Washington, DC 20036
March 23, 2001
Representative Nancy L. Johnson
Chair, Subcommittee on Health
House Committee on Ways and Means
1136 Longworth House Office Building
Washington, DC 20515-6349
Dear Representative Johnson:
On behalf of Mayo Foundation, I would like to submit this information for the record of the Health Subcommittee hearing of March 15, 2001: "Medicare Reform: Bringing Regulatory Relief to Beneficiaries and Providers."
At the hearing, Representatives Stark and Kleczka raised questions relating to the number of pages of Medicare rules and regulations. The source of the numbers referenced in the testimony of several witnesses is an estimate made by Mayo in 1998. The original breakdown of the numbers of pages of regulations and supporting documents, as estimated by Mayo, is attached for the record. This estimate was made in 1998, so it does not include most of the thousands of pages of rules implementing the Balanced Budget Act of 1997. Nor does the total include any number for some of the listed categories for which we were unable to make estimates. We therefore believe this estimate significantly underestimates the real number.
Questions were raised at the hearing concerning the accuracy of the Mayo numbers, and it was stated that HCFA estimated a much smaller number of pages - in the range of 35,000. We stand by the accuracy of our estimate, noting as we have in the past that we are including all Medicare rules, manuals, and other guidance documents that are necessary for providers to deal with the Medicare program. We have circulated our list publicly, and in fact it was included in a publication of the House Budget Committee in May 2000 ("Budget Committee Task Force on Health: Medicare's Regulatory Burden on Providers", Hearing Press Kit, May 18, 2000).
We also believe that there is no point in engaging in an argument with HCFA or anyone else over the definitions of "rules" or the exact number of pages of such. The important points we intended to raise with this count are:
(1) There is a major regulatory overload in Medicare.
(2) The rules are spread out over numerous sources, making it even more difficult to know all the rules that may apply.
(3) Many carrier and intermediary rules vary among the different areas of the country.
Rather than debating the numbers, we believe it is time to move forward to finding solutions to these problems. For that reason, we salute your efforts in holding the hearing: "Medicare Reform: Bringing Regulatory Relief to Beneficiaries and Providers." We are ready to assist you and the Health Subcommittee in any way to improve the Medicare program for beneficiaries and providers alike.
Bruce M. Kelly
Director of Government Relations
Medicare Regulations and Supporting Documents
|Medicare Laws and Related Laws (SSA and 350 Amendments)||706|
|Fraud and Abuse Regulation||14,500|
|BBA of 1997 (statute only)||800|
|Medicare Regulations (42 CFR)||3,574|
|21 HCFA Manuals||10,500|
|HCFA Federal Registers||30,000|
|Carrier Part B Manuals||500|
|Correct Coding Manual||340|
|Intermediary Medicare Bulletins||2.250|
|Medicare Administrative Bulletins||5,000|
|BCA Administrative Bulletins||2,500|
|HCFA Intermediary Letters|
|HCFA Carrier Letters|
|HCFA Intermediary/Carrier Letters|
|HCFA Administrator Decisions||2,000|
|OIG Federal Registers ('94-'98)||1,000|
|OIG Workplan and Compliance Program Guidance||170|
|RHC Billing Carrier Instruction manual||300|
|HCFA Advisory Opinions|
|AHA Coding Clinics for ICD9||1,920|
|CPT Coding Book||588|
|State Department of Health Interpretive Guidelines||30|
|GAO Reports on Medicare||2,000|
Other Government Agencies
|Laws, Regulations, Manuals, State Registers, Enrollment Agreements|