October 21, 2019 VIA ELECTRONIC SUBMISSION Centers for Medicare & Medicaid Services Department of Health and Human Services Attention: CMS-9115-P, Mail Stop C4-26-05 7500 Security Boulevard Baltimore, MD 21244-1850 RE: CMS-R-131-Advance Beneficiary Notice of Noncoverage (ABN) Dear Administrator Verma: The Center for Medicare Advocacy (Center) is pleased to provide the Centers for Medicare & Medicaid … Read more

October 16, 2019 Frank Pallone Chairman Energy and Commerce Committee United States House of Representatives Washington, DC 20515 Greg Walden Ranking Member Energy and Commerce Committee United States House of Representatives Washington, DC 20515         Re: Support for H.R. 3 and Reinvestment of Savings in Medicare Program Dear Chairman Pallone and Ranking … Read more

October 16, 2019 Richard Neal Chairman Ways and Means Committee United States House of Representatives Washington, DC 20515 Kevin Brady Ranking Member Ways and Means Committee United States House of Representatives Washington, DC 20515         Re: Support for H.R. 3 and Reinvestment of Savings in Medicare Program Dear Chairman Neal and Ranking … Read more

September 15, 2019 Administrator Seema Verma Centers for Medicare & Medicaid Services Department of Health and Human Services Attention: CMS-3347-P P.O. Box 8010 Baltimore, MD 21244-1850 Re: CMS-3374-P; Federal Register, Vol. 84, No. 138 (July 18, 2019) Submitted electronically: www.regulations.gov Dear Administrator Verma: The Center for Medicare Advocacy and the Long Term Care Community Coalition … Read more

September 9, 2019 Centers for Medicare & Medicaid Services Department of Health and Human Services Attention: CMS-1711-P P.O. Box 8013 Baltimore, Maryland  21244-8013 Submitted electronically to: http://www.regulations.gov Re:  CMS-1711-P; Federal Register, Volume 84, No. 138 (July 18, 2019) The Center for Medicare Advocacy (the Center) provides these comments about CMS-1711-P and the impact of the … Read more

August 27, 2019 Seema Verma Administrator, Centers for Medicare & Medicaid Services Department of Health and Human Services 200 Independence Avenue, SW Washington DC 20201 Dear Administrator Verma: The undersigned organizations are committed to ensuring that all people with Medicare have unfettered access to the accurate and impartial information they need to make optimal choices … Read more

August 13, 2019 VIA ELECTRONIC SUBMISSION Secretary Alex Azar U.S. Department of Health and Human Services Herbert H. Humphrey Building, Room 509F 200 Independence Avenue SW Washington, DC 20201 RE: Docket ID HHS-OCR-2019-0007, RIN 0945-AA11, Nondiscrimination in Health and Health Education Programs or Activities Dear Secretary Azar: The Center for Medicare Advocacy (“Center”) appreciates the … Read more

August 12, 2019 SUBMITTED ELECTRONICALLY VIA www.regulations.gov Centers for Medicare and Medicaid Services U.S. Department of Health and Human Services 7500 Security Boulevard Baltimore, MD 21244 Re:       CMS-6082-NC; Request for Information: Reducing Administrative Burden to Put Patients over Paperwork Dear Administrator Verma: The Center for Medicare Advocacy (“Center”) appreciates the opportunity to comment on … Read more

June 25, 2019 The Honorable Richard Neal, Chairman The Honorable Kevin Brady, Ranking Member House Ways and Means Committee Washington, DC 20515 Dear Chairman Neal, Ranking Member Brady: The Center for Medicare Advocacy (Center) applauds the committee for its work addressing important beneficiary-related issues in the Beneficiary Education Tools Telehealth Extender Reauthorization (BETTER) Act of … Read more

June 21, 2019 Nancy Potok Chief Statistician Office of Management and Budget 9257 New Executive Office Building 725 17th St. NW, Washington, DC 20006 Submitted via www.regulations.gov Re: Directive No. 14 Consumer Inflation Measures Produced by Federal Statistical Agencies (OMB–2019–0002) Dear Dr. Potok: The Center for Medicare Advocacy (Center) is pleased to provide comments to the Office … Read more

June 18, 2019 Centers for Medicare & Medicaid Services Department of Health and Human Services Attention: CMS-1718-P P.O. Box 8016 Baltimore, MD 21244-8016 Re: Medicare Program; Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities; Updates to the Quality Reporting Program and Value-Based Purchasing Program for Federal Fiscal Year 2020 Submitted electronically to: http://www.regulations.gov. … Read more

June 6, 2019 Via Electronic Submission to PartDImprovements@mail.house.gov The Honorable Richard Neal                             The Honorable Frank Pallone Chairman                                                    … Read more

May 30, 2019 Via Electronic Submission to DPC@cms.hhs.gov    Adam Boehler Director, Center for Medicare and Medicaid Innovation Centers for Medicare & Medicaid Services 200 Independence Ave, SW Washington, DC 20201 Re: Request for Information on Direct Contracting—Geographic Population-Based Payment Model Option Dear Director Boehler: The Center for Medicare Advocacy (Center) is pleased to provide … Read more

(Due) June 18, 2019 Centers for Medicare & Medicaid Services Department of Health and Human Services Attention: CMS-1718-P P.O. Box 8016 Baltimore, MD 21244-8016 Re: Medicare Program; Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities; Updates to the Quality Reporting Program and Value-Based Purchasing Program for Federal Fiscal Year 2020 Submitted electronically to: … Read more

Comments to Medicare Marketing Guidelines (MMG) Submitted by Center for Medicare Advocacy April 4, 2019 The following comments were submitted to CMS online via 2020 MCMG feedback tool: https://cmsgov.wufoo.com/forms/cy2020-mcmg-feedback-tool/.  Submitted by David Lipschutz, Senior Policy Attorney, Center for Medicare Advocacy – dlipschutz@medicareadvocacy.org ——————————————————————————– Section: Miscellaneous Communicating About New MA Benefit Flexibilities.  We are disappointed that … Read more

NOT FORGOTTEN: PROTECTING AMERICANS FROM ABUSE AND NEGLECT IN NURSING HOMES Hearing held March 6, 2019 Statement for the record submitted by:  Tony Chicotel, Staff Attorney; Michael Connors, Long Term Care Advocate; Janet Wells, Public Policy Consultant California Advocates for Nursing Home Reform 650 Harrison Street, #2 San Francisco, CA  94107 www.canhr.org Toby Edelman, Senior … Read more

United States Senate Committee on Finance “Not Forgotten: Protecting Americans From Abuse and Neglect in Nursing Homes” March 6, 2019 Statement submitted by: Long Term Care Community Coalition, Center for Medicare Advocacy, National Consumer Voice for Quality Long-Term Care, Justice in Aging, California Advocates for Nursing Home Reform, and National Academy of Elder Law Attorneys … Read more

March 1, 2019 Via Electronic Submission to www.regulations.gov (CMS-2018-0154)   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) 2020 for Medicare Advantage (MA) Capitation Rates, Part C and Part D Payment Policies, … Read more

January 25, 2018 Submitted via www.regulations.gov Centers for Medicare & Medicaid Services Department of Health and Human Services Attention: CMS-4180-P Re: CMS-4180-P: Modernizing Part D and Medicare Advantage to Lower Drug Prices and Reduce Out-of-Pocket Expenses The Center for Medicare Advocacy (Center) submits the following comments in response to the Centers for Medicare & Medicaid … Read more

December 10, 2018 Submitted via www.regulations.gov Samantha Deshommes, Chief Regulatory Coordination Division, Office of Policy and Strategy U.S. Citizenship and Immigration Services Department of Homeland Security 20 Massachusetts Avenue NW Washington, DC 20529-2140 Re: DHS Docket No. USCIS-2010-0012, RIN 1615-AA22, Comments in Response to Proposed Rulemaking: Inadmissibility on Public Charge Grounds The Center for Medicare … Read more

November 16, 2018 Administrator Seema Verma Centers for Medicare & Medicaid Services Department of Health and Human Services Attention: CMS-3346-P P.O. Box 8010 Baltimore, MD 21244-1810 Re: CMS-3346-P; Federal Register, Vol. 83, No. 183 (September 20, 2018). Submitted electronically: www.regulations.gov. Dear Administrator Verma, The Long Term Care Community Coalition (LTCCC) is a non-profit organization dedicated … Read more

Legislation to Reduce Rehospitalizations Fails to Answer Questions About Resident Protections The Reducing Unnecessary Senior Hospitalizations (RUSH) Act of 2018 (H.R. 6502) would allow certain medical groups to provide telehealth and on-site first responder services to nursing home residents in an attempt to reduce rehospitalizations. Although the goal of reducing unnecessary and inappropriate rehospitalizations is … Read more

September 10, 2018 Centers for Medicare & Medicaid Services Department of Health and Human Services Attention: CMS-1691-P Mail Stop C4-26-05 7500 Security Boulevard Baltimore, Maryland  21244-1850 Submitted electronically to: http://www.regulations.gov Re:  CMS-1691-P; Federal Register, Volume 83, No. 139 (July 19, 2018) The Center for Medicare Advocacy (the Center) provides these comments regarding CMS-1691-P and the … Read more

August 27, 2018 Centers for Medicare & Medicaid Services Department of Health and Human Services Attention: CMS-1689-P P.O. Box 8013 Baltimore, Maryland  21244-8013 Submitted electronically to: http://www.regulations.gov Re:  CMS-1689-P; Federal Register, Volume 83, No. 134 (July 12, 2018) The Center for Medicare Advocacy (the Center) provides these comments regarding CMS-1689-P and the impact of the … Read more

August 18, 2018 Via Electronic Submission: Medicaid.gov U.S. Department of Health and Human Services 200 Independence Avenue S.W. Washington, DC 20201 RE: Comments on the Kentucky HEALTH Medicaid Section 1115 waiver The Center for Medicare Advocacy (Center) is pleased to provide comments during the re-opened comment period for the Kentucky HEALTH Medicaid Section 1115 waiver … Read more

July 16, 2018 Via Electronic Submission: Regulations.gov U.S. Department of Health and Human Services 200 Independence Avenue S.W. Washington, DC 20201 RE: RIN 0991-ZA49 Comments to HHS Blueprint to Lower Drug Prices and Reduce Out-of-Pocket Costs The Center for Medicare Advocacy (Center) is pleased to provide comments on the HHS Blueprint to Lower Drug Prices … Read more

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

August 7, 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: Medicare and Medicaid Programs; Revision of Requirements for Long-Term Care Facilities: Arbitration Agreements … Read more

July 12, 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: Request for information: Reducing Regulatory Burdens Imposed by the Patient Protection and Affordable … 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