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 to the VA on Expanding the Authority of Professional Practice
View comments submitted by C-TAC in response to a final rule from the U.S. Department of Veterans Affairs (VA). The rule would allow health care professionals within the VA to practice consistent with their national scope and training regardless of state license, registration, certification, or other requirements that unduly interfere with their practice. C-TAC expressed strong support for this measure as a way to optimize the practice of every health care professional.
Comments on Fourth Interim COVID-19 Rule
View comments submitted by C-TAC in response to the fourth interim COVID-19 rule released by CMS. C-TAC expressed support for the overall goal of the rule, which is to clarify policies that are intended to support COVID-19 vaccine reimbursement and distribution. However, C-TAC did share concerns about the provisions related to vaccine coverage limitations and encouraged CMS to continue to develop transparent, evidence-based strategies to promote COVID-19 acceptance and 2 equitable and effective vaccine delivery.
Comments on Best Practices in Health Care in Response to the COVID–19 Pandemic
View comments submitted by C-TAC in response to a Request for Information issued by CMS regarding effective and innovative approaches to health care in response to the COVID-19 pandemic. C-TAC noted that there have been numerous efforts to leverage the telehealth flexibillities and waivers implemented during the public health emergency to support those with serious illness. C-TAC believes that with the appropriate telehealth policy changes such as allowing a patient’s home to serve as an eligible originating site and to continue to allow providers to use the advance care billing codes (99497 and 99498) for audio-only telehealth, such innovations could be scaled broadly and permanently.
Comments on Landscape Analysis to Leverage Novel Technologies for Chronic Disease Management for Aging Underserved Populations
View comments submitted by C-TAC in response to a Request for Information issued by CMS regarding a landscape analysis to leverage novel technologies for chronic disease management for aging underserved populations. C-TAC agrees that technology could help improve access and quality of care for this group, we are also concerned that such technology needs to address systemic and structural inequities in health care for this population. C-TAC also strongly encouraged CMS to include family caregivers into the group to consider for technology access and management.
Comments on Recommended Measure Set for Medicaid-Funded Home and Community-Based Services
View comments submitted by C-TAC in response to a Request for Information (RFI) released by CMS related to a recommended measure set for Medicaid-funded Home and Community-Based Services (HCBS). C-TAC expressed support for promoting the accessibility of and ensuring the quality of home and community-based services. We also support the inclusion of tested, validated measures and recommend prioritizing measures that are patient, or client-reported, and measure outcomes rather than just processes.
Comments on Proposed CY 2021 Physician Fee Schedule
View comments submitted by C-TAC on a proposed CMS rule that would update physician fee schedule (PFS) payments for calendar year (CY) 2021, and C-TAC submitted comments this week in response. C-TAC was pleased that the agency included several proposals that would increase telehealth and scope of practice flexibilities. However, we were concerned about the redistributive effect of CMS’s budget-neutral proposed increases in the payment rates for office/outpatient evaluation and management (E/M) visits.
Comments on Proposed Home Health Requirements
View comments that C-TAC submitted to the Center for Medicare & Medicaid Services regarding sections of a proposed rule related to the CY 2021 Home Health Prospective Payment System Rate Update, as well as the Home Health Quality Reporting Requirements and Home Infusion Therapy Services Requirements. We expressed support for the use of telehealth for people with advanced illness under the Medicare Home Health Benefit, although we recommended that the term "physician" be replaced with "non-physician" to reflect the full scope of providers delivering these services. We also asked for clarification that covered telehealth visits will include audio-only services, to be more inclusive of those who do not have access to smartphones or other technology needed for video conferencing.
Comments on Sections of Medicaid State Drug
Utilization Review (DUR) Proposed Rule
View comments that C-TAC submitted to the Center for Medicare & Medicaid Services regarding sections of a proposed rule related to the Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment (SUPPORT) Act. We expressed concern that gives too much autonomy to states regarding setting initial fill days’ supply, duplicative and early refill limits, dosing limits, etc. We also recommended that those with sickle cell disease (SCD) also be excluded from the proposed rule's requirements.
Comments on Additional Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency
View comments that C-TAC submitted to the Center for Medicare & Medicaid Services regarding additional policy and regulatory revisions proposed in response to the COVID-19 pandemic. C-TAC expressed support for the flexibilities included in this interim rule which enable providers to care for those with serious illness during the COVID-19 pandemic. Specifically, C-TAC supports the waiver allowing for telehealth services to be provided through audio-only technology and advocated for making the provision permanent.
Comments on Proposed FY 2021 Hospice Wage Index and Payment Rate Update
View comments that C-TAC submitted to the Center for Medicare & Medicaid Services regarding the proposed Hospice Wage Index and Payment Rate Update for the 2021 Fiscal Year. C-TAC proposed delaying implementation of this rule until October 2021 or the end of the COVID-19 pandemic. C-TAC also recommended that specific language be added to provide guidance to hospice providers on how to handle when a patient dies within five days of admission, as well as handling a patient or representative who refuses to sign the addendum.
Comments on Policy and Regulatory Revisions In Response to COVID-19 Pandemic
View comments that C-TAC submitted to the Center for Medicare & Medicaid Services regarding policy and regulatory revisions proposed in response to the COVID-19 pandemic. C-TAC expressed support for the interim changes suggested in the rule, which allow greater flexibility for providers to deliver care amid the COVID-19 pandemic. C-TAC suggested that data be collected on the patient and provider impact of these interim changes to determine which revisions should become permanent.
Comments on Medicare and Medicaid Programs: CY 2021 and 2022 Policy and Technical Changes
View comments that C-TAC submitted to the Center for Medicare & Medicaid Services in response to policy and technical changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, Medicaid Program, Medicare Cost Plan Program, and Programs of All-Inclusive Care for the Elderly for Contract Year 2021 and 2022.
Comments on Advance Notice of Methodological Changes for Calendar Year 2021 for
Medicare Advantage Capitation Rates and Part C and Part D Payment Policies
View comments that C-TAC submitted to the Centers for Medicare & Medicaid Services in response to an advance notice of methodological changes for Calendar Year 2021 for Medicare Advantage Capitation Rates and Part C and Part D Payment Policies. Overall, we are excited about a number of proposed changes in this advance notice as we
feel they will help improve the care of those living with advanced illness.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.