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	<title>Comments for Health Reform GPS: Navigating the Implementation Process</title>
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	<description>Navigating the Implementation Process</description>
	<lastBuildDate>Tue, 15 May 2012 00:52:34 +0000</lastBuildDate>
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		<title>Comment on CMS selects 500 FQHCs for Advanced Primary Care Practice demonstration project by William E Tierney, CPA</title>
		<link>http://www.healthreformgps.org/resources/cms-selects-500-fqhcs-for-advanced-primary-care-practice-demonstration-project/comment-page-1/#comment-58631</link>
		<dc:creator>William E Tierney, CPA</dc:creator>
		<pubDate>Tue, 15 May 2012 00:52:34 +0000</pubDate>
		<guid isPermaLink="false">http://healthreformgps.org/?p=3951#comment-58631</guid>
		<description>Productivity screenings-Team &amp; Non-Team

Make sure the Medicaid model uses the team productivity standard, and not the non-team productivity standard. With the non-team productivity standard, a patient may never see a physician; they could be seen by midlevels only. The Medicaid non-team productivity standards are not a reasonable screening process.   
The Medicaid productivity screening is using the higher count of actual encounters, or standard encounters (4200 for docs  &amp; 2100 for midlevels) for each provider type. 

Medicare uses the higher of actual team encounters, or team standard encounters. Medicare is using the reasonable productivity screen.  

The Medicaid programs created the non-team standard after a 1994 Medicare printing error on the Medicare HCFA/CMS 222 productivity form. It must have been published at one of the State Medicaid director meetings. I would really like to find a presentation document.          

It is time for someone to step up and show how bad the non-team productivity standards methodology is.

Let’s look at the productivity for 500 Health Center base PPS rates &amp; actual encounter productivity using both methods. 

Did Medicaid apply productivity penalties when the FQHCs actually met team productivity standards?    

 
These 500 FQHCs would be a great case study.   

  



The form HCFA -222-92 (8/94) Worksheet B, Part I &amp; II Line 1-3, col. 4 were not shaded, thereby causing the Non-Team practice of medicine in the USA FQHCs.  The Medicare intermediary recorded the XXXX where it should have been shaded  The Medicare computerized Form HCFA/CMS 222 was always correct.                


After 18 years, Medicaid now needs to use the more reasonable screening model.   
We now need to use the proper national productivity screening philosophy.   

TEAM-TEAM-TEAM-TEAM-TEAM-TEAM    

The 2012 MEI % change from 1.8% to 0.60%; I know I did the right thing.           

WET</description>
		<content:encoded><![CDATA[<p>Productivity screenings-Team &amp; Non-Team</p>
<p>Make sure the Medicaid model uses the team productivity standard, and not the non-team productivity standard. With the non-team productivity standard, a patient may never see a physician; they could be seen by midlevels only. The Medicaid non-team productivity standards are not a reasonable screening process.<br />
The Medicaid productivity screening is using the higher count of actual encounters, or standard encounters (4200 for docs  &amp; 2100 for midlevels) for each provider type. </p>
<p>Medicare uses the higher of actual team encounters, or team standard encounters. Medicare is using the reasonable productivity screen.  </p>
<p>The Medicaid programs created the non-team standard after a 1994 Medicare printing error on the Medicare HCFA/CMS 222 productivity form. It must have been published at one of the State Medicaid director meetings. I would really like to find a presentation document.          </p>
<p>It is time for someone to step up and show how bad the non-team productivity standards methodology is.</p>
<p>Let’s look at the productivity for 500 Health Center base PPS rates &amp; actual encounter productivity using both methods. </p>
<p>Did Medicaid apply productivity penalties when the FQHCs actually met team productivity standards?    </p>
<p>These 500 FQHCs would be a great case study.   </p>
<p>The form HCFA -222-92 (8/94) Worksheet B, Part I &amp; II Line 1-3, col. 4 were not shaded, thereby causing the Non-Team practice of medicine in the USA FQHCs.  The Medicare intermediary recorded the XXXX where it should have been shaded  The Medicare computerized Form HCFA/CMS 222 was always correct.                </p>
<p>After 18 years, Medicaid now needs to use the more reasonable screening model.<br />
We now need to use the proper national productivity screening philosophy.   </p>
<p>TEAM-TEAM-TEAM-TEAM-TEAM-TEAM    </p>
<p>The 2012 MEI % change from 1.8% to 0.60%; I know I did the right thing.           </p>
<p>WET</p>
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		<title>Comment on Ways and Means Committee speculates that ACA could cause employers to drop ESI by Art As Social Inquiry</title>
		<link>http://www.healthreformgps.org/resources/ways-and-means-committee-speculates-that-aca-could-cause-employers-to-drop-esi/comment-page-1/#comment-54208</link>
		<dc:creator>Art As Social Inquiry</dc:creator>
		<pubDate>Wed, 02 May 2012 02:16:56 +0000</pubDate>
		<guid isPermaLink="false">http://www.healthreformgps.org/?p=5394#comment-54208</guid>
		<description>Second that.  Large firms that can avoid paying insurance premiums are already doing it by hiring part time.  I do not expect a big exodus by large employers. 

Small employers are dropping coverage altogether now. They are squeezed out of the market by outrageous premium hikes if somebody in their small risk pool actually uses the insurance a lot.</description>
		<content:encoded><![CDATA[<p>Second that.  Large firms that can avoid paying insurance premiums are already doing it by hiring part time.  I do not expect a big exodus by large employers. </p>
<p>Small employers are dropping coverage altogether now. They are squeezed out of the market by outrageous premium hikes if somebody in their small risk pool actually uses the insurance a lot.</p>
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		<title>Comment on Contraception Coverage under the ACA’s Preventive Services Coverage Requirements, and Employer Implementation: An Update by Jack Cameron</title>
		<link>http://www.healthreformgps.org/resources/contraception-coverage-under-the-acas-preventive-services-coverage-requirements-and-employer-implementation-an-update/comment-page-1/#comment-53994</link>
		<dc:creator>Jack Cameron</dc:creator>
		<pubDate>Tue, 01 May 2012 12:55:44 +0000</pubDate>
		<guid isPermaLink="false">http://www.healthreformgps.org/?p=5240#comment-53994</guid>
		<description>Having been Executrive Director of a Catholic Charities organization, I understand the conflict with personal and religious values.   However, the health care needs of those employees are also very important.  In our organization, 82% of of income came through Medicaid or other government payor sources.   It seems to me that when religious organizations are predominently funded by government, they forfeit much of that argument that they are &quot;religious organizations&quot;.   So, if the Diocese is only contributing 18% to the budget, it appears to be a stretch to call yourself a religious institution.   Where I worked, most of our employees and clients were not Catholic and overwhelmingly wanted contraception.</description>
		<content:encoded><![CDATA[<p>Having been Executrive Director of a Catholic Charities organization, I understand the conflict with personal and religious values.   However, the health care needs of those employees are also very important.  In our organization, 82% of of income came through Medicaid or other government payor sources.   It seems to me that when religious organizations are predominently funded by government, they forfeit much of that argument that they are &#8220;religious organizations&#8221;.   So, if the Diocese is only contributing 18% to the budget, it appears to be a stretch to call yourself a religious institution.   Where I worked, most of our employees and clients were not Catholic and overwhelmingly wanted contraception.</p>
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		<title>Comment on Legal Challenges to the Affordable Care Act: Tabular Summary of Supreme Court Amicus Briefs by Deborah Kelch</title>
		<link>http://www.healthreformgps.org/resources/summary-of-amicus-briefs/comment-page-1/#comment-47394</link>
		<dc:creator>Deborah Kelch</dc:creator>
		<pubDate>Mon, 26 Mar 2012 14:14:58 +0000</pubDate>
		<guid isPermaLink="false">http://www.healthreformgps.org/?p=5021#comment-47394</guid>
		<description>This is great!  Thanks for organizing it....</description>
		<content:encoded><![CDATA[<p>This is great!  Thanks for organizing it&#8230;.</p>
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		<title>Comment on HHS releases advanced NPRM on preventive services policy by Shireen</title>
		<link>http://www.healthreformgps.org/resources/hhs-releases-advanced-nprm-on-preventive-services-policy/comment-page-1/#comment-46763</link>
		<dc:creator>Shireen</dc:creator>
		<pubDate>Tue, 20 Mar 2012 14:09:18 +0000</pubDate>
		<guid isPermaLink="false">http://www.healthreformgps.org/?p=4974#comment-46763</guid>
		<description>Access to preventive services is key to women&#039;s health.</description>
		<content:encoded><![CDATA[<p>Access to preventive services is key to women&#8217;s health.</p>
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		<title>Comment on State Health Insurance Exchange Navigators by Brandon</title>
		<link>http://www.healthreformgps.org/resources/state-health-insurance-exchange-navigators/comment-page-1/#comment-45528</link>
		<dc:creator>Brandon</dc:creator>
		<pubDate>Mon, 12 Mar 2012 19:00:31 +0000</pubDate>
		<guid isPermaLink="false">http://healthreformgps.org/?p=2668#comment-45528</guid>
		<description>&quot;More competition will drive down costs and exchanges will give individuals and small businesses the same purchasing power big businesses have today,&quot; Health and Human Services Kathleen Sebelius said in a statement.

I guess more companies will appear overnight and they will be able to compete with these large companies that are already competing ??? REALLY ?</description>
		<content:encoded><![CDATA[<p>&#8220;More competition will drive down costs and exchanges will give individuals and small businesses the same purchasing power big businesses have today,&#8221; Health and Human Services Kathleen Sebelius said in a statement.</p>
<p>I guess more companies will appear overnight and they will be able to compete with these large companies that are already competing ??? REALLY ?</p>
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		<title>Comment on Center for Medicare and Medicaid Innovation by Johnny Warren</title>
		<link>http://www.healthreformgps.org/resources/center-for-medicare-and-medicaid-innovation/comment-page-1/#comment-44419</link>
		<dc:creator>Johnny Warren</dc:creator>
		<pubDate>Tue, 06 Mar 2012 17:02:41 +0000</pubDate>
		<guid isPermaLink="false">http://healthreformgps.org/?p=762#comment-44419</guid>
		<description>If Medicare would start paying transportation for wheel chair bound patients plus non-ambulatory patients to go to the doctor, then in the long-term, you would see a reduction in health cost.  A lot of people don&#039;t go to the doctor because of the cost associated with ambulance and wheel chair transportation</description>
		<content:encoded><![CDATA[<p>If Medicare would start paying transportation for wheel chair bound patients plus non-ambulatory patients to go to the doctor, then in the long-term, you would see a reduction in health cost.  A lot of people don&#8217;t go to the doctor because of the cost associated with ambulance and wheel chair transportation</p>
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		<title>Comment on Immediate Private Health Insurance Reforms by Health Insurance Exchanges Update: Qualified Health Plans, Reinsurance, Risk Corridors and Risk Adjustment &#8211; Health Reform GPS: Navigating the Implementation Process</title>
		<link>http://www.healthreformgps.org/resources/immediate-private-health-insurance-reforms/comment-page-1/#comment-16194</link>
		<dc:creator>Health Insurance Exchanges Update: Qualified Health Plans, Reinsurance, Risk Corridors and Risk Adjustment &#8211; Health Reform GPS: Navigating the Implementation Process</dc:creator>
		<pubDate>Thu, 15 Sep 2011 21:12:12 +0000</pubDate>
		<guid isPermaLink="false">http://healthreformgps.org/?p=738#comment-16194</guid>
		<description>[...] Through the Exchanges, qualified small businesses and individuals will have a choice of private health insurance plans and access to information that permits comparison of available health insurance plans. In the event that a state chooses not to establish state-based Exchanges, the Secretary of HHS is authorized to establish an Exchange either directly or by contracting with a non-profit organization to assure that residents of every state have access to an Exchange. The ACA also includes provisions to assure rate stability and to mitigate adverse selection in the event that some plans enroll a disproportionate share of high-cost individuals. For more detailed background information and a detailed explanation of changes made by the ACA, see the previous implementation briefs on Exchanges and insurance market reforms. [...]</description>
		<content:encoded><![CDATA[<p>[...] Through the Exchanges, qualified small businesses and individuals will have a choice of private health insurance plans and access to information that permits comparison of available health insurance plans. In the event that a state chooses not to establish state-based Exchanges, the Secretary of HHS is authorized to establish an Exchange either directly or by contracting with a non-profit organization to assure that residents of every state have access to an Exchange. The ACA also includes provisions to assure rate stability and to mitigate adverse selection in the event that some plans enroll a disproportionate share of high-cost individuals. For more detailed background information and a detailed explanation of changes made by the ACA, see the previous implementation briefs on Exchanges and insurance market reforms. [...]</p>
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		<title>Comment on Legal Challenges to the Affordable Care Act by Federal appeals court rules state of virginia lacks in health reform challenge &#8211; Health Reform GPS: Navigating the Implementation Process</title>
		<link>http://www.healthreformgps.org/resources/health-reform-and-the-constitutional-challenges/comment-page-1/#comment-16131</link>
		<dc:creator>Federal appeals court rules state of virginia lacks in health reform challenge &#8211; Health Reform GPS: Navigating the Implementation Process</dc:creator>
		<pubDate>Tue, 13 Sep 2011 22:57:34 +0000</pubDate>
		<guid isPermaLink="false">http://healthreformgps.org/?p=1972#comment-16131</guid>
		<description>[...] For more information of legal challenges to the ACA, click here. [...]</description>
		<content:encoded><![CDATA[<p>[...] For more information of legal challenges to the ACA, click here. [...]</p>
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		<title>Comment on Legal Challenges to the Affordable Care Act by District court rules individual mandate unconstitutional &#8211; Health Reform GPS: Navigating the Implementation Process</title>
		<link>http://www.healthreformgps.org/resources/health-reform-and-the-constitutional-challenges/comment-page-1/#comment-16130</link>
		<dc:creator>District court rules individual mandate unconstitutional &#8211; Health Reform GPS: Navigating the Implementation Process</dc:creator>
		<pubDate>Tue, 13 Sep 2011 22:39:34 +0000</pubDate>
		<guid isPermaLink="false">http://healthreformgps.org/?p=1972#comment-16130</guid>
		<description>[...] For more information of legal challanges to the ACA, click here. [...]</description>
		<content:encoded><![CDATA[<p>[...] For more information of legal challanges to the ACA, click here. [...]</p>
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