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Comments

Comments on 2022 IPPS Proposed Rule

Comments on the proposed use of an indirect estimation algorithm for racial and ethnic demographics as well as a clarification of the requirement for states to enroll all Medicare-eligible providers for purposes of determining reimbursement.

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Comments on the HCBS Access Act Discussion Draft

If enacted, the HAA would greatly expand access to HCBS, helping people who need supports to stay in their communities, age in place, and live the lives they choose. The Medicaid program must be made more equitable and better meet the needs of those it serves. We are fully committed to this vision and offer the following suggestions to tweak the HAA to better achieve it.

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Comments on Interim Final Rule on MCIT and Definition of “Reasonable and Necessary” (CMS-3372-IFC)

The Medicare Rights Center (Medicare Rights) appreciates this additional opportunity to comment on the Medicare Program; Medicare Coverage of Innovative Technology (MCIT) and Definition of “Reasonable and Necessary”; Delay of Effective Date; Public Comment Period (CMS-3372-IFC) interim final rule. Medicare Rights is a national, nonprofit organization that works to ensure access to affordable health care for older adults and people with disabilities through counseling and advocacy, educational programs, and public policy initiatives. Each year, Medicare Rights provides services and resources to nearly three million people with Medicare, family caregivers, and professionals.
We reaffirm our support for ensuring greater access to appropriate innovative technologies and necessary care for people with Medicare.

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Comments on the Fourth COVID Interim Final Rule

The Families First Coronavirus Response Act (FFCRA), signed into law on March 18, includes an option for states to receive enhanced federal Medicaid funding. In exchange for these additional funds, states must comply with certain maintenance of effort (MOE) protections. These policies are intended to help ensure individuals can access coverage and care during the COVID-19 public health emergency (PHE). Specifically, Section 6008b(3) of the FFCRA requires states to preserve then-current enrollments and benefits through the end of the PHE: “an individual who is enrolled for benefits under such plan (or waiver) as of the date of enactment shall be treated as eligible for such benefits through the end of the month in which such emergency period ends.”

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Comments on SUNSET rule

The COVID-19 public health emergency continues to demonstrate the need for reliable access to health care, especially for older adults and people with disabilities. The pandemic makes it crucial to protect Medicare’s ability to provide guaranteed coverage and meet the changing and urgent needs of the populations it serves. The Department of Health and Human Services (HHS) also must have the bandwidth to shift focus and respond quickly to immediate and emergent issues. Thousands of lives are at stake.

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Comments on Notice of Benefit and Payment Parameters for 2022

As the current COVID-19 public health emergency continues to reveal, the need for health care can arise at any moment and may be the difference between life and death. People without comprehensive health coverage may delay or forgo care, worsening their own and public health outcomes. Those who do seek treatment may face extreme financial hardships, impacting patient, program, and taxpayer costs.

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Comments on Medicare Coverage of Innovative Technology (MCIT) and Definition of “Reasonable and Necessary”

The Medicare Rights Center (Medicare Rights) appreciates this opportunity to comment on the Medicare Program; Medicare Coverage of Innovative Technology (MCIT) and Definition of “Reasonable and Necessary” (CMS–3372–P) proposed rule. Medicare Rights is a national, nonprofit organization that works to ensure access to affordable health care for older adults and people with disabilities through counseling and advocacy, educational programs, and public policy initiatives. Each year, Medicare Rights provides services and resources to nearly three million people with Medicare, family caregivers, and professionals.

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