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Regulatory Issues
COCA has focused most of its energy and resources over the past two years on the PE RVU changes embedded in the proposed CMS 2007-2010 Physician Fee Schedules. The simple reason for this focused effort is because the draconian cuts for outpatient cath lab procedures caused by the PE RVU changes would result in the closure of most, if not all of these facilities if these cuts are allowed to stand.
The attached documents describe the actions that COCA has taken over the last several months to demonstrate the reason the proposed changes are flawed and provide a workable solution to the problem.
COCA 2011 PFS Final Rule Comment Letter to CMS 1-3-11
Comparison of 2007-2011 Medicare APC & PFS for LHC 1-2-11
Comparison of 2010-2011 Medicare PFS for LHC and PVI 12-12-10
Cardiovascular Business OPCL Article - April 2010
COCA Congressional Talking Points – April 2010
Cardiovascular Business OPCL Article - September 2008