SBA Sends Comments to CMS on Proposed Rebasing Rule
Tuesday, September 17, 2013
by: Policy Team

Section: Public Policy and Advocacy

The Office of Advocacy for the Small Business Administration (SBA) recently sent a letter to the Centers for Medicare and Medicaid Services (CMS) raising concerns about the proposed home health prospective payment system rate update for CY 2014. Prior to sending the letter, VNAA, NAHC and the Partnership met to encourage SBA to weigh in with CMS.   

SBA questioned the methodologies and assumptions underlying CMS’s economic analysis and noted:   
·    CMS certified that this rule will not have a significant economic impact on a substantial number of small entities but has not provided a factual basis for this certification.
·    The assumptions utilized by CMS in the proposed rule and the discussion of possible alternative approaches may result in industry uncertainty regarding how the regulation will impact providers in CY 2014 and beyond to CY 2017.
SBA concluded its comments by requesting that CMS take SBA’s concerns into consideration as the agency finalizes the rule.

Read the SBA's full comments
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