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June 11, 2018 Seema Verma Administrator Centers for Medicare and Medicaid Services U.S. Department of Health and Human Services 7500 Security Boulevard, Baltimore, MD  21244 Via Electronic Mail Dear Administrator Verma:  Thank you for the opportunity to meet with you on June 25, 2018 to discuss the Requirements of Participation (RoPs).  In response to your … Read more

June , 2018 Mr. Alex M. Azar. II Secretary, Department of Health and Human Services Seema Verma Administrator, Centers for Medicare & Medicaid Services Department of Health and Human Services Room 445-G, Hubert H. Humphrey Building 200 Independence Ave., S.W. Washington, D.C.  20201 Re: CMS-1696-P.  Notice of Proposed Rulemaking with Comment.  Medicare Program; Prospective Payment … Read more

May 25, 2018 Via Electronic Submission DPC@cms.hhs.gov Seema Verma, Administrator Centers for Medicare & Medicaid Services U.S. Department of Health and Human Services 200 Independence Avenue, S.W. Washington, DC 20201 RE: Request for Information on Direct Provider Contracting Models Dear Administrator Verma: The Center for Medicare Advocacy (Center) is pleased to provide the Centers for … Read more

Submitted by Center for Medicare Advocacy April 26, 2018 The Center provided the following comments to the Centers for Medicare & Medicaid Services (CMS) in response to an April 12, 2018  Request for Input on the 2019 Medicare Communications and Marketing Guidelines. Section: Other – Miscellaneous Concern about Process.  As a consumer organization seeking to … Read more

April 23, 2018 Via Electronic Submission: Regulations.gov U.S. Department of Health and Human Services 200 Independence Avenue S.W. Washington, DC 20201 RE: Comments on Short-Term, Limited-Duration Insurance Proposed Rule (CMS-9924-P) The Center for Medicare Advocacy (Center) is pleased to provide comments on the proposed rule on short-term limited-duration insurance. The Center, founded in 1986, is … Read more

March 27, 2018 Via Electronic Submission: Regulations.gov U.S. Department of Health and Human Services Office for Civil Rights Attention: Conscience NPRM, RIN 0945-ZA03 Hubert H. Humphrey Building Room 509F 200 Independence Avenue, S.W. Washington, D.C. 20201 RE: Public Comment in Response to the Proposed Regulation, Protecting Statutory Conscience Rights in Health Care RIN 0945-ZA03 The … Read more

Via Electronic Submission: Regulations.gov March 6, 2018 U.S. Department of Labor 200 Constitution Avenue, NW Washington, DC 20210 RE: Definition of “Employer” under Section 3(5) of ERISA – Association Health Plans (RIN 1210-AB85) The Center for Medicare Advocacy (Center) is pleased to provide comments in response to the proposed rule, Definition of “Employer” under Section … Read more

March 5, 2018 Via Electronic Submission to www.regulations.gov Seema Verma, Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services 7500 Security Blvd. Baltimore, Maryland 21244 Re: Advance Notice of Methodological Changes for Calendar Year (CY) 2019 for Medicare Advantage (MA) Capitation Rates, Part C and Part D Payment Policies, and 2019 … Read more

January 25, 2018 Via Electronic Submission: CompetitionRFI@hhs,gov U.S. Department of Health and Human Services Office of the Assistant Secretary for Planning and Evaluation 200 Independence Avenue S.W. Washington, DC 20201 Re: Promoting Healthcare Choice and Competition Across the United States The Center for Medicare Advocacy (Center) is pleased to provide the Office of the Assistant … Read more

January 16, 2018 Via Electronic Submission to www.regulations.gov Seema Verma, Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services Attention: CMS-4182-P P.O. Box 8013 Baltimore, MD 21244-8013 Re: CMS-4182-P – Policy and Technical Changes to the Medicare Advantage and the Medicare Prescription Drug Benefit Programs for Contract Year 2019 Dear Administrator … Read more

November 27, 2017 Submitted Electronically to www.regulations.gov Centers for Medicare & Medicaid Services Department of Health and Human Services Room 445-G Hubert H. Humphrey Building 200 Independence Avenue SW Washington, D.C. 20201 Attn:   CMS-9930-P             NPRM Notice of Benefit and Payment Parameters for 2019 Thank you for the opportunity to comment on the proposed HHS … Read more

November 20, 2017 Via Electronic Submission CMMI_NewDirection@cms.hhs.gov Seema Verma, Administrator Centers for Medicare & Medicaid Services U.S. Department of Health and Human Services 200 Independence Avenue, S.W. Washington, DC 20201 RE: Request for Information on Innovation Center New Direction Dear Administrator Verma: The Center for Medicare Advocacy (Center) is pleased to provide the Centers for … Read more

November 22, 2017 Division of Nursing Homes Survey and Certification Group Center for Medicare & Medicaid Services 7500 Security Blvd. Baltimore, MD 21244 Re: Revised Policies regarding the Immediate Imposition of Federal Remedies-FOR ACTION (S&C: 18-01-NH) Submitted electronically: dnh_triageteam@cms.hhs.gov. Dear David, Karen, Evan, Lisa, and CMS colleagues,    The Center for Medicare Advocacy (Center) is … Read more

Below is a joint statement from Judith Stein, executive director, Center for Medicare Advocacy, and Joe Baker, president, Medicare Rights Center, regarding the Tax Cuts and Jobs Act. As organizations that share a commitment to promoting access to affordable, high-quality health care for older adults, people with disabilities, and their families, we have significant concerns with … Read more

September 25, 2017 Centers for Medicare & Medicaid Services Department of Health and Human Services Attention: CMS-1672-P P.O. Box 8016 Baltimore, Maryland  21244-8016 Submitted electronically to: http://www.regulations.gov Re:      Federal Register Volume 82 No. 144 Medicare and Medicaid Programs: CY 2018 Home Health Prospective Payment System Rate Update and Proposed CY 2019 Case-Mix Adjustment Methodology … Read more

United States Senate Special Committee on Aging Hearing September 20, 2017 Statement Submitted by the Center for Medicare Advocacy The Center for Medicare Advocacy (Center) thanks the Senate Special Committee on Aging for holding the September 20th hearing examining “policies and procedures for sheltering in place, evacuating, and relocating our most vulnerable citizens before disaster … Read more

September 11, 2017 Administrator Seema Verma Centers for Medicare & Medicaid Services Department of Health and Human Services Attention: CMS-1676-P P.O. Box 8016, Baltimore, MD 21244-8013. Re: CMS-1676 Submitted electronically: http://www.regulations.gov Dear Administrator Verma: The Center for Medicare Advocacy (Center) is pleased to provide the Centers for Medicare & Medicaid Services (CMS) comments on the 2018 … Read more

August 9, 2017 Thomas E. Price Secretary Department of Health and Human Services Seema Verma Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services Room 445-G, Hubert H. Humphrey Building 200 Independence Ave., S.W. Washington, D.C.  20201 Re: CMS-1686-ANPRM.  Advance Notice of Proposed Rulemaking with Comment.  Medicare Program; Prospective Payment System … Read more

Senate Releases Draft of Bill to Undermine Health Coverage: Stop the “Better Care Reconciliation Act”

The wait is finally over. Senate Republicans have released a "discussion draft" of their health care bill, The Better Care Reconciliation Act of 2017. This language is the culmination of secret drafting by a few Republican Senators, and it is as harmful to millions of Americans and as mean as we expected. Said Center for Medicare Advocacy … Read more

Senator Richard Blumenthal Field Hearing Regarding the American Health Care Act June 19, 2017 Testimony of Judith Stein In Opposition to the AHCA and the Secret Senate Process Senator Blumenthal, thank you for holding this hearing. I am Judith Stein, founder and Executive Director of the Center for Medicare Advocacy. The Center is a national … Read more

UNITED STATES HOUSE OF REPRESENTATIVES COMMITTEE ON WAYS & MEANS, SUBCOMMITTEE ON HEALTH HEARING ON "THE CURRENT STATUS OF THE MEDICARE PROGRAM, PAYMENT SYSTEMS, AND EXTENDERS” WRITTEN TESTIMONY SUBMITTED BY CENTER FOR MEDICARE ADVOCACY May 18, 2017 Introduction The Center for Medicare Advocacy, founded in 1986, is a national, non-partisan education and advocacy organization that … Read more

Examining Bipartisan Medicare Policies that Improve Care for Patients with Chronic Conditions May 16, 2017 Hearing before the Senate Committee on Finance Statement for the Record Center for Medicare Advocacy 1025 Connecticut Avenue, N.W., Suite 709 Washington, DC  20036 The Center for Medicare Advocacy, founded in 1986, is a national, non-partisan education and advocacy organization … Read more

April 24, 2017 VIA ELECTRONIC SUBMISSION PartCDcomments@cms.hhs.gov Seema Verma, Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services Baltimore, MD 21244 Re:                  2017 Transformation Ideas – Response to Request for Information re: Medicare Advantage and Part D Dear Administrator Verma: The Center for Medicare Advocacy (Center) is pleased to provide … Read more

March 3, 2017 VIA ELECTRONIC SUBMISSION AdvanceNotice2018@cms.hhs.gov Cynthia G. Tudor, Acting Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services Baltimore, MD 21244 Re:  Advance Notice of Methodological Changes for Calendar Year 2018 for Medicare Advantage (MA) Capitation Rates, Part C and Part D Payment Policies and 2018 Call Letter Dear … Read more

1.The Problem The Center for Medicare Advocacy has been hearing from people who meet Medicare coverage criteria but are unable to access Medicare-covered home health care, or the appropriate amount of care. These problems have been escalating in 2016. Care provided often falls short of care that is covered under the law and ordered by … Read more

August 29, 2016 Office of Medicare Hearings and Appeals Department of Health & Human Services Attention: HHS-2015-49 5201 Leesberg Pike, Suite 1300 Falls Church, VA 22041  Submitted electronically to: www.regulations.gov Re: HHS-2015-49 To Whom It May Concern: The Center for Medicare Advocacy (the Center) is pleased to provide the Centers for Medicare & Medicaid Services (CMS) … Read more

August 26, 2016 Centers for Medicare & Medicaid Services Department of Health and Human Services Attention: CMS-1648-P P.O. Box 8016 Baltimore, Maryland  21244-8016 Submitted electronically to: http://www.regulations.gov Re:      Federal Register Volume 81 No. 128 Medicare and Medicaid Programs: CY 2017 Home Health Prospective Payment System Rate Update; Home Health Value-Based Purchasing Model; and Home … Read more

The Honorable Andy Slavitt Acting Administrator Centers for Medicare & Medicaid Services 7500 Security Blvd. Baltimore, MD 21244 August 19, 2016 Submitted electronically: http://www.regulations.gov Re: CMS–1651–P; Medicare Program; End-Stage Renal Disease Prospective Payment System, Coverage and Payment for Renal Dialysis Services Furnished to Individuals with Acute Kidney Injury, End-Stage Renal Disease Quality Incentive Program, Durable … Read more

August 23, 2016 Centers for Medicare & Medicaid Services Department of Health & Human Services Attention: CMS–1651-P P.O. Box 8010 Baltimore, MD 21244–8010 Submitted electronically to:  www.regulations.gov           Re:      CMS-1651-P To Whom It May Concern: The Center for Medicare Advocacy (the Center) is pleased to provide the Centers for Medicare & Medicaid Services (CMS) comments … Read more

August 5, 2016 Mr. Laurence Wilson Director Chronic Conditions Policy Group Center for Medicare & Medicaid Services 7500 Security Boulevard Baltimore, MD  21244 Laurence.wilson@cms.hhs.gov  Ms. Jeanette Kranacs Acting Deputy Director Chronic Conditions Policy Group Center for Medicare Centers for Medicare & Medicaid Services 7500 Security Boulevard Baltimore, MD  21244 Jeanette.kranacas@cms.hhs.gov Dear Mr. Wilson and Ms. … Read more

June 16, 2016 Andrew M. Slavitt Acting Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services Room 445-G, Hubert H. Humphrey Building 200 Independence Ave., S.W. Washington, D.C.  20201 Re: CMS-1655-P, Medicare Program; Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and … Read more

June 27, 2016 Centers for Medicare & Medicaid Services Department of Health & Human Services Attention: CMS–5571–P P.O. Box 8013 Baltimore, MD 21244–8013 Submitted electronically to: www.regulations.gov             Re:  CMS–5517–P To Whom It May Concern: The Center for Medicare Advocacy (the Center) is pleased to provide the Centers for Medicare & … Read more

June 20, 2016 Andrew M. Slavitt Acting Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services Room 445-G, Hubert H. Humphrey Building 200 Independence Ave., S.W. Washington, D.C.  20201 Re: CMS-1655-P, Medicare Program; Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities Proposed Rule for FY2017, SNF Value-Based Purchasing Program, … Read more

June 20, 2016 Andrew Slavitt, Acting Administrator Centers for Medicare & Medicaid Services Department of Health & Human Services Attention: CMS–1652–P P.O. Box 8010 Baltimore, MD 21244-8010 Re: CMS–1652–P Dear Mr. Slavitt: The Center for Medicare Advocacy (Center) is pleased to provide the Centers for Medicare & Medicaid Services (CMS) comments on its proposal “Medicare … Read more

May 9, 2016 Centers for Medicare & Medicaid Services Department of Health & Human Services Attention: CMS–1670–P Mail Stop C4–26–05 7500 Security Boulevard Baltimore, MD 21244–1850 Submitted electronically to:    http://regulations.gov Re:      CMS–1670–P   To Whom It May Concern: The Center for Medicare Advocacy (Center) is pleased to provide the Centers for Medicare & … Read more

Medicare coverage for medically necessary oral health care is supported by the Medicare statute, its legislative history and, in some instances, even CMS policy.  For this purpose, “medically necessary oral health care” refers to treatment deemed necessary by a physician when a patient’s medical condition or treatment is or will likely be complicated by an … Read more

April 5, 2016 Centers for Medicare & Medicaid Services Office of Strategic Operations and Regulatory Affairs Division of Regulations Development 7500 Security Blvd. Baltimore, MD 21244-1850 Delivered Electronically through www.regulations.gov Re: Medicare Prior Authorization of Home Health Services Demonstration (CMS-10599) To Whom It May Concern: The Center for Medicare Advocacy (the Center) appreciates the opportunity … Read more

March 4, 2016 The Honorable Ron Wyden Ranking Member, Committee on Finance United States Senate Washington, D.C. 20510 The Honorable Charles Grassley Senior Member, Committee on Finance United States Senate Washington, D.C. 20510 Submitted electronically to: Report_Feedback@finance.senate.gov Re: Comments on Prescription Drug Pricing Reform Dear Ranking Member Wyden and Senior Member Grassley: The Center for Medicare … Read more

March 4, 2016 VIA ELECTRONIC SUBMISSION AdvanceNotice2017@cms.hhs.gov Andrew Slavitt, Acting Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services P.O. Box 8016 Baltimore, MD 21244-8016 Re: Advance Notice of Methodological Changes for Calendar Year 2017 for Medicare Advantage (MA) Capitation Rates, Part C and Part D Payment Policies and 2017 Call … Read more

January 29, 2016 The Honorable Orrin Hatch                                       The Honorable Ron Wyden Chair, Committee on Finance                                    Ranking Member, Committee on Finance United States Senate                                               United States Senate Washington, D.C. 20510                                           Washington, D.C. 20510 The Honorable Johnny Isakson                                 The Honorable Mark Warner United States Senate                                               United States Senate Washington, D.C. 20510                                           Washington, DC 20510 Submitted electronically to: chronic_care@finance.senate.gov Re: Comments … Read more

January 4, 2016 Centers for Medicare & Medicaid Services Comments on NOTICE Act Submitted electronically: NOTICE_Act@cms.hhs.gov The Center for Medicare Advocacy (Center) is a national, private, non-profit law organization, founded in 1986, that provides education, analysis, advocacy, and legal assistance to help people nationwide, primarily older people and people with disabilities, to obtain necessary health … Read more

December 21, 2015 Acting Administrator Andy Slavitt Centers for Medicare & Medicaid Services Department of Health and Human Services 7500 Security Boulevard Baltimore, MD 21244-8016 RE: Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters for 2017 [CMS–9937–P] Submitted electronically via www.regulations.gov Dear Acting Administrator Slavitt: The Center for Medicare Advocacy … Read more

Submitted electronically via MMCOcapsmodel@cms.hhs.gov December 21, 2015 Tim Engelhardt, Director Medicare-Medicaid Coordination Office Centers for Medicare and Medicaid Services 7500 Security Boulevard Baltimore, MD 21244 Re: Medicare-Medicaid Plan Quality Ratings Strategy Dear Director Engelhardt, The Center for Medicare Advocacy (Center) greatly appreciates the opportunity to provide comments on the Medicare-Medicaid Plan Quality Ratings Strategy. The … Read more

Submitted electronically at http://www.regulations.gov December 15, 2015 CMS, Office of Strategic Operations and Regulatory Affairs, Division of Regulations Development, Attention: CMS-10003/0938-0829, Room C4-26-05, 7500 Security Boulevard, Baltimore, Maryland 21244-1850 Re:      Comments on CMS-10003 Notice of Denial of Medical Coverage (or Payment) To Whom It May Concern: The Center for Medicare Advocacy (the Center) greatly appreciates … Read more

October 14, 2015 Andrew M. Slavitt Acting Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services Room 445-G, Hubert H. Humphrey Building 200 Independence Ave., S.W. Washington, D.C.  20201 Medicare and Medicaid Programs; Reform of Requirements for long-Term Care Facilities CMS-3260-P Submitted electronically:  http://www.regulations.gov Dear Mr. Slavitt and CMS Colleagues: The … Read more

Proposed LCD DL 33787 unfairly and illegally restricts Medicare coverage for, and discriminates against, Dr. Roger Catlin, an above-knee amputee who wears an elevated vacuum socket, micro-processor knee and energy storing foot. Dr. Catlin breaks all assumptions the proposed LCD makes about his co-morbidities related to his functional potential. He ambulates independently, runs a tractor, … Read more

September 15, 2015 Submitted electronically Sheila Hanley Director, Policy and Programs Group Center for Medicare & Medicaid Innovation Centers for Medicare & Medicaid Services HealthPlanInnovation@cms.hhs.gov RE: Medicare Advantage (MA) Value-Based Insurance Design (VBID) Model The Center for Medicare Advocacy, Inc., (Center) appreciates the opportunity to provide comments in response to the recently announced Medicare Advantage … Read more

September 8, 2015 Andy Slavitt, Acting Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services Attention: CMS-1631-P P.O. Box 8016 Baltimore, MD 21244-8016 Delivered Electronically through www.regulations.gov Re: Medicare Program; Revisions to Payment Policies Under the Physician Fee Schedule and Other Revisions to Part B for CY 2016  Administrator Slavitt: The … Read more

September 8, 2015 Andy Slavitt Acting Administrator Centers for Medicare and Medicaid Services U.S. Department of Health and Human Services Attention: CMS-5516-P 7500 Security Boulevard Baltimore, MD 21244-1850 Delivered Electronically through www.regulations.gov Re: Medicare Program; Comprehensive Care for Joint Replacement Payment Model for Acute Care Hospitals Furnishing Lower Extremity Joint Replacement Services (CMS-5516-P) Administrator Slavitt: … Read more

September 1, 2015 SUBMITTED ELECTRONICALLY http://www.regulations.gov Andrew Slavitt, Acting Administrator Centers for Medicare & Medicaid Services Department of Health & Human Services 200 Independence Avenue, SW Washington, DC 20201 Re: CMS-1625-P Dear Acting Administrator Slavitt: The Center for Medicare Advocacy (the Center) is pleased to provide comments on the Centers for Medicare & Medicaid Services … Read more