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CHA submitted comments to the Centers for Medicare & Medicaid Services (CMS) this week regarding establishing an independent review process for assessing appropriate physician supervision levels for individual outpatient therapeutic services. The comment letter is in response to CMS’ request for input on how the review process should function, as well as for suggestions on entities to serve on a technical expert panel that would provide further input.
CHA called on CMS, before instituting stricter regulations, to provide clinical evidence and documentation that demonstrates there is a need for increased personal supervision by physicians. CHA also urged CMS to create a new entity, representing all providers including rural and Critical Access Hospitals, that would craft recommendations.
CHA’s comment letter is attached below.
