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<strong>CMS</strong>-1403-FC<br />

additional rental payments for the remainder of the<br />

equipment’s reasonable useful lifetime. It is difficult to<br />

estimate the impact of this change, but we believe the<br />

impact will be minimal and, therefore, do not believe it<br />

will be economically significant.<br />

In addition, our regulations implementing MIPPA may<br />

provide a slight financial benefit to Medicare because we<br />

have determined that at this time it is not reasonable and<br />

necessary to make payments for non-routine maintenance and<br />

servicing (including repair) of supplier-owned oxygen<br />

equipment. We understand that oxygen equipment is very<br />

durable and should need few repairs in the first 5 years.<br />

Any costs suppliers may incur in repairs would be offset by<br />

the gains they achieve through retaining ownership of the<br />

equipment. Taken together, we expect these changes to have<br />

a minimal impact on Medicare expenditures.<br />

10. Section 145: Clinical Laboratory Tests<br />

Section 145 of the MIPPA reduces the Clinical<br />

Laboratory Fee Schedule update by 0.5 percentage points for<br />

each year, CY 2009 through CY 2013, and is estimated to<br />

result in an incurred benefit savings of $40 million.<br />

11. Section 146: Improved Access to Ambulance Services<br />

Section 146 of the MIPPA makes certain changes to<br />

Medicare payment for ambulance services. Specifically,<br />

this section: increases the payment rate under the<br />

1085

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