COMMENTS SUBMITTED BY
MEDICARE CONSUMERS WORKING GROUP ON PROPOSED
MEDICARE MODERNIZATION ACT REGULATIONS


The Centers for Medicare and Medicaid Services (CMS) has published proposed regulations for the new prescription drug benefit and HMO changes required under the new Medicare law. These regulations - which are around 2,000 pages long - spell out crucial details about how the new law will operate. Click here to view the proposed regulations.  CMS has accepted comments on these regulations from the public.  Comments were due by October 4, 2004.

 

Advocacy groups that work on Medicare and/or Medicaid have made sure that their voices were heard in this processA number of national organizations - click here for the working group paticipants list - coordinated the process of responding to these regulations. The goal was to develop comprehensive comments that covered the full range of issues, from A to Z.


SUMMARY OF ISSUES


The outline below and draft comments reachable by the links above summarize some of the topics that will be more fully addressed in a final comment letter. Given the length and complexity of the proposed regulations, this document does not enumerate all of the issues that will be addressed in that letter or covered in the discussion today, but highlights some key points.

The items noted are grouped by subject matter in the order they will be discussed today, rather than in order of the proposed regulations. For each topic area, the relevant subparts of the proposed regulations are noted in parentheses. All relate to Title I unless otherwise noted.

General Observations

Low Income Issues

 

Low-Income Eligibility and Enrollment (Subpart P)

Premiums and Cost-Sharing Subsidies for Low-Income Individuals (Subpart P)

Special Rules For States—Eligibility Determinations for Subsidies and General Payment Provisions (Subpart S)

General Eligibility, Enrollment, Plan Marketing Materials and Marketing Practices

 

Enrollment, Late Enrollment Penalties, Disenrollment (Subpart B)

Information about Part D; Marketing Materials (Subpart B)

Formularies, Quality Assurance, Quality Improvement and Utilization Review

 

Formulary Policies (Subpart C)

Dissemination of Benefits Information (Subpart C)

Cost Control and Quality Improvement (Subpart D)

Appeals, Grievances, Benefits Structure

 

Appeals and Grievances (Subpart M)

Benefits Structure/Qualified Prescription Drug Coverage (Subpart C )

Retiree Coverage

 

Payments to Sponsors and Calculation of True Out-of-Pocket Spending (Subpart R)

Other Coverage

 

MA Provisions (Various Subparts in Title I; Title II)

Medigap Policies (Subpart S)

Care in Other Settings (Long Term Care Issues)

 

Special Issues for Long-Term Care Facilities (Varouis Subparts in Title I)


 

PARTICIPANTS
 


The table below lists the participants in the Medicare Regulations Working Group, their affiliation, email, and organization’s website. If an individual is focusing on a particular issue or set of issues as we develop comments, we have noted that in the last column.

We appreciate comments and insights. You may send comments, issues, etc. related to drafting a comment letter either to one or more of the individuals working on the issue you are writing about, or to Dee Mahan at Families USA. If you send them to Dee, she will forward them to the appropriate individual(s). If possible, please reference the relevant section(s) in the proposed regulations, so that we can more easily incorporate your comments as we draft a final letter.

The comment letter is due on October 4; our goal is to have a letter in fairly complete draft form by September 24. Therefore, we would appreciate comments and suggestions to be forwarded by September 22.

We appreciate your thoughts and comments.

Name

Organization

e-mail

Website

Issues

Kirsten Beronio

National Mental Health Association

Kberonio@nmha.org

www.nmha.org

Low income issues
Enrollment/ disenrollment; late fees; plan marketing
Formularies
QA/UR
Appeals/grievances

Andrea Cohen

Medicare Rights Center

acohen@medicarerights.org

www.medicarerights.org

Low income issues (esp SPAPs)

Priscilla Chatman

Natl Com. to Preserve SS and Medicare

chatmanp@ncpssm.org

 

 

Al Chiplin

Center for Medicare Advocacy

Achiplin@medicareadvocacy.org.

 

www.medicareadvocacy.org

 

Jeff Crowley

Georgetown U. Health Policy Institute

Jsc26@georgetown.org

 

Formularies
QA/UR
Low Income issues
Enrollment/ disenrollment; late fees; plan marketing
Appeals/grievances

Toby Edelman

Center for Medicare Advocacy

Tedelman@medicareadvocacy.

org

www.medicareadvocacy.org

Civil and monetary penalties

Kim Glaun

Medicare Rights Center

Kglaun@medicarerights.org

www.medicarerights.org

Low income issues Enrollment/ disenrollment; late fees; plan marketing MA provisions

Vicki Gottlich

Center for Medicare Advocacy

vgottlich@medicareadvocacy.org

www.medicareadvocacy.org

Appeals/grievances
Benefits (actuarial equivalency
Formularies
MA provisions
Medigap provisions
LTC issues/other settings

Steve Hitov

National Health Law Program

hitov@healthlaw.org

www.nhelp.org

Low income issues
Enrollment/ disenrollment; late fees; plan marketing
Appeals/grievances

Jeanne Lambrew

Center for American Progress

jlambrew@gwu.edu

 

Industry relations (PDP conflicts)

Dee Mahan

Families USA

dmahan@familiesusa.org

www.familiesusa.org

Enrollment/ disenrollment; late fees; plan marketing
Formularies
Appeals/Grievances
Industry relations (PDP conflicts)

Pam Meliso

Center for Medicare Advocacy

pmeliso@medicareadvocacy.org

www.medicareadvocacy.org

Low income issues (SPAPs)

Trish Nemore

Center for Medicare Advocacy

pnemore@medicareadvocacy.org

www.medicareadvocacy.org

Low income issues
Care in other settings

Lena O’Rourke

Families USA

lorourke@familiesusa.

org

www.familiesusa.org

Low income issues (SPAPs)

Edwin Park

Center for Budget and Policy Priorities

park@cbpp.org

www.cbpp.org

Low income issues

Liz Savage

The Arc

savage@thearc.org

www.thearc.org

 

Marc Steinberg

Families USA

msteinberg@familiesusa.

org

www.familiesusa.org

Low income issues

Bill Vaughan

Families USA

bvaughan@familiesusa.

org

www.familiesusa.org

Retiree coverage
Ma provisions
Medigap
Definition of creditable coverage
Payments to sponsors (calculating TrOOP)

JoAnn Volk

AFL-CIO

Jvolk@aflcio.org

 

www.aflcio.org

Retiree coverage

Additional Assistance

Also working on low-income enrollment and related issues:

Howard Bedlin

Natl Council on Aging

Howard.bedlin@ncoa.org

 

 

On formularies, etc.

Mary Worstell

Drew Sommers

 

Lupus Foundation

Epilepsy Foundation

 

 

sommers@efa.org

 

 

www.efa.org

 

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