DOCSLIB.ORG

October 5, 2020 the Honorable Seema Verma Administrator

Total Page：16

File Type：pdf, Size：1020Kb

Download full-text PDF Read full-text
October 5, 2020 the Honorable Seema Verma Administrator October 5, 2020 The Honorable Seema Verma Administrator Centers for Medicare & Medicaid Services U.S. Department of Health and Human Services Hubert H. Humphrey Building, Room 445–G 200 Independence Avenue, SW Washington, DC 20201 Re: File Code CMS–1734–P. Medicare Program; CY 2021 Revisions to Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment Policies; Medicare Shared Savings Program Requirements; Medicaid Promoting Interoperability Program Requirements for Eligible Professionals; Updates to the Quality Payment Program; Medicare Coverage of Opioid Use Disorder Services Furnished by Opioid Treatment Programs: Medicare Enrollment of Opioid Treatment Programs; Requirement for Electronic Prescribing for Controlled Substances for a Covered Part D Drug under a Prescription Drug Plan or an MA-PD plan; Payment for Office/Outpatient Evaluation and Management Services; Hospital IQR Program; Proposal to Establish New Code Categories; and Medicare Diabetes Prevention Program (MDPP) Expanded Model Emergency Policy Proposed Rule. Dear Administrator Verma: On behalf of the physician and medical student members of the American Medical Association (AMA), I appreciate the opportunity to offer our comments to the Centers for Medicare & Medicaid Services (CMS) on the 2021 Physician Fee Schedule (PFS) and Quality Payment Program (QPP) proposed rule, published in the Federal Register on August 17, 2020 (85 Fed. Reg. 50074). While there are numerous important proposals in this proposed rule which we provide comments on below, the AMA has been particularly focused on four issues. First, the calendar year (CY) 2021 rate setting and conversion factor deliver a significant decrease overall to physician payment. The proposals related to relative value units (RVUs), office and outpatient evaluation and management (E/M) visits, and the application of budget neutrality together result in a conversion factor that poses a very real threat to the ability of many physicians to deliver health care services to their patients. Our AMA strongly supports implementation of CMS’ new office visit policy and believes it will lead to significant administrative burden reduction and better describe and recognize the resources involved in office visits as they are performed today. However, we are deeply concerned that the corresponding budget neutrality cuts are deeply problematic during or immediately after the SARS-CoV-2 or COVID public health emergency (PHE), during which physician practices have experienced severe reductions in revenue. The almost 11 percent cut to physician payment is impactful in a most harmful way, especially during these unprecedented times. We urge CMS to use its authority to waive budget neutrality, and to bring physician The Honorable Seema Verma October 5, 2020 Page 2 payment up to a level commensurate with their service. We offer several recommendations on how the impact of the conversion factor can be lessened. Second, the AMA opposes CMS’ decision not to incorporate the revised office and outpatient E/M values in the global surgical codes, as this disrupts relativity and treats the same physician work differently based on whether the service is a stand-alone or post-operative visit. The AMA asks for CMS to convene the RUC and other stakeholders to discuss the global surgical codes and the add-on codes issues before moving forward with the proposed policies scheduled to take effect on January 1, 2021. The AMA supports the RUC recommendations on how to implement the global surgical codes. The AMA recommends that the implementation of the GP1X add-on code be postponed. Third, the AMA continues to work closely with CMS to promote improvements to the Medicare Quality Payment Program (QPP). The AMA appreciates CMS’ proposals to introduce a more clinically relevant, less burdensome approach to the Merit-based Incentive Payment System (MIPS) via the new MIPS Value Pathways (MVPs) and makes recommendations that we believe are critical to the successful implementation of MVPs. The AMA supports the MIPS flexibilities that CMS implemented during the COVID-19 pandemic and urges the agency to continue these policies through 2021 as the pandemic remains an ongoing crisis and disruptive to the fair and accurate evaluation of physician performance in MIPS. We recommend CMS postpone its transition away from the Group Practice Reporting Option web- interface and associated measures until 2023. The AMA does not support the CMS proposal to transition MIPS Alternative Payment Models (APM) to the Alternative Payment Model Performance Pathway (APP), as the quality measures should match the focus of the APM. Fourth, the AMA is grateful that CMS moved so quickly to provide critical flexibilities for telehealth policies. CMS telehealth policy changes during the PHE enabled patients to get much needed care. Patients and physicians now understand the value and importance of telehealth. Consequently, the AMA urges CMS to continue to strengthen telehealth policies: making permanent several telehealth services, removing geographic and site of service barriers, and continuing to cover services through the end of the year following the year in which the PHE ends. These services should include audio only visits. It is important to state the obvious our physicians have stepped into harrowing situations in heroic form, providing around-the-clock care while facing workforce challenges and shortages of personal protective equipment during the SARS-CoV-2 or COVID pandemic. COVID-19 has exposed the weaknesses in our health care system as well as opportunities for improvement, but the dedication of our physicians to deliver quality care for all patients, especially in emergency and pandemic situations, remains unchanged. In response to the COVID-19 pandemic, many physician practices closed to conserve personal protective equipment and to reduce the virus’ spread. The impact of COVID-19 has been devastating to physician practices. While some patient visits and surgeries were postponed during the early months of COVID-19 public health emergency (PHE), many patients have foregone those services completely. As a result, some patients did not receive the care they needed to prevent or manage their condition, and physician practices were not able to meet their expenses related to their practices even with the modest assistance from the Medicare Accelerated and Advance Payments, the Provider Relief Fund, and other small business supports. Our AMA continues to put the concerns of our physicians, our medical students, and the patients they serve at the forefront of everything we do. We are particularly concerned that the impact of some The Honorable Seema Verma October 5, 2020 Page 3 proposals combined with COVID-19 will continue to widen the gap for marginalized and minoritized communities. While the data remain incomplete, the data that have emerged on the racial and ethnic patterns of the COVID-19 pandemic show that the virus has clearly disproportionately affected Black and Latinx, American Indian/Alaska Native—particularly in the Navajo Nation—Asian-American, and Pacific Islander communities. As CMS prioritizes proposals and creates future plans for addressing health care needs during a pandemic, the agency must also prioritize promptly providing culturally appropriate public health information to minoritized populations through appropriate channels and ensuring access to telehealth services for underserved areas in order to assist those communities access health care services while maintaining CDC-recommended physical distancing practices. Our AMA is committed to not only reducing health disparities, but to increasing health equity, in the wake of the pandemic, the public health emergency, and beyond. The AMA comments are guided by our AMA policies, informed by our members, and presented through a COVID-19 and health equity lens. The following outlines our principal recommendation to the 2021 proposed rule. Physician Fee Schedule (PFS) • The AMA strongly supports the January 1, 2021 implementation of the improvements to the E/M office visits, including those bundled into the post-operative period of surgical procedures. However, the physician payment cuts due to budget neutrality adjustments cannot take effect. CMS should exercise the full breadth and depth of its administrative authority to avert or, at a minimum, mitigate these unconscionable payment cuts. The AMA offers several alternatives. • The AMA recommends a new data collection process and potential changes to the underlying PE methodology should be explored related to practice expense relative values with the goal of an effective, transparent, and fair data collection effort. • The AMA urges CMS to continue and make permanent several telehealth services, to remove barriers to access based on geography and site of service, and to continue the coverage and payment policies that it has put in place for audio-video and audio-only services during the COVID-19 public health emergency (PHE) through the end of the year following the year in which the PHE ends. • The AMA is concerned that CMS has fundamentally misinterpreted the structure of the Remote Physiological Monitoring codes, as intended within the CPT code set, particularly with regards to CPT codes 99457 and 99458, and does not agree these codes only describe treatment management services. • The AMA supports permanently allowing the supervision of residents in teaching settings through audio/video real-time communications technology,
Load more

Recommended publications
  • Congressional Record United States Th of America PROCEEDINGS and DEBATES of the 114 CONGRESS, FIRST SESSION
    E PL UR UM IB N U U S Congressional Record United States th of America PROCEEDINGS AND DEBATES OF THE 114 CONGRESS, FIRST SESSION Vol. 163 WASHINGTON, MONDAY, MARCH 13, 2017 No. 43 House of Representatives The House met at noon and was pursuant to clause 12(c) of rule I, of an immi- lions of Americans. Grant that the se- called to order by the Speaker pro tem- nent impairment of the place of reconvening verity of this late winter storm wane. pore (Ms. CHENEY). at that time. The impairment is due to se- But for those affected, may the assist- vere weather. ance of first responders and more fortu- f Sincerely, PAUL D. IRVING, nate neighbors ease the passage DESIGNATION OF THE SPEAKER Sergeant at Arms. through this weather, prove that the PRO TEMPORE fiber of our national community is f The SPEAKER pro tempore laid be- strong and reliable. fore the House the following commu- ANNOUNCEMENT BY THE SPEAKER May all that is done this day be for nication from the Speaker: PRO TEMPORE Your greater honor and glory. WASHINGTON, DC, The SPEAKER pro tempore. Under Amen. clause 12(c) of rule I, the Speaker es- March 13, 2017. f I hereby appoint the Honorable LIZ CHENEY tablished this time for reconvening and to act as Speaker pro tempore on this day. notified Members accordingly. PLEDGE OF ALLEGIANCE PAUL D. RYAN, f Speaker of the House of Representatives. The SPEAKER pro tempore. The Chair will lead the House in the Pledge f PRAYER The Chaplain, the Reverend Patrick of Allegiance.
    [Show full text]
  • Congressional Record—Senate S6263
    October 30, 2019 CONGRESSIONAL RECORD — SENATE S6263 confer on President Trump the most As Senate Republicans have said over of title 5, United States Code, of the rule basic rights of due process or, seem- and over and over again, we support submitted by the Secretary of the Treasury ingly, alter Chairman SCHIFF’s unfair protections for Americans with pre- and the Secretary of Health and Human process in the House Intelligence Com- Services relating to ‘‘State Relief and Em- existing conditions. And the adminis- powerment Waivers’’. mittee in any way whatsoever. tration has made it very clear that this There being no objection, the Senate Chairman SCHIFF can continue doing waiver program poses no threat—no proceeded to consider the resolution. this behind closed doors without the threat—to those protections. The Ad- Mr. MCCONNELL. I suggest the ab- President’s participation, so long as he ministrator of the Centers for Medicare holds at least one public hearing at sence of a quorum. & Medicaid Services has stated that ‘‘a The PRESIDING OFFICER. The some point. He is not even required to section 1332 waiver cannot’’—cannot— clerk will call the roll. make all the evidence he obtains pub- ‘‘undermine coverage with people with The senior assistant legislative clerk lic. He alone gets to decide what evi- pre-existing conditions.’’ proceeded to call the roll. dence goes in his report. And the reso- What is more, as the White House has Mr. SCHUMER. Mr. President, I ask lution doesn’t even give the President already made clear, Democrats’ resolu- unanimous consent that the order for any rights in the public hearing that it tion has zero chance of becoming law.
    [Show full text]
  • December 30, 2020 the Honorable Seema Verma Administrator Centers for Medicare & Medicaid Services Hubert H. Humphrey Buil
    December 30, 2020 The Honorable Seema Verma Administrator Centers for Medicare & Medicaid Services Hubert H. Humphrey Building 200 Independence Avenue, S.W., Room 445-G Washington, DC 20201 RE: Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters for 2022 and Pharmacy Benefit Manager Standards; Updates To State Innovation Waiver (Section 1332 Waiver) Implementing Regulations (CMS-9914-P) Dear Administrator Verma: On behalf of the American Hospital Association’s (AHA) nearly 5,000 member hospitals, health systems and other health care organizations, including approximately 90 that offer health plans, and our clinician partners – including more than 270,000 affiliated physicians, 2 million nurses and other caregivers – and the 43,000 health care leaders who belong to our professional membership groups, we thank you for the opportunity to comment on the Centers for Medicare & Medicaid Services’ (CMS) proposed Notice of Benefit and Payment Parameters for 2022. The AHA remains committed to ensuring that consumers have access to comprehensive, affordable coverage through the marketplaces and is concerned that several proposals could jeopardize progress that has been made toward this goal. Specifically, we urge the agency not to finalize proposals that would allow states to create a new type of direct enrollment marketplace in lieu of Healthcare.gov or a state-based marketplace. In addition, we do not support the codification in regulation of previous Section 1332 guidance that could allow states to pursue alternative approaches to coverage that would result in coverage losses. Comprehensive, affordable coverage is critical to patients’ access to care, and the Health Insurance Marketplaces remain the best option for individuals searching for comprehensive individual market coverage or Medicaid.
    [Show full text]
  • August 27, 2020 the Honorable Seema Verma Administrator
    August 27, 2020 The Honorable Seema Verma Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services 200 Independence Avenue SW Washington, DC 20201 Dear Administrator Verma: Nursing homes continue to be at the epicenter of the spread of the novel coronavirus disease 2019 (COVID-19) in the United States. To date, over 70,000 residents and workers in nursing homes and other long-term care settings have lost their lives to COVID-19, and more than 378,000 have been infected.1 Recent reports from state inspection officials have revealed that in more than one such facility, residents were treated with hydroxychloroquine without their informed consent or without approval from state officials. Such actions may be in violation of Centers for Medicare and Medicaid Services (CMS) rules that provide resident the right to “to be informed of, and participate in, his or her treatment.”2 The use of hydroxychloroquine is all the more concerning due to warnings from medical experts about the increased risks seniors face from the drug due to its effect on heart rhythms, renal systems and interactions with other medications.3 As the agency with primary responsibility for oversight of nursing homes participating in Medicare and Medicaid, we write to request information on what CMS is doing to monitor the use of hydroxychloroquine by nursing homes and to ensure that resident rights are adequately protected. Further, we urge CMS to investigate this matter using data already maintained and collected by CMS, including Medicare claims data and available inspection reports. Early in the pandemic, and without significant study or consensus among the scientific community, the Trump Administration inappropriately looked to hydroxychloroquine as a potential treatment for 1 The COVID Tracking Project, “The Long-Term Care COVID Tracker,” https://covidtracking.com/data/longtermcare (last visited August 26, 2020).
    [Show full text]
  • April 23, 2018 Seema Verma Administrator Centers for Medicare
    April 23, 2018 Seema Verma Administrator Centers for Medicare & Medicaid Services Hubert H. Humphrey Building 200 Independence Avenue, S.W., Room 445-G Washington, DC 20201 RE: Short-Term, Limited-Duration Insurance (CMS-9924-P) Dear Ms. Verma: On behalf of the American Hospital Association’s (AHA) nearly 5,000 member hospitals, health systems and other health care organizations, and our clinical partners – including more than 270,000 affiliated physicians, 2 million nurses and other caregivers – and the 43,000 health care leaders who belong to our professional membership groups, we thank you for the opportunity to comment on the proposed rule amending the definition of short-term, limited-duration health insurance. While we appreciate the Departments of Treasury, Labor, and Health and Human Services’ (collectively, the departments) effort, this rule fails to adequately protect consumers and could contribute to instability in the individual insurance market, ultimately decreasing access to affordable coverage for vulnerable populations. The AHA is committed to expanding affordable, high-quality health coverage and looks forward to working with the departments on this shared goal. In previous comments to the Administration, we have expressed our support for solutions to both lower the cost of coverage and provide greater choice among plans, including by supporting federal and state reinsurance programs, increasing outreach and enrollment assistance, and funding the cost-sharing reduction subsidies. These approaches retain vital consumer protections while supporting greater enrollment and reducing costs by better balancing the marketplace risk pools. In contrast, short-term, limited-duration insurance products could harm consumers by providing inadequate access to care and subjecting them to much greater out-of-pocket spending when illness or injury occurs.
    [Show full text]
  • NCPA Letter to CMS Seema Verma
    March 26, 2020 Ms. Seema Verma Administrator Centers for Medicare & Medicaid Services 7500 Security Boulevard Baltimore, MD 21244 Re: NCPA Sends Small Business Community Pharmacy Recommendations and Needs to Administration’s Coronavirus Task Force Dear Administrator Verma, Attached you will find NCPA’s recommendations to the Trump Administration on how our members can and are helping during the COVID-19 public health emergency. However, in order to remain viable and keep doors open to provide continued access and care, I wanted to reach out about two very important asks to CMS: 1. Require Part D sponsors and Pharmacy Benefit Managers (PBMs) to temporarily suspend all pharmacy audits during the public health emergency. 2. Provide clear guidance stating that Part D sponsors and PBMs are not able to audit pharmacies in the future for any alterations or waivers of Part D sponsor and PBM requirements, including patient signatures as proof of delivery for any medications, made during this emergency period. Pharmacies remain one of the few entities open to assist patients in their local communities. Our members need relief to stay open and help their patients. Unfortunately, pharmacies are still receiving audit notices from PBMs daily. This interrupts patient care in trying times and we are asking CMS to require all Part D sponsors and PBMs to temporarily suspend all pharmacy audits. We greatly appreciate CMS’ guidance dated March 20, 2020, “Minimizing Face-to-Face Contact for Medication Delivery or Dispensing,” and we continue to track how various PBMs are implementing this guidance. CMS stated the following in the guidance: “We are making clear that HHS does not require and will not audit for patient signatures as proof of delivery for any medications, including for controlled substances.” However, PBMs are still requiring pharmacies to document various aspects of proof of delivery, and each PBMs notice to pharmacies can vary greatly.
    [Show full text]
  • March 31, 2020 Alex M. Azar Seema Verma Secretary Administrator
    March 31, 2020 Alex M. Azar Seema Verma Secretary Administrator Health and Human Services Centers for Medicare & Medicaid Services 200 Independence Avenue, S.W. 200 Independence Avenue, S.W., Room 445-G Washington, D.C. 20201 Washington, DC 20201 Dear Secretary Azar and Administrator Verma: On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, our clinician partners – including more than 270,000 affiliated physicians, 2 million nurses and other caregivers – and the 43,000 health care leaders who belong to our professional membership groups, the American Hospital Association (AHA) asks the Department of Health and Human Services (HHS) and the Centers for Medicare & Medicaid Services (CMS) to directly and expediently distribute to rural and urban hospitals and health systems funds from the Public Health and Social Services Emergency Fund that were designated for providers in the Coronavirus Aid, Relief, and Economic Security (CARES) Act. The CARES Act increased funding for the Public Health and Social Services Emergency Fund by $100 billion in order to reimburse eligible health care providers for health care-related expenses or lost revenues that are attributable to COVID-19. Eligible providers are public entities, Medicare- or Medicaid-enrolled suppliers and providers, and other for-profit and non-profit entities as designated by the HHS Secretary. The law specified that funding be distributed on a rolling basis through “the most efficient payment systems practicable to provide emergency payment.” As you are aware, hospitals are in a crisis situation and time is of the essence. Thus, we ask you distribute these funds directly to providers.
    [Show full text]
  • Medicare Advantage (MA) Coverage of End Stage Renal Disease (ESRD) and Network Requirement Changes
    Medicare Advantage (MA) Coverage of End Stage Renal Disease (ESRD) and Network Requirement Changes January 11, 2021 Congressional Research Service https://crsreports.congress.gov R46655 SUMMARY R46655 Medicare Advantage (MA) Coverage of End January 11, 2021 Stage Renal Disease (ESRD) and Network Paulette C. Morgan Requirement Changes Specialist in Health Care Financing Starting in calendar year (CY) 2021, all Medicare beneficiaries with end stage renal disease (ESRD) are allowed to enroll in Medicare Advantage (MA) plans. MA plans are an alternative to Suzanne M. Kirchhoff original Medicare under which beneficiaries receive all required Medicare benefits (except Analyst in Health Care hospice) through private insurers. Prior to CY2021, beneficiaries with ESRD, in general, were Financing not allowed to enroll in MA plans but could be enrolled in MA plans in limited circumstances. For example, Medicare beneficiaries with ESRD could remain in MA plans if they were diagnosed with ESRD while already enrolled in an MA plan. In 2019, there were 534,000 Medicare beneficiaries with ESRD, of whom approximately 25% (131,000) were in MA plans. The CY2021 policy change, which Congress required in the 21st Century Cures Act (Cures Act; P.L. 114-255), is expected to increase the number of MA enrollees with ESRD by 83,000 (more than 60%) over six years, with half the increase in CY2021. Congress enacted the Cures Act change for several reasons. Most ESRD patients undergo thrice-weekly dialysis treatments to stay alive, and many have other chronic health conditions that require medical care, such as diabetes, heart disease, or hypertension. Patient advocates and lawmakers have said that ESRD patients, because of their complex medical conditions, could benefit from joining MA plans, which are required to ensure continuity of care and integration of services.
    [Show full text]
  • CMS Snapshot February 6-13, 2020 Delivered to You by the Partner Relations Group in the Office of Communications
    CMS Snapshot February 6-13, 2020 Delivered to you by the Partner Relations Group in the Office of Communications All releases below are from 2pm Thursday, February 6 through 2pm Thursday, February 13, 2020. News Releases *February 6- CMS Prepare Nation’s Healthcare Facilities for Coronavirus Threat. Today, under the leadership of President Donald Trump and Secretary of Health and Human Services Alex Azar, the Centers for Medicare & Medicaid Services (CMS) is taking critical steps to ensure America’s health care facilities and clinical laboratories are prepared to respond to the threat of the 2019-Novel Coronavirus (2019-nCoV). *February 6- HHS Marks 2019 Accomplishments. Today, the U.S. Department of Health and Human Services (HHS) released a report highlighting accomplishments from 2019. To read the report, visit: https://www.hhs.gov/about/leadership/secretary/2019-annual-report/index.html *February 9- Representatives of Coronavirus Task Force Brief Governors at NGA. On Sunday, February 9, representatives of President Trump's Coronavirus Task Force provided an update at the National Governors Association (NGA) Winter Meeting about the U.S. response to the coronavirus outbreak. *February 10- HHS Pioneers First Foundry for American Biotechnology. The U.S. Department of Health and Human Services launched the nation's first Foundry for American Biotechnology today to produce technological solutions that help the United States protect against and respond to health security threats, enhance daily medical care, and add to the U.S. bioeconomy. *February 10- Secretary Azar Statement on President Trump's FY 2021 Budget. Health and Human Services Secretary Alex Azar issued the following statement regarding the release of President Trump's Fiscal Year 2021 Budget.
    [Show full text]
  • Questions for the Record
    Questions for the Record “Hearing to Consider the Nomination of Seema Verma to be Administrator of the Centers for Medicare & Medicaid Services” Before Senate Finance Committee February 16, 2017 Questions for the record from Senator Chuck Grassley 1. Thirty million Americans suffer from a rare disease and many of these patients have no therapeutic option to address their condition. Timely access to innovative therapies for these patients with no other viable therapeutic options is critical. How can we ensure that Medicaid drug coverage processes include reviews by clinicians with expert knowledge and experience with the particular rare disease and its patient population? Answer: If confirmed, I commit to working with you and your colleagues in Congress as well as the FDA and other federal agencies to prioritize access to innovative therapies for patients, especially our most vulnerable citizens who have unmet medical needs. I look forward to working with clinical experts and relevant federal entities to ensure patients’ needs are at the center of decision making. 2. CMS invests heavily in the training expenses of psychiatry residents serving in both institutions for mental disease (IMD) and general medical inpatient psychiatric units. But IMDs rules either prohibit the small number of IMD teaching hospitals from serving adults with Medicaid, or restrict IMDs from caring for the most severely ill who need care for slightly longer lengths of stay (15-20) days. This rule exacerbates the severe national shortage of treatment for people with severe mental illness. Resolving this issue would help with the shortage and would also provide psychiatrists in training with invaluable experience.
    [Show full text]
  • Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters for 2021 (CMS-9916-P)
    March 2, 2020 Seema Verma Administrator Centers for Medicare & Medicaid Services Hubert H. Humphrey Building 200 Independence Avenue, S.W., Room 445-G Washington, DC 20201 RE: Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters for 2021 (CMS-9916-P) Dear Ms. Verma: On behalf of the American Hospital Association’s (AHA) nearly 5,000 member hospitals, health systems and other health care organizations, including approximately 90 that offer health plans, and our clinician partners – including more than 270,000 affiliated physicians, 2 million nurses and other caregivers – and the 43,000 health care leaders who belong to our professional membership groups, we thank you for the opportunity to comment on the Centers for Medicare & Medicaid Services’ (CMS) proposed Notice of Benefit and Payment Parameters for 2021. The AHA remains committed to ensuring that consumers have access to comprehensive, affordable coverage through the marketplaces and looks forward to continuing to work with the agency on this objective. We appreciate that most of the proposed changes in this notice are modest, which may help to support the gains in marketplace stability that have already been achieved. Comprehensive, affordable coverage is critical to patients’ access to care. We are pleased that the agency is proposing or considering a number of policies that could benefit patients by lowering drug prices and premiums, incentivizing utilization of high value services, and ensuring premium dollars are spent wisely. We are concerned, however, that CMS continues to consider changes to automatic reenrollment, which could result in the loss of coverage for vulnerable enrollees and contribute to marketplace destabilization.
    [Show full text]
  • November 2, 2020 Seema Verma
    November 2, 2020 Seema Verma Administrator Centers for Medicare & Medicaid Services 7500 Security Boulevard Baltimore, MD 21244 Re: CMS-3372-P: Medicare Program: Medicare Coverage of Innovative Technology and Definition of Reasonable and Necessary Dear Administrator Verma, The Alliance for Aging Research (Alliance) appreciates the opportunity to provide input on the Centers for Medicare & Medicaid Services’ (CMS) proposed rule on Medicare Coverage of Innovative Technology (MCIT) and the Definition of “Reasonable and Necessary.” The Alliance for Aging Research (Alliance) is the leading nonprofit organization dedicated to accelerating the pace of scientific discoveries and their application to vastly improve the universal human experience of aging and health. The Alliance believes that advances in research help people live longer, happier, more productive lives and reduce healthcare costs over the long term. The Alliance strives to advance science and enhance lives through a variety of activities and initiatives – from policy issues to provider and consumer health programs – that generate knowledge and action on age-related matters. The Alliance serves as a valued patient-focused voice in policy development, including for medical device coverage. We serve as conveners for the Heart Valve Disease Task Force, which convenes patient advocacy organizations to improve access, research, and awareness of heart disease detection and treatment. We are also engaged as a stakeholder in medical device priorities with the Food and Drug Administration (FDA), including multiple reauthorization cycles for the Medical Device User Fee Act. We support the proposal to align Medicare coverage for breakthrough medical devices with FDA market approval for a period of up to four years.
    [Show full text]