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Comments on Conditions for Coverage for End-Stage Renal Disease Facilities Third Party Payment (CMS-3337-IFC)

The Medicare Rights Center (Medicare Rights) is pleased to submit comments in response to the Centers for Medicare & Medicaid Services (CMS) interim final rule with comment establishing new requirements for Medicare-certified dialysis facilities that make payments of premiums for individual market health plans for patients with End-Stage Renal Disease (ESRD).

The following comments are informed by our experience assisting individuals with End-Stage Renal Disease (ESRD) and their family members as they navigate the transition to Medicare. Our comments underscore unique enrollment considerations for the ESRD population.

Reference
RIN: 0938-AT11
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