The Medicare Rights Center (Medicare Rights) is pleased to submit comments on the Notice of Denial of Medical Coverage (or Payment) (Integrated Denial Notice). 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. Medicare Rights provides services and resources to three million people with Medicare, family caregivers, and professionals each year.

The following comments are informed by our experience working with Medicare beneficiaries and their families, as they navigate both the Medicare and Medicaid appeals processes. They are also informed by our work in New York State, where we have worked closely with the Department of Health on the implementation the Fully Integrated Dual Advantage (FIDA) program through our leadership on the Coalition to Protect the Rights of New York’s Dually Eligible (CPRNYDE). CPRNYDE successfully advocated for a single integrated appeals process in FIDA, allowing beneficiaries to appeal both Medicare and Medicaid denials without having to distinguish between the two systems. We continue to work closely with New York to finalize rules for the post-FIDA duals plans as well…