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On August 12, 2019 the Center for Medicare Advocacy submitted comments on the Centers for Medicare & Medicaid Services’ (“CMS”) request for information (“RFI”) regarding reducing administrative burden through the Patients over Paperwork initiative. The RFI sought information on how CMS could simplify and reduce paperwork burdens, including methods to modify and streamline reporting and documentation processes and requirements, and simplify beneficiary enrollment and eligibility determinations.

The Center urged CMS to consider several proposals, including eliminating the asset test in Medicare Savings Programs (MSPs), which we believe unfairly penalizes low-income beneficiaries for putting aside modest savings for retirement and emergency expenses; implementing a process that would improve access to necessary durable medical equipment for dually eligible beneficiaries; improving the multi-level, protracted Part D exceptions and appeals process, by allowing the pharmacy counter refusal to serve as the coverage determination, and using Part B standards for Part D off-label usage, among other suggestions.

Read the Center’s full comments at

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