2019 Public Comments

When relevant legislation, regulations, guidance, and other opportunities to shape policy related to health services research arise, UnityPoint Health may decide it is appropriate to develop an official position. The UnityPoint Health Government & External Affairs department serves as the primary liaison for regulatory submissions in response to state and federal rule-making and public requests for information, as well as communications advocating changes in state and federal policy direction or strategic initiatives. 

Federal Comments

Physician Self-Referral Regulations

Agency: Centers for Medicare & Medicaid (CMS)
Proposed Rules Modernizing and Clarifying the Physician Self-Referral Regulations (Stark Law)

Additional Information on Proposed Rule

Anti-Kickback Statute (AKS) Safe Harbors

Agency: Office of the Inspector General (OIG)
Revisions to Safe Harbors under the Anti-Kickback Statute and Civil Monetary Penalty Rules regarding Beneficiary Inducements

Additional Information on Proposed Rule

PACE Application Revisions

Agency: Centers for Medicare & Medicaid
Proposed Revisions to the Programs of All-Inclusive Care for the Elderly (PACE) Application

Additional Information on Proposal

PACE Audit Protocols

Agency: Office of Management and Budget
2020 Proposed Audit Protocol for Programs of All-Inclusive Care for the Elderly (PACE)

Additional Information on Proposal

Rural and Underserved Communities RFI

Agency: US House Ways & Means Committee
Request for Information (RFI) on Priority Topics that Impact Health Status and Outcomes for Rural and Underserved Communities Health Task Force

Additional Information on  RFI

340B Program Cost Collection

Agency: Centers for Medicare and Medicaid Services
Collection of 340B Drug Acquisition Cost Data

Additional Information on Information Collection Request

2020 Outpatient Prospective Payment System 

Agency: Centers for Medicare and Medicaid Services (CMS) 
CY 2020 Proposed Changes to Hospital Outpatient Prospective Payment Systems

Additional Information on 2020 Outpatient Prospective Payment Systems

2020 Physician Fee Schedule

Agency: Centers for Medicare and Medicaid Services (CMS)
CY 2020 Revisions to Payment Policies Under the Physician Fee Schedule

Additional Information on 2020 Physician Fee Schedule

Medicare Mandatory Specialty Models

Agency: Centers for Medicare and Medicaid Services (CMS)
Specialty Care Models To Improve Quality of Care and Reduce Expenditures

Additional Information on Medicare Mandatory Specialty Models

Medicaid Access

Agency: Centers for Medicare and Medicaid Services (CMS)
Methods for Assuring Access to Covered Medicaid Services—Rescission

Additional Information on Medicaid Access Rule

Home Health Prospective Payment System 

Agency: Centers for Medicare and Medicaid Services (CMS)
CY 2020 Home Health Prospective Payment System Rate Update; Home Health Value-Based Purchasing Model; Home Health Quality Reporting Requirements; and Home Infusion Therapy Requirements 

Additional Information on Home Health CY 2020 Rule

Part D Prior Authorization

Agency: Centers for Medicare and Medicaid Services (CMS)
Secure Electronic Prior Authorization for Medicare Part D

Additional Information on the Part D Prior Authorization Rule

Patients Over Paperwork

Agency: Centers for Medicare and Medicaid Services (CMS)
Reducing Administrative Burden To Put Patients Over Paperwork

Additional Information on Patients Over Paperwork Rule

Hospital Co-Location Guidance

Agency: Centers for Medicare and Medicaid Services (CMS)
Draft Guidance for Hospital Co-location with Other Hospitals or Healthcare Facilities

Additional Information on the Draft Guidance

State Relief and Empowerment (Section 1332) Waivers

Agency: Centers for Medicare and Medicaid Services (CMS) & Department of the Treasury
Request for Information (RFI) regarding State Relief and Empowerment (Section 1332) Waivers

Additional Information on Section 1332 Waivers RFI

2020 Inpatient Prospective Payment System (IPPS)

Agency: Centers for Medicare and Medicaid Services (CMS)
Hospital IPPS for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Proposed Policy Changes and Fiscal Year 2020 Rates; Proposed Quality Reporting Requirements for Specific Providers; Medicare and Medicaid Promoting Interoperability Programs Proposed Requirements for Eligible Hospitals and Critical Access Hospitals

Additional Information on the 2020 IPPS Rule

2020 Hospice Update

Agency: Centers for Medicare and Medicaid Services (CMS)
FY2020 Hospice Wage Index and Payment Rate Update and Hospice Quality Reporting Requirements

Additional Information on 2020 Hospice Rule

2020 Skilled Nursing Facility (SNF) Update

Agency: Centers for Medicare and Medicaid Services (CMS)
FY2020 SNF Payment Update and Quality Reporting Requirements

Additional Information on 2020 SNF Rule

2020 Inpatient Rehabilitation Facility (IRF) Update

Agency: Centers for Medicare and Medicaid Services (CMS)
FY2020 IRF Payment Update and Quality Reporting Requirements

Additional Information on 2020 IRF Rule

Interoperability and Information Blocking

Agency: Office of the National Coordinator (ONC), Department of Health and Human Services
Interoperability, Information Blocking and the ONC Health IT Certification Program Proposed Rule

Additional Information on the Proposed Rule

Interoperability and Patient Access

Agency: Centers for Medicare and Medicaid (CMS)
Interoperability and Patient Access Proposed Rule

Additional Information on Proposed Rule

Clinical Laboratory Proficiency Testing

Agency: Centers for Medicare and Medicaid (CMS)
Clinical Laboratory Improvement Amendments of 1988 (CLIA) Proficiency Testing Regulations Related to Analytes and Acceptable Performance

Additional Information on the Clinical Laboratory Proficiency Testing Proposed Rule

Direct Contracting: Geographic RFI

Agency: Centers for Medicare and Medicaid Innovation (CMMI)
Request for Information on the Proposed CMMI Direct Contracting: Geographic Population-Based Payment Model

Additional Information on the Direct Contracting: Geographic RFI

2020 PACE Audit Protocol

Agency: Centers for Medicare and Medicaid Services (CMS)
Programs of All-Inclusive Care for the Elderly (PACE) 2020 Audit Protocol

Additional Information on 2020 PACE Audit Protocol

Prescription Safe Harbors

Agency: Department of Health and Human Services
Fraud and Abuse Safe Harbor Protection Revisions for Prescription Pharmaceuticals and Certain Pharmacy Benefit Manager Service Fees

Additional Information on Fraud and Abuse Safe Harbor Protection Revisions for Prescription Pharmaceuticals and Certain Pharmacy Benefit Manager Service Fees

Hospital Quality Star Rating

Agency: Centers for Medicare & Medicaid (CMS)
Overall Hospital Quality Star Rating on Hospital Compare

Additional Information on Public Input Request for Hospital Quality Star Rating 

Medicare Advantage (MA) Performance Year 2020

Agency: Centers for Medicare & Medicaid (CMS) Proposed Methodological Changes for Medicare Advantage PY 2020

Additional Information on Medicare Advantage PY 2020

HIPAA and Coordinated Care

Agency: Department of Health and Human Services (HHS) Request for Information (RFI) on Modifying HIPAA Rules to Improve Coordinated Care

Additional Information on HIPAA and Coordinated Care RFI

Health IT and Electronic Health Records (EHRs)

Agency: Office of the National Coordinator for Health Information Technology (ONC)

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

Additional Information on the Draft Health IT and EHR Strategy

Medicare Part D Drug Prices 

Agency: Centers for Medicare & Medicaid Services (CMS)

Proposed Changes to Modernize Part D and Medicare Advantage to Lower Drug Prices and Reduce Out of Pocket Expenses

Additional Information on the Proposed Rule on Medicare Part D

Healthy People 2030 Objectives 

Agency: Health and Human Services (HHS)

Proposed Core, Developmental and Research Objectives for Healthy People 2030

Additional Information on Healthy People 2030 Objectives

Medicaid Managed Care

Agency: Centers for Medicare & Medicaid Services (CMS)

Proposed Changes to the Medicaid Program; Medicaid and Children’s Health Insurance Plan (CHIP) Managed Care 

Additional Information on the Proposed Rule on Medicaid Managed Care

State Comments

Case Management – Iowa Chapter 90

Agency: Department of Human Services

Proposed Rewrite to Iowa Administrative Rules on Case Management

Additional information on Chapter 90 rewrite

Home- and Community-Based Services (HCBS)

Agency: Iowa Medicaid Enterprise
HCBS Settings Statewide Transition Plan (STP)

Additional Information on HCBS Settings STP

Integrated Health Homes

Agency: Iowa Medicaid Enterprise
Development of future Integrated Health Homes State Plan Amendment

Additional Information on the Request for Stakeholder Input

Iowa Medicaid Critical Access Hospital Cost Adjustment

Agency: Iowa Department of Human Services

State Plan Amendment authorizing a Cost Adjustment Factor to Inpatient Rates and Outpatient Services for Critical Access Hospitals

Additional Information on the State Plan Amendment

Iowa Wellness Plan Waiver Extension

Agency: Iowa Department of Human Services

Five-year Extension of the 1115 Iowa Wellness Plan Demonstration Waiver – Iowa’s Medicaid Expansion Program

Additional Information on the Extension Request

Iowa Managed Care Enrollment Process

Agency: Iowa Department of Human Services

1915(b) Waiver Amendment to the Iowa High Quality Healthcare Initiative, including the Managed Care Enrollment Process

Additional Information on the 1915(b) Waiver Amendment to the Iowa High Quality Healthcare Initiative, including the Managed Care Enrollment Process

Iowa Prescription Monitoring Program – ARC 4205C

Agency: Iowa Board of Pharmacy

Revisions to the Iowa Prescription Monitoring Program, including the Role of Hospital Pharmacies 

Additional Information on the Notice of Intended Action on the Iowa Prescription Monitoring Program

Legislative Positions and Collaborative Sign-On Letters

There are no comments yet available.

Executive Order Summaries

At the Federal level, Executive Orders (EOs) are issued by the President. The EOs listed below announce regulatory and administrative priorities and often foreshadow future administrative rule-making efforts. UnityPoint Health often summarizes EOs impacting healthcare to inform advocacy efforts.

Medicare

Protecting and Improving Medicare for Our Nation’s Seniors, EO 13890

Price Transparency

Improving Price and Quality Transparency in American Healthcare to Put Patients First, EO 13877

For Further Information:

Please email Cathy Simmons, Executive Director of Government and External Affairs.

Contact Us

UnityPoint Health
Government & External Affairs
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West Des Moines, Iowa 50266