Christopher McEleney

Document ID: CMS-2011-0129-0006
Document Type: Public Submission
Agency: Centers For Medicare & Medicaid Services
Received Date: July 19 2011, at 12:00 AM Eastern Daylight Time
Date Posted: August 1 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: July 8 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: August 30 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80ec60c2
View Document:

This is comment on Proposed Rule

Medicare Program: Changes to End-Stage Renal Disease Prospective Payment System for CY 2012, etc.

View Comment

CMS1577 dated 7/8/11 proposes changes to the ESRD PPS for CY2012. The CY2011 ESRD PPS contained info concerning Low Volume facilities and requesting low volume payments. Under 413.232(b)1 and 2 the requirements to be low volume includes a segment; "has not opened, closed, or received a new provider number due to a change of ownership during the 3 years preceding the payment year". The CY2012 proposed rule has eliminated the phrase "received a new provider number due to a change of ownership". We do not believe there was an intent to change this requirement, nor do we agree that a change is necessary. The proposed rule would negatively impact new owners of under-performing clinics that would otherwise wish to apply for the low volume designation.