The Medicare Rights Center (Medicare Rights) is pleased to submit comments in response to the Request for Information: Reducing Administrative Burden to put Patients over Paperwork (the RFI). 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.

Medicare Rights appreciates the Patients over Paperwork initiative and supports its stated aims. In our response to this RFI, we are particularly focused on Centers for Medicare & Medicaid’s (CMS’s) specific request for suggestions to ease the burdens placed on beneficiaries who are dually eligible for Medicare and Medicaid (“dual eligibles”) and suggestions for simplification of enrollment and eligibility determinations across programs. Low-income beneficiaries can find paperwork particularly challenging as many have relatively low health literacy and often face significant health challenges. This can limit their ability to handle documentation and timely respond to complex income and asset requests or to provide information supporting appeals, requests for waivers, or rate reductions.