During the 2016 legislative session the Reimbursement Unit received a lot of push back from hospitals related to its proposed policy to eliminate Provider Based Billing (PBB), with specific complaints on the length of the public comment period. In this case, public comment was posted to the Global Commitment Register on February 13, 2016 and slated to run until February 29th (Leap Year), a total of 17 days. The new policy was to have been implemented on March 1, 2016.
While Vermont Medicaid does not have a specific policy related to the length of a public comment period, it has followed Medicare guidelines which states public comment should be posted for a "reasonable" length of time. As a result, the Reimbursement Unit has established the goal that 100% of annual fee schedule/policy change updates will be posted for public comment 30 days prior to the effective date of the rate or policy change.
It is important to stakeholders to be able to analyze and review proposed changes prior to their implementation so that they can familiarize themselves with the changes and analyze how it effects their operations. It also gives stakeholders the opportunity to be engaged in the process and provide feedback to the State. Medicaid Reimbursement appreciates the benefits of being able to work collaboratively with partners and stakeholders so that we can all work together effectively to provide the best health care possible at a reasonable cost to Vermont residents.
For 2020, the target of 30 day public notice prior to rate updates was not met for the following reasons 1) waiting for State Budget to be signed and 2) rate modeling not completed in a timely manner allowing for PBR completion and posting of public comment to meet our 30 day goal. We will continue with our efforts to meet this goal in the future.
Last updated: 07/15/2020
Author: Reimbursement Unit