Skip to content

Regulatory Work

C-TAC and its Regulatory Taskforce works closely with our partners at the Centers for Medicare & Medicaid Services (CMS) to submit comments on proposed rules regarding those with advanced illness and potential regulatory initiatives. Please see our collection of submitted comments below.


Comments on Oncology Care First Model 2019 Informal Request for Information

View comments that C-TAC submitted to the Centers for Medicare & Medicaid Services in response to an informal Request for Information (RFI) regarding the Oncology Care First model. Overall, C-TAC supported the concept of an Oncology Care First Model and shared feedback on a variety of subjects, including care transformation, quality strategy and multi-payer participation.

View comments


Comments on AHRQ Systematic Review on Noninvasive Nonpharmacological Treatment Options for Chronic Pain

View comments that C-TAC submitted to the Agency for Healthcare Research and Quality on AHRQ's systematic review of noninvasive nonpharmacological treatments for chronic pain. C-TAC supports for the agency's efforts on this matter and believes the review will be helpful to direct care for chronic pain, but did express concern that the review could inadvertently diminish the importance of pharmacological treatments.

View comments


Comments on Proposed Revisions to Payment Policies under the Physician Fee Schedule

View comments that C-TAC submitted to the Centers for Medicare & Medicaid Services, responding to proposed revisions to payment policies under the physician fee schedule and other changes to Medicare Part B payment policies.

View comments


Comments on Proposed Specialty Care Models for Radiation Oncology and End-Stage Renal Disease

View comments that C-TAC submitted to the Centers for Medicare & Medicaid Services, responding to the proposed rule focused on implementing two mandatory payment models, one for a radiation oncology bundle and another for end-stage renal disease. Overall, C-TAC expressed support for the models and recommended including palliative care as a required additional service in both models.

View comments


Comments on Proposed 2020 Home Health Rule

View comments that C-TAC submitted to the Centers for Medicare & Medicaid Services, responding to the proposed 2020 Home Health Rule. C-TAC's comments addressed several aspects of the rule, covering the implementation of the Patient-Driven Grouping Model, proposed changes to the Home Health Plan of Care regulations, and more.

View comments


Comments on Proposed Rule Nondiscrimination in Health Care

View comments that C-TAC submitted to the Centers for Medicare & Medicaid Services, responding to a proposed rule regarding changing aspects of the nondiscrimination aspects of some health care regulations. C-TAC's recommended that the rule be revised to ensure that those with advanced illness and their families receive all the protections and opportunities possible to attain their best health and quality of life.

View comments


Comments on Proposed Medicare Hospital IPPS and LTCH Prospective Payment System Rule

View comments that C-TAC submitted to the Centers for Medicare & Medicaid Services, responding to a proposed rule regarding the 2020 Medicare Hospital Inpatient Prospective Payment System (IPPS). C-TAC's comments covered a range of topics, including the Hospital Inpatient Quality Reporting Program, the proposed removal of pain management questions from the PCHQR program, and the LTCH Quality Reporting Program.

View comments


Comments on Proposed Skilled Nursing Facility Rule

View comments that C-TAC submitted to week to the Centers for Medicare & Medicaid Services regarding a proposed rule focused on Skilled Nursing Facilities (SNFs) and its impact on the advanced illness population. The comments focused on the proposed transfer of health information to the provider-post-acute-care, as well collecting standardized patient assessment data as it relates to cognitive function and mental status.

View comments


Comments on Proposed 2020 Hospice Rule

View comments that C-TAC submitted to the Centers for Medicare & Medicaid Services on a proposed rule regarding the hospice wage index, payment rate and quality reporting requirements for hospices. C-TAC's comments focused on the proposed rebasing of continuous home care, in addition to the role of hospice and care coordination at the end of life.

View comments


 

Comments on Proposed Interoperability Rule

View comments that C-TAC submitted to week to the Centers for Medicare & Medicaid Services regarding a proposed interoperability rule and its effects on people living with advanced illness. C-TAC expressed support for the rule and shared commitments covering a range of topics, from care coordination to conditions of participation for hospitals and critical access hospitals.

View comments


 

Comments on AHRQ Integrating Palliative Care with Chronic Disease Management in Ambulatory Care

View comments that C-TAC submitted to the Agency for Healthcare Research & Quality regarding the value of integrating palliative care into chronic disease management. These were in response to their commissioning a topic refinement and systematic review on this topic. AHRQ provided a set of key questions to guide the systematic review and C-TAC commented on each specifically.

View comments


Comments on HHS Draft Pain Management Report

View C-TAC's comments on the HHS Pain Management Best Practices Inter- Agency Task Force Draft Report on Pain Management Best Practices: Updates, Gaps, Inconsistencies, and Recommendations. C-TAC supported most of the report's recommendations, but cautioned that certain recommended practices could be inappropriate for those with advanced illlness. C-TAC also recommended that additional research is needed to better understand the impact of pain on family caregivers.

View comments


Comments on HEDIS 2020 Measures

View C-TAC's comments on the HEDIS data set, which is used to assess performance improvement for health plans covering 190 million Americans. The comments covered proposed changes to the functional status assessment of care for older adults, as well as the use of high-risk medications in the elderly and use of opioids at high dosages.

View comments


Advance Notice of Proposed Changes for the Medicare Advantage CMS-HCC Risk Adjustment Model - Parts 1 and 2

View C-TAC's comments on proposed changes for  the Medicare Advantage CMS-HCC Risk Adjustment Model. C-TAC responded to Parts 1 and 2 of the proposed changes, covering subjects ranging from non-opioid pain management supplemental benefits to risk adjustment model methodology.

View comments


Draft Strategy on Reducing Regulatory and Administrative Burden Relating to the Use of Health IT and EHRs

View C-TAC's comments on the draft strategy on reducing regulatory and administrative burden relating to the use of health IT and electronic health records. C-TAC's comments offer support for efforts to reduce administrative burden as a means to ensure more time for direct care with those living with advanced illness. C-TAC also suggested that public health reporting via Health IT include advance directives and POLST forms.

View comments


Healthy People 2030 Proposed National Objectives

View C-TAC's comments on the proposed Healthy People 2030 national objectives. C-TAC and NHPCO offer concerns that references to serious and advanced illness are not found throughout the document where there are appropriate health care concerns faced by many Americans.

View comments


Proposed 2020 Medicaid Managed Care Rule Comments

View C-TAC's comments on the proposed rule to streamline the Medicaid and Children's Health Insurance Plan (CHIP) managed care regulatory framework. C-TAC's comments offer recommendations for future rulemaking on promoting care coordination and developing measures to capture the experiences of patients and families with advanced illness.

View comments


Proposed Regulatory Provisions to Reduce Redundancy Comments

View C-TAC's comments on the proposed regulatory provisions to promote program transparency, efficiency and burden reduction. C-TAC's comments address the effects that this proposed rule would have on hospices, hospitals and home health.

View comments


Comments on HHS Request for Information (RFI) on Adjusting for Social Risk Factors

View C-TAC's comments citing results from various palliative care and advanced illness models that better meet the needs of those with advanced illness and, as a side benefit, reduce utilization and cost.

View comments


Proposed Changes to Medicare Physician Fee Schedule and Other Medicare Part B Payment Policies Comments

View C-TAC's comments on the proposed Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2019; Medicare Shared Savings Program Requirements;Quality Payment Program; and Medicaid Promoting Interoperability Program.

View comments


Medicare Advantage (MA) Proposed Rule Comments

View C-TAC's comments on the Medicare Advantage (MA) proposed rule of 2019. C-TAC offers recommendations on addiction provisions, uniformity requirements, quality rating system, and more.

View Comments


Proposed Decision Memo for Implantable Cardioverter Defibrillators (ICD) Comments

View C-TAC's comments on the proposed decision memo for Implantable Cardioverter Defibrillators (ICD). C-TAC's comments suggest requiring a patient shared decision-making (SDM) interaction prior to ICD implantation for certain patients and encourage CMS to provide patients with more detailed information surrounding the deactivation of ICDs.

View Comments


HHS Strategic Vision FY 2018-22 Comments

View C-TAC's comments on the Department of Health and Human Services’s (HHS) draft Strategic Plan for FY 2018-2022. C-TAC's comments offer recommendations on consumer decision-making, advance care planning, and efficient delivery of care.

View Comments


ESRD Rule Comments

View C-TAC's comments on the End-Stage Renal Disease (ESRD) Prospective Payment System (PPS) proposed rule to the Centers for Medicare & Medicaid Services (CMS). C-TAC’s recommendations illustrate how the proposed ESRD PPS rule can best serve those with ESRD.

View Comments


MACRA Rule Comments

View C-TAC’s comments on the proposed rule: Medicare Program; Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive Under the Physician Fee Schedule, and Criteria for Physician-Focused Payment Models, particularly with respect to the policies that would affect providers treating those with especially complex and/or advanced illness.

View Comments


LTCH PPS Rule Comments

View C-TAC's comments on the Medicare Program; Hospital Inpatient Prospective Payment Systems (IPPS) for Acute Care Hospitals and the Long Term Care Hospital Prospective Payment System (LTCH PPS) and Proposed Policy Changes and Fiscal Year 2018 Rates; Quality Reporting Requirements for Specific Providers proposed rule.

View Comments