June 11, 2012

Submitted Electronically

Marilyn Tavenner
Acting Administrator
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Hubert H. Humphrey Building, Room 445-G
200 Independence Avenue, S.W.
Washington, D.C. 20201

RE: Medicaid Program; Payments for Services Furnished by Certain Primary Care Physicians and Charges for Vaccine Administration Under the Vaccines for Children Program (CMS-2370-P)

Dear Ms. Tavenner:

The New Hampshire Hospital Association (NHHA), on behalf of our 26 member hospitals appreciates the opportunity to comment on the Centers for Medicare & Medicaid Services (CMS) proposed rule implementing the Patient Protection and Affordable Care Act (ACA) provision to increase Medicaid payment for primary care services for certain physicians. The proposed rule also updates the payment rates for providers for the administration of pediatric vaccines through the federal Vaccines for Children Program.

State Medicaid programs, including the program here in New Hampshire, have historically underfunded providers, including providers of primary care. The ACA recognizes the importance of primary care services and sets a course to improve access by requiring Medicaid to reimburse primary care providers at parity with Medicare rates in 2013 and 2014 with full financing by the federal government. This ACA provision is an important acknowledgement that payment levels are linked to access for the Medicaid population and improving access to primary care is going to be critical as the Medicaid program is expanded in 2014. The following are specific comments related to the proposed rule.

The NHHA supports CMS's proposal to expand the payment increase for primary care services to related subspecialists. The ACA specifies that the payment increase apply to certain primary care services furnished by a physician with a specialty designation of family medicine, general internal medicine or pediatric medicine. By extending the specialty designations to the relevant subspecialists in accordance with the American Board of Medical Specialties, the payment increase will apply to such subspecialties as gastroenterology, critical care, pediatric cardiology and pediatric critical care. The NHHA also supports CMS's proposal to allow non-physician providers, such as nurse practitioners and physician assistants, to qualify for the higher payment if they deliver primary care services under the personal supervision of an eligible physician and bill under the provider number of the physician. These proposals appropriately extend the payment increase to physicians and non-physician providers that deliver primary care services to Medicaid enrollees.

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