Submitted Online (www.townhall.com) and Sent Via Email (Emily.McClellan@dmas.virginia.gov)
September 10, 2020
Emily McClellan
Virginia Department of Medical Assistance Services
600 E. Broad St., Suite 1300
Richmond, VA 23219
Re: Virginia Hospital & Healthcare Association
Public Comment on Physician Manual Chapters IV, V
Virginia Hospital & Healthcare Association (“VHHA”) appreciates the opportunity to submit comments to the Virginia Department of Medical Assistance Services (“DMAS”) in response to its General Notice regarding draft Physician Manual Chapters IV, V posted on August 11, 2020. The draft changes to Chapters IV, V relate to implementation of reimbursement changes directed by Item 313.AAAAA of HB30 (the “Budget Bill”), which alters Medicaid reimbursements for certain emergency department (“ED”) claims (the “Reimbursement Change”).
On June 19, 2020, VHHA submitted public comment in response to the DMAS Notice of Intent to Amend the Virginia State Plan for Medical Assistance posted on May 20, 2020, for the purpose of implementing the Reimbursement Change. In its public comment in response to that notice, VHHA expressed its opposition to the Reimbursement Change and related State Plan Amendment. Because this General Notice relates to the same subject matter as the proposed State Plan Amendment, VHHA is opposed to the draft changes to Physician Manual Chapters IV, V for the same reasons stated in our public comment on June 19, 2020.
For your reference, please find enclosed a copy of the public comment submitted on June 19, 2020, expressing our opposition to the Reimbursement Change.
https://townhall.virginia.gov/l/viewcomments.cfm?commentid=80911
To summarize the reasons for our opposition as it relates to the Reimbursement Change and the draft Physician Manual Chapters IV, V:
For all of the reasons stated in our June 19, 2020, public comment and restated herein, VHHA is opposed to the draft Physician Manual Chapters IV, V. Furthermore, to our knowledge the State Plan Amendments for the Reimbursement Change have not yet been approved by the Centers for Medicare & Medicaid Services. Accordingly, it may be premature to amend the Physician Manual at this time.
Thank you again for this opportunity to comment. If you have any questions or require clarifications of our comments, please feel free to contact me at brawlings@vhha.com.
Sincerely,
R. Brent Rawlings
Senior Vice President & General Counsel
Enclosure