Philips Healthcare submitted comments to CMS August 25, 2008, on the proposed Medicare Physician Fee Schedule and related policy changes for calendar year 2009. Philips expressed concerns and recommendations in a variety of areas, including the following:
- Urged CMS to refrain from imposing IDTF credentialing requirements on physician offices.
- Opposed a CMS proposal that would extend the anti-mark-up prohibition to services provided directly by physician practices, rather than outside suppliers.
- Requested clarification on how the cap on diagnostic imaging services and the multiple procedure reduction required by the Deficit Reduction Act will be applied under the Physician Fee Schedule and the Hospital Outpatient Prospective Payment rule for 2009.
- Urged inclusion of remote critical care services in the list of approved telehealth services, citing data supporting the clinical utility of remote critical care services.
- Supported efforts by the American College of Cardiology and the Remote Services Provider Group to increase the relative value units, or RVUs, for holter monitoring, and supported the proposed change in the equipment utilization assumption for cardiac event monitoring.
- Urged CMS to authorize Medicare coverage for the four new cardiac MRI codes that involve blood flow/velocity.
To read the Philips comments, please 
click here.