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Comments on Notice of Benefit and Payment Parameters for 2022

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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.

The interdependent nature of the nation’s health care system means that improving coverage and care will not only help individual people and programs, but the system as a whole. Medicare, for example, benefits when new enrollees are insured. These beneficiaries tend to be in better physical and financial shape than their un- or under-insured counterparts, who are more likely to have unmet health care needs. The absence of quality pre-Medicare coverage can lead to reduced well-being for entire families; poorer health; lack of access to care; economic devastation; and higher Medicare costs when they are ultimately eligible. Accordingly, Medicare Rights supports efforts to ensure that all Americans who come to Medicare are transitioning from and have long experienced high quality, affordable coverage.

These factors and perspectives have influenced our comments. We have significant concerns that as written, the proposed rule would undermine efforts to improve coverage rates and quality. It must not be finalized without major changes and assurances that it would not put individual or public health and economic security at risk.

Reference
RIN: 0938-AU18
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