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1. Comments to Senate Finance Committee Chronic Care Workgroup

On June 22, 2015, the Center for Medicare Advocacy submitted comments to the Senate Finance Committee Chronic Care Workgroup in response to the Committee’s May 22, 2015 request for comments on reforming care for individuals with chronic conditions.

The Committee identified three overarching goals to guide the development of bipartisan legislation: increased care coordination; streamlined payment systems to incentivize appropriate care; and improved quality, outcomes, and program efficiency.  The Center organized our comments around these broad goals. The full Comments are available at They are summarized below.

  • Care Coordination.  We strongly urged Congress to establish a care coordination benefit within Traditional Medicare. We support full implementation of the settlement in Jimmo v. Sebelius and the addition of oral health to the comprehensive services provided to beneficiaries with chronic conditions. In addition, we identified a number of barriers that currently exist in the Medicare program that prevent individuals with chronic conditions from obtaining medically necessary care, including outpatient therapy caps, the three-day prior hospitalization requirement for skilled nursing facility coverage, and the lack of care coordination between stand-alone Part D prescription drug plans and other health care providers.
  • Streamlining Payment Systems. While we recognize that payment systems within Medicare must evolve in order to incentivize appropriate care, we urge caution with respect to the potential impact of some of these new payment models on Medicare beneficiaries, in particular, value-based purchasing, bundled payments, site-neutral payments, and value-based insurance design (VBID).  We recommend that new payment systems be tested in demonstration form before being adopted wholesale, and that any adoption be based on evidence that better care actually results from changes in payment models.  There is some evidence that some of the most frequently discussed payment system reforms have had unintended negative consequences for beneficiary care and access to services.
  • Facilitating Delivery of High Quality Care.   In order to achieve the articulated goal of delivering high quality care, improving care transitions, and producing stronger patient outcomes, reforming Medicare coverage for all beneficiaries, and in particular those with chronic conditions, must place primary focus on the beneficiary perspective.  Shifting additional costs onto beneficiaries, as some Medicare reform proposals would do, would slow, rather than foster, these important goals.  Further, before private Medicare Advantage (MA) plans are looked to as a model of care coordination for those with chronic conditions, and such plans seek increased payment and altered quality measurement based upon enrollment of such individuals, greater scrutiny of MA plan performance is necessary.  Finally, quality of care across settings must not only be measured, but enforced.

The Center also signed on to a letter along with 36 other national organizations outlining principles relating to chronic care reform.  See

2. Comments to the Centers’ for Medicare & Medicaid Services (CMS) Regarding Medicare Reimbursement of Skilled Nursing Facilities

The Center’s June 19, 2015 comments on CMS-1622-P, the annual update for Medicare Part A reimbursement of skilled nursing facilities, focused on (1) The Quality-Based Reporting Program (requirement imposed by the IMPACT Act that post-acute providers submit uniform assessment data); (2) The Value-Based Purchasing Program (requirement imposed by the Protecting Access to Medicare Act of 2014 for an all-cause, all-condition hospital readmission measure); and (3) Staffing data collection (requirement imposed by the Affordable Care Act for nursing homes to submit payroll-based staffing data).  See

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