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Medicare Improvements for Patients and Providers Act of 2008 (MIPPA) During the FNCE meetings in Chicago, our ADA Washington office staff provided all practice groups with the following valuable information about the Medicare Improvements for Patients and Providers Act of 2008.
What the New Law (MIPPA) Means to Medicare MNT Providers
The Medicare Improvements for Patients and Providers Act of 2008 (MIPPA), Public Law 110-275, goes into effect January 2009. It amends titles XVII and XIX of the Social Security Act and is now part of the Unites States Code. The expansion of MNT is a key amendment that improves access to preventive care.
Specifics of the New Law
Coverage, payment and coinsurance aspects of the additional Medicare preventive services is specified. Additional services can be authorized if the Secretary of Health and Human Services determines that the services are:
- Reasonable and necessary to the prevention or early detection of an illness or disability
- Recommended with a grade A or B by the United States Preventive Services Task Force (USPSTF)
- Appropriate for individuals entitled for entitled to benefits under part A or enrolled in part B of Medicare.
An additional service can be implemented after the HHS Secretary has conducted a National Coverage Determination to determine the cost-effectiveness of any new service that decides to cover it. Payment for additional preventive services will be 80 percent of the lesser of the actual charge for the service, or the amount determined under a fee schedule. The Centers for Medicare and Medicaid services will advise the HHS Secretary on matters of coverage and payment.
The United States Preventive Services Task Force Recommendations
Published in 2003, Counseling for a Healthy Diet, a USPSTF systematic review of the literature and recommendations, stated the following: “The USPSTF recommends intensive behavioral dietary counseling for adult patients with hyperlipidemia and other known risk factors for cardiovascular and diet-related chronic disease. Intensive counseling can be delivered b y primary care clinicians or by referral to other specialists, such as nutritionist or dietitians. Rating: “B” recommendation.
What Is A National Coverage Determination (NCD)?
NCDs are made through an evidenced-based process and opportunities for public participation. In some in cases, including the case of the new law, CMS’s research is supplemented by an outside technology assessment and/or consultation with the Medicare Evidence Development & Coverage Advisory Committee (MEDCAC). (USPSTF recommendations are supported by the outside technology assessment and are evidence-based.)
How Long Does It Take To Get A Coverage Determination?
Once the NCD request is proposed by ADA, CMS determines if additional evidence is required to make a coverage decision. If additional evidence is not needed, the process may take 6 months; if CMS feels that additional evidence is needed, the NCD process may take 9-12 months.
When Can Dietitians Start Billing?
The law goes into effect January 2009, and requires that the HHS Secretary conduct a National Coverage Determination to decide if covering the additional services is reasonable and necessary.
It is not clear if RDs will be the sole providers of this service. CMS has requested evidence that would justify allowing only RDs to bill for these services.
Key Milestones and Expected Timeline
New laws require a determination of how to interpret and implement the letter and spirit of the statutes. At the initial meeting with ADA, CMS admitted that it was too early to know exactly how NCD requests for additional preventive services would be handled after they were received, and how they would be prioritized for review.
ADA is preparing the NCD request, which is a proposal document with supporting systematically-reviewed evidence to justify expanding the services. ADA intends to submit this request during the first half of 2009.
The following dates have been clearly defined by CMS:
November, 2008: Federal Register publication of the regulations that clarify the
MIPPA process and implementation, including additional preventive services
January, 2009: Law goes into effect. CMS will now accept MIPPA-related requests.
Once CMS issues a favorable decision, registered dietitians who are Medicare providers will be issued guidance on the new coverage decision, including billing instructions.
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