Kirby, Randall--TN

Document ID: CMS-2010-0205-0042
Document Type: Public Submission
Agency: Centers For Medicare & Medicaid Services
Received Date: July 14 2010, at 12:00 AM Eastern Daylight Time
Date Posted: September 24 2010, at 12:00 AM Eastern Standard Time
Comment Start Date: July 13 2010, at 12:00 AM Eastern Standard Time
Comment Due Date: August 24 2010, at 11:59 PM Eastern Standard Time
Tracking Number: 80b18ab0
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This is comment on Proposed Rule

Medicare Program: Payment Policies Under the Physician Fee Schedule and Other Revisions toPart B (for CY 2011)

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I am writing this in regards to CMS-1503-P. This rule change would greatly affect our rural EMS service in a negative way. The inclusion of the multifactor productivity (MFP) in the calculation of the inflation factor for the annual adjustment in reimbursement results in a reduction in reimbursement. The GAO has published a report stating that CMS does not reimburse EMS (particularly rural EMS) enough. Please register that we are not in favor of this rule change.