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San Francisco Marin Medical Society Blog

Feedback Requested: CMS Requests Examples of Burdensome Certification/Recertification Requirements

CMS has requested the AMA’s help in identifying opportunities to reduce the administrative burden caused by certification requirements.  In addition, we have heard from some specialty societies about concerns with the development of local coverage decisions (LCDs). In our discussions with CMS the agency appears open to hearing about this issue as well.   Towards that end, we wanted to give the Federation the opportunity to provide feedback on the following:  

CMS Administrative Relief:    We would like the Federation’s help in identifying specific examples of certification requirements/forms that are adding burden to a physician practice, especially those that seem unnecessary.  We are specifically looking for examples related to DME, home health, and other  healthcare services that can only be delivered by certified providers.

Local Coverage Decisions:  We would like the Federation’s help in identifying any broad issues or concerns about the LCD process that we can then take back to CMS.  As an example, we have heard that many specialties would like to be notified before publication of new or revised LCDs that affect their members.

We have told CMS staff that we would provide comprehensive feedback form the Federation on these issues.  Please reply with you feedback by Friday September 29th.  Feel free to contact Jason Scull ( with any questions or concerns.

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