ADVOCACY

Please contact us if you have questions, comments or want to help the advocacy team.
EMAIL HERE or call 888-892-2732

September 1, 2020
Q. Any updates on R Code initiative?
A. APDA will hold a web go to meeting on Friday, 9/11, at 1 PM eastern standard time (EST) for MEMBERS ONLY. The purpose of the call is to bring you up-to-date on APDA’s progress on its regulatory and legislative goals and to ask your help in achieving them.
Sign-on letter: We are asking members of Congress to sign-on to a letter to CMS directing the agency to:

Pause all R-Code reimbursement reviews until the end of the pandemic.
Adjust all R-Code transportations rates to cover the added costs of Covid-19 for the duration of the pandemic.
Revisit the process for computing the R-Code for the purpose of developing a transparent methodology which insures adequate reimbursement.

Legislation: Because CMS has told APDA that it doesn’t have the necessary authority, we will be seeking potential Senate & House sponsors for a bill to remove PXR from Consolidated Billing.Our consultants, Laura Bozell and Chris Sarley, from Cornerstone Government Affairs (CGA), will be guiding these initiatives in two stages: (1) virtual visits to a handful of primarily Senate offices and (2) advocacy emails from you to Congressional members in the House & Senate in those states where you have operations. Some of you, particularly those who were active in the Washington, DC visits in December 2019, will be invited to join the virtual visits. All of you will be asked to craft personalized emails from templates prepared by CGA requesting Congressional support for our “Asks.”
APDA URGES ANY PORTABLE X-RAY PROVIDER THAT IS NOT A MEMBER TO JOIN TODAY! IT IS VITAL THAT ALL INDUSTRY PARTNERS PARTICIPATE AND SUPPORT THE FUTURE OF PORTABLE DIAGNOSTICS!

July 30, 2020
Q. I understand APDA has brought on a new lobby group, Cornerstone. What is CSG's plan for pxr representation and initiatives?
A. Your APDA Board has been working tirelessly over the last few months to represent every member around the country. Cornerstone has quickly helped us understand possible “Champions” on the Hill that could help all of our current efforts. With help from Cornerstone, we are again asking CMS the following:

Request that CMS pause any rate reviews until after the pandemic
Work with APDA and PXR companies to develop a transparent and practical methodology for adequate reimbursement for portable diagnostics
Asked that they consider, due to our updated cost data from all of you, an immediate increase of 20% to all transportation codes to help offset our cost of COVID-19. The Board, along with CGA is currently scheduling Congressional meetings and will be reaching out to you to take advantage of past communications with your Senators and House representatives. Although it is a difficult time, we believe PXR companies are being heard and that we are gaining champions from many different areas and parts of the country that are pushing for our industry.Please be looking for updates from APDA and CGA. If you have any concerns, questions or assistance, please reach out to any of the Executive Committee or Board directly.

May 25, 2020

Q. Is APDA working for members in other regions against such R code cuts?
A. Yes, APDA has made a push for fair evaluation of the Rcode reimbursement for ALL regions.

APDA is collaborating with the R-Code Standing Committee, consisting of APDA and other industry partners for the next phase of our lobbying initiatives with CMS and Congressional offices. In April, we spoke directly to the Office of CMS Administrator Seema Verma about our requests and believe we made a strong case for CMS to act. The next phase of our effort focuses on applying pressure to CMS to direct Novitas and the other MACs to implement our requests. We expect a response from CMS within the next 2 weeks, after which time we will evaluate the need to engage more members of Congress directly and through a grassroots effort by PXR providers. We will keep you informed about those initiatives and anticipate mid-June to be a critical time for this initiative.Be assured that your APDA Executive Committee is fighting to protect the interests of all PXR providers. Do not hesitate to contact us with questions.

May 13, 2020
Q. Are there any updates to the R code cuts?
A. APDA is working diligently to fight these cuts and any future cuts. These proposed cuts have led to the formation of the R-Code Standing Committee, consisting of APDA and other industry partners such as the National Association for the Support of Long-Term Care (NASL). That Committee meets weekly to formulate our industry’s regulatory and legislative strategy with respect to these rate cuts in the time of COVID-19. Your President, Will Irwin, and your President-Elect, Ryan Kingrey, participate in every single meeting. The collaboration has resulted in letters dated 3/31/2020 to Novitas and to CMS dated 04/22/2020. Our “Asks” of Novitas and CMS are somewhat different but can be summarized below:

Pause any pending portable x-ray transportation rate reviews until after the COVID-19 emergency subsides
Implement a 10% increase in the portable x-ray transportation rate for the duration of the COVID-19 outbreak
Recognize the dramatic increase in demand for EKGs and echocardiograms for which there is no transportation fee paid
Understand that without these measures PXR companies will have no choice but to reduce services hours, days, and distances traveled as they reduce staff.
Recognize the PXR company technologists are front line health care workers, who at great risk, perform critical diagnostic tests on the residents of LTCFs aimed at preventing unnecessary and dangerous transfers to the Emergency Room and/or Hospital
Recognize that PXR should not be part of consolidated billing and that PXR charges are a small part of MPFS allowed charges (<0.1%)

March 25, 2020
Q. Novitas has proposed a huge cut in the R code, what is APDA doing to help its members?
A. Please see letter from APDA President

Dear APDA Members and Industry Partners,

This APDA Action Alert contains two important updates:

(1) Novitas reassessment of portable x-ray (PXR) transportation rates in Jurisdictions JH and JL, and (2) an action alert for providers to engage with their elected representatives and state-based stakeholders to secure a 10% transportation fee increase in ALL states and a pause in any MAC rate reviews due to the COVID-19 pandemic.

APDA has prepared instructions to assist you with this grassroots effort and we are asking providers in ALL states to reach out to their Members of Congress.

R-Code Changes in Novitas Jurisdictions JH/JL

As you are aware, Novitas is currently reevaluating the transportation payment rates for PXR in the following states: Arkansas, Colorado, Louisiana, Mississippi, New Mexico, Oklahoma, Texas, Delaware, Maryland, New Jersey, Pennsylvania, and the District of Columbia.

APDA Leadership along with the Dumbarton Group, convened a conference call with Novitas principals last week. This update covers some initial thoughts about what transpired between the APDA team and Novitas decision-makers.

During our call, APDA firmly stated our position that Novitas should:

Maintain current rates until such time as new adequate rates for each state can be developed
Ensure Medicare beneficiaries maintain access to timely portable x-ray services
Create determinate, predictable reimbursement for providers
Reject a “flat rate” application and take into consideration real variances between the 11 states and District of Columbia

While this issue remains fluid and the final outcome is unclear at this time, APDA’s meeting with Novitas resulted in the following:

Novitas was complimentary about APDA’s collection efforts and our ability to increase industry participation with submitting detailed data
Novitas confirmed the March 31, 2020 data collection period was still intact
Novitas requested APDA to secure additional PXR companies cost data to increase industry participation
Novitas would continue to work with APDA and other stakeholders during the review process
Novitas provided the following timeline they will likely follow:
Data collection period will expire on March 31, 2020
Novitas will take 30-60 days to review data it received from all industry providers
After a comprehensive review, Novitas will release new rates for each of the 11 states and DC
Once the new rates are announced, the effective date will most likely begin 6 weeks from the date of the announcement
Novitas indicated a single “flat rate” across all 11 states and DC would NOT occur. Novitas acknowledged there are geographic and demographic differences that create unique costs for each state.

During the meeting, APDA also reviewed a joint ADPA/National Association for the Support of Long-Term Care (NASL) letter to CMS on COVID-19 where we call upon CMS to:

Immediately provide a 10% increase to PXR transportation rates in all Medicare jurisdictions while heightened infection control procedures are in place, and
Pause all current Medicare Administrative Contractors (MAC) action on the reevaluation of PXR transportation rates for no less than six months or until the COVID-19 outbreak subsides.

We anticipate meeting with CMS, along with our allied stakeholders, to press for action on both the R-code and a fee increase due to COVID-19.

Action Items for APDA Members

APDA is asking all members to remain engaged in grassroots efforts to promote the new phase of this initiative and we have prepared instructions to assist you. We are specifically asking members to:

Contact your respective Members of Congress and ask them to reach out to CMS and promote:
Providing a 10% increase to PXR transportation rates in all Medicare jurisdictions while heightened infection control procedures are in place
Pausing all current Medicare Administrative Contractors (MAC) actions on the reevaluation of PXR transportation rates for no less than six months or until the COVID-19 outbreak subsides.
Reach out to state stakeholders and ask if they will write CMS and promote our new requests as stated above.

APDA remains hopeful with resolute efforts of our members and industry partners we can receive a positive outcome and secure rates that are palatable to all 50 states. APDA will continue to update members on this fluid issue that has a tremendous impact to our industry.

Respectfully,

Will Irwin

APDA President

Click here for INSTRUCTIONS
Click here for APDA/NASL LETTER

APDA ADVOCACY ISSUES:

Ask for CMS to approve code 99072 allowing reimbursement for Covid expenses for Portable Diagnostics

Novitas steep cuts to Portable X-ray transportation rates

2021 6% Medicare reimbursement cuts

AVOCACY RESOURCES:
U. S. Senate
U. S. House of Repesentatives
Legislation and Records, Floor Activity & Calendars