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[Your institution’s letterhead][Today’s date]Seema Verma, AdministratorCenters for Medicare & Medicaid ServicesDepartment of Health and Human ServicesAttention: CMS -1736-PPO Box 8013Baltimore, MD 21244-1850Re: CMS - 1736-P: Medicare Program: Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems and Quality Reporting Programs (CY 2021)Comments submitted electronically via Administrator Verma: My name is [name] and I am a [cardiologist/radiologist/hospital administrator/other] from [institution, location]. I appreciate the opportunity to comment on the CY 2021 Medicare Hospital Outpatient Prospective Payment System proposed rule. I am providing this comment in opposition to the proposed rule pertaining to CPT codes 75572, 75573 and 75574, which will result in decreased reimbursement for cardiac CT for the fourth consecutive year. In particular, I am concerned about 75574, coronary CT angiography (CCTA), which has experienced a greater than 30% over the past 3 years.The current payment for 75572-75574 is well below the cost of providing these services, which significantly limits access of this test to Medicare beneficiaries. Accordingly, we would ask CMS to take action to increase reimbursement to levels in line with the actual testing costs.[Suggested message: The value of the test for patient care]Why is CCTA a powerful clinical tool? How has it helped your patients? What role does it serve in patient care? What does the ability to perform this procedure mean to your institution? Provide description of the unique benefits of the test to your patient population, describe coronary CTA, also other types of cardiac CT for structure and function. Consider providing data from literature on unique value/benefits of CCT tests. You can discuss how use of CCTA can be used to avoid expensive downstream tests. How has this test been particularly valuable in the care of patients during the COVID pandemic? [Suggested message: Cost to hospital of providing this test exceeds current payment; it requires extensive hospital resources, including equipment, medication administration, staff time, scanner time, etc.]Provide information about the cost of this test in your institution – if not available, describe why this test utilizes significantly more hospital resources than other single organ CT scans. Resources to mention include: longer exam times, need to administer medications, need to monitor patients on a monitor prior to exam while administering medications, need for more contemporary/costly scanners, need to train technologists, need for ECG monitoring, special injector or contrast that you use for cardiac CT, longer time in exam room, need for special software (i.e. dedicated 3D workstation, or other software needed for cardiac CT. Provide information why a cardiac CT is more similar to other types of stress test than other CT scans, requiring more highly trained technologists, nursing support, administration of cardiac medications, patient monitoring. Describe complexity of cardiac CT[Suggested message: impact on hospital] Provide description of the impact of low CCT payment, which is below cost of providing the exam -- i.e., other more expensive tests ordered instead, institution unable to invest in resources needed for this test. Detail how the low payment for CCT will negatively affect patients. [Suggested message: Concerns about reimbursement levels inhibiting use of CCTACan you describe how low reimbursement rates affect your ability to provide access to this procedure? What do you feel will happen if the inadequacy of reimbursement is not addressed? How might this harm patients?[Optional: Summarize your concerns and request that CMS provide better payment for cardiac CT tests}I am a member of the Society of Cardiovascular Computed Tomography (SCCT). SCCT is submitting comments on the effects of the proposed OPPS cuts to CCT and will provide detailed recommendations for addressing the establishment of a more appropriate payment rate for these services.Thank you for your consideration of these issues. Sincerely,[Your signature] ................
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