Colleen Dailey -- PA

I am a health care practitioner in a non profit organization. I personally think that the current CMS-1455-R is very equitable to the hospital that accomodated your benificiary and to CMS. The hospital provided services and should be reimbursed for those services at a level that is deemed appropriate. On the other hand, the CMS-1455-P is so discrimanatory and dishonorable. It limits timely filing to 1 year which is ludicrous since the RAC look back period is 3 years. Those denials that are submerged in this onerous appeal process may be 5 years or older. The proposal essentially takes all of these denials off the table. It frankly shows a certain level of insouciance and lack of conscience. If the RA is denying an inpatient level of care as not medically necessary, but agrees that the care could have been provided at a lower level, then pay the hospital at the lower level. Th RA is reopening an old claim that has already been paid and decides now that the level of care was not appropriate. OOPs!! We are going to take the whole payment back and if they (hospitals) don't like it they can appeal. In the meantime we can make interest on the whole amount for the next 2-3 years. WHAT OTHER BUSINESS IS ALLOWED TO DO THIS???? Talk about fraud an waste, this progam wrote the book!!!!