AARC/RT Comments Noted in Final Regs on Inpatient Hospital PPS

August 24, 2007

AARC comments on ventilator-associated pneumonia (VAP) and RT-related comments on smoking cessation counseling have captured the attention of the Centers for Medicare and Medicaid Services (CMS). Summaries of both appear in the recently released final regulations on the inpatient hospital PPS.

The AARC comments are recognized in a portion of the document on a proposal to include VAP in the CMS prevention guidelines for hospitals. The Association noted tracking VAP is a good idea and provided a copy of its Clinical Practice Guideline on VAP to illustrate strategies that can be used to prevent the condition, but urged more study before including VAP in the guidelines.

CMS responded by summarizing the comments, and even included a direct link to the CPG in the final regulations. It also agreed with the AARC comments, and those of other commenters, opting not to include VAP in the guidelines at this time, in part because an ICD 9 CM code for VAP has yet to be developed.

The smoking cessation comments, which appear later on in the document in a section related to reportable measures under the pneumonia topic, note respiratory therapists are acknowledged experts in providing smoking cessation counseling. CMS affirmed the importance of providing preventive services such as smoking cessation counseling and encouraged hospitals to develop system approaches that would include team members such as respiratory therapists to provide this patient education.

“It is nice that CMS recognized our VAP comments, noted the importance of RTs in smoking cessation counseling, and even included a link to our CPG,” says AARC Director of Government Affairs Cheryl West. “That is a tip of the hat to the AARC and to the entire respiratory care profession.”