“Finally, the bill proposes the creation of an ombudsman, who would provide information regarding appeals for public consumption,” says Dr. Fahey. The ombudsman’s duties would include providing administrative and technical assistance in filing requests, and publicly posting information on 1) the number of requests or appeals filed with the MAC and 2) the actions taken by the MAC in response. The ombudsman would also provide recommendations to the CMS to improve the appeals process, according to the bill’s text.
Working Toward Better Collaboration
Although it is hard to measure the impact of the lack of transparency in LCDs, “we have experienced situations [in which] a policy has spread from MAC to MAC without a clear explanation about why,” says Dr. Fahey. “The CMS is such a huge organization, and requiring more clarity in how decisions are made at the local level is a great start toward more transparency at the national level, as well.”
Openness and stakeholder engagement in Medicare coverage determinations are critical aspects of evolving national healthcare reform, says Dr. Fahey.
“Having a trusting relationship with CMS and the MAC is crucial to our understanding of the direction that our biggest payer is taking on policies that affect us and our patients,” he says. “We don’t always agree with decisions that are made, but transparency and accountability regarding how and why the policy was created goes a long way toward fostering collaboration.”
Susan Bernstein is a freelance journalist based in Atlanta.
