully, Belinda Murray