2021 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
2022 Surprise Billing Part 2
Agency: Centers for Medicare & Medicaid Services (CMS)
CMS requests comments on the Surprise Billing Part 2 proposals published October 7, 2021.
HRSA Criteria for Determining Maternity Care Health Professional Target Areas
Agency: HHS: Health Resources and Services Administration (HRSA)
HRSA requests comments on proposed criteria for determining maternity care health professional target areas published September 27, 2021.
- UnityPoint Health Comment on HRSA Maternity Care Health MCTAs
- HHS 2021-20855: HRSA Criteria for Determining Maternity Care Health Professional Target Areas
SAMHSA Revisions of Mental Health Outcome Measures and IPP Indicators
Agency: Substance Abuse and Mental Health Services Administration (SAMHSA)
SAMHSA requests comments on proposed revisions of mental health client participant outcome measures and infrastructure prevention and mental health promotion (IPP) indicators published August 2, 2021.
- UnityPoint Health Comment on SAMHSA Mental Health Outcome Measures and IPP Indicators
- OMB No 0930-0285 Summary of Information Collection Request
2022 Hospital Outpatient Prospective Payment System (OPPS)
Agency: Centers for Medicare & Medicaid Services (CMS)
CMS requests comments on the 2022 hospital outpatient prospective payment system proposed rule published August 8, 2021.
- UnityPoint Health Comment on 2022 OPPS
- CMS-1753-P: CMS 2022 OPPS Rule
- CMS-1753-FC: CMS 2022 OPPS FINAL RULE
2022 Physician Fee Schedule (PFS)
Agency: Centers for Medicare & Medicaid Services (CMS)
CMS requests comments on the 2022 Physician Fee Schedule published July 23, 2021.
- UnityPoint Clinic Comment on 2022 PFS
- CMS-1751-P: CMS Physician Fee Schedule Rule
- CMS-1751-F: CMS Physician Fee Schedule FINAL RULE
2022 Surprise Billing Part 1
Agency: Centers for Medicare & Medicaid Services (CMS)
CMS requests comments on the Surprise Billing Part 1 proposals published July 13, 2021.
2022 Home Health
Agency: Centers for Medicare & Medicaid Services (CMS)
CMS requests comments on the Home Health Prospective Payment System published July 7, 2021.
- UnityPoint at Home Comment on Home Health PPS
- CMS-1747-P: CMS Home Health PPS Rule
- CMS-1747-F: CMS Home Health FINAL RULE
Occupational Exposure to COVID-19 Emergency Temporary Standard
Agency: Occupational Safety and Health Administration (OSHA)
OSHA requests comments on the Occupational Exposure to COVID-19 Emergency Temporary Standard published June 21, 2021.
2022 Inpatient Prospective Payment System (IPPS)
Agency: Centers for Medicare & Medicaid Services (CMS)
CMS requests comments on the Medicare FY 2022 proposed rule related to IPPS rates, quality reporting and promoting interoperability program requirements.
- UnityPoint Health Comment on FY 2022 IPPS Proposed Rule
- CMS-1752-P Medicare Program: FY 2022 Inpatient Prospective Payment System
- The Academy Advisors (TAA) Comment Letter: FY 2022 IPPS Proposed Rule
2022 Inpatient Psychiatric Facilities (IPF)
Agency: Centers for Medicare & Medicaid Services (CMS)
CMS requests comments on the Medicare FY 2022 proposed rule related to IPF rates and quality reporting.
- UnityPoint Health Comment on FY 2022 IPF Proposed Rule
- CMS-1750-P Medicare Program: FY 2022 Inpatient Psychiatric Facilities
2022 Skilled Nursing Facilities(SNF)
Agency: Centers for Medicare & Medicaid Services (CMS)
CMS requests comments on the Medicare FY 2022 proposed rule related to SNF rates and quality reporting.
- UnityPoint Health Comment on FY 2022 SNF Proposed Rule
- CMS-1746-P Medicare Program: FY 2022 Skilled Nursing Facility
2022 Inpatient Rehabilitation Facility (IRF)
Agency: Centers for Medicare & Medicaid Services (CMS)
CMS requests comments on the Medicare FY 2022 proposed rule related to IRF rates and quality reporting.
- UnityPoint Health Comment on FY 2022 IRF Proposed Rule
- CMS-1748-P Medicare Program: FY 2022 Inpatient Rehabilitation Facility
2022 Hospice
Agency: Centers for Medicare & Medicaid Services (CMS)
CMS requests comments on the Medicare FY 2022 proposed rule related to hospice rates and quality reporting.
- UnityPoint Health Comment on FY 2022 Hospice Proposed Rule
- CMS-1754-P Medicare Program: FY 2022 Hospice
Proposed Modifications to the HIPAA Privacy Rule To Support, and Remove Barriers to, Coordinate Care and Individual Engagement
Agency: Health and Human Services (HHS)
HHS requests comment on the recommendations for modifications to the HIPAA privacy rule.
Recommended Changes to the 2010 Standards for Delineating Metropolitan and Micropolitan Statistical Areas
Agency: Office of Management and Budget (OMB)
OMB requests comment on the recommendations for changes to metropolitan and micropolitan statistical area standards.
- UnityPoint Health Comment on MSA Rural Definition, March 19, 2021
- The Office of Management and Budget Official Notice and Request
Strategies to Improve Patient Safety
Agency: Health and Human Services (HHS)
HHS requests comment on the draft report on effective strategies for reducing medical errors and increasing patient safety.
Most Favored Nations (MFN)
Agency: Center for Medicare & Medicaid Services (CMS)
CMS requests comment on the MFN Model, a new Medicare payment model under section 1115A of the Social Security Act.
COVID-19 Telehealth Program
Agency: Federal Communications Commission (FCC)
Request for Information on the COVID-19 Telehealth Program
Additional Information on the COVID-19 Telehealth Program
- Notice of Request for Information on COVID-19 Telehealth Program
- FCC Wireline Competition Docket Number 20-89
State Comments
Iowa Medicaid Inpatient Hospital Reimbursement Rate and Diagnosis-Related Group Weights
Agency: Iowa Medicaid Enterprise (IME)
IME requests comments on the proposed State Plan Amendment IA-21-0019: Medicaid Inpatient Hospital Reimbursement Rates and Diagnosis-Related Group Weights.
- UnityPoint Health comment letter on Iowa Medicaid Inpatient Hospital Reimbursement Rates and Diagnosis-Related Group Weights
- Proposed State of Iowa Plan Amendment IA-21-0019
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Iowa Medicaid Enterprise Bureau of Managed Care Quality Plan 2021
Agency: Iowa Department of Human Services | Iowa Medicaid Enterprise (IME)
IME requests comments on the 2021 Iowa Medicaid Enterprise Bureau of Managed Care Quality Plan.
- UnityPoint Health comment letter on Iowa Medicaid Enterprise Bureau of Managed Care Quality Plan 2021
- Iowa Medicaid Enterprise Bureau of Managed Cared Quality Plan 2021
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Home Health Low Utilization Payment Adjustment (LUPA) Rates
Agency: Iowa Department of Human Services | Iowa Medicaid Enterprise (IME)
IME requests comments on Iowa’s State Plan Amendment (SPA) IA-21-031: Medicaid Home Health Payment Adjustment (LUPA) Rates, published June 24, 2021.
Legislative Positions and Collaborative Sign-On Letters
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Hospital Acute Care at Home (AHCAH) Waiver
Lead Organization: Advance Care at Home Coalition
Audience: Congress — Representatives: Speaker Pelosi, McCarthy, Schumer and McConnell
Sign-on letter dated October 28, 2021 encourages congress to extend the Acute Hospital Care at Home (AHCAH) waiver for two to four years allowing health systems and providers to continue building on its success in achieving better outcomes for patients at a lower cost. This waiver has allowed Medicare beneficiaries the option to receive acute-level health care services in their home environment during the COVID-19 public health emergency (PHE).
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Priorities for Medicare Telehealth Reform
Lead Organization: Led by the Alliance for Connected Care, American Telemedicine Association, Consumer Technology Association, eHealth Initiative, HIMSS, Health Innovation Alliance, Partnership to Advance Virtual Care, and PCH Alliance
Audience: Congress — Senators Schumer and McConnell, Representatives Pelosi and McCarthy
Sign-on letter dated July 26, 2021. The letter calls for Congress to advance permanent telehealth reform focused on specific priorities:
- Removing arbitrary restrictions on where a patient must be located in order to utilize telehealth services;
- Ensuring federally qualified health centers, critical access hospitals, and rural health centers can furnish telehealth services;
- Authorizing the Secretary to allow additional telehealth practitioners, services, and modalities; and
- Removing restrictions on telemental health services.
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CMS FY 2022 IPPS Proposed Rule, Closing The Health Equity Gap
Lead Organization: The Academy Advisors (TAA)
Audience: Centers for Medicare and Medicaid Services (CMS) – Biden Administration
Sign-on letter dated June 28, 2021 requests CMS and the Administration to create a health equity taskforce, conduct an inventory of existing equity and partner to identify the root cause(s) of these disparities as well as aid in the planning and execution of innovative solutions.
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Pharmacy and Medically Underserved Areas Enhancement Act
Lead Organization: American Society of Hospital Pharmacists (ASHP)
Audience: Senators Grassley, Casey, Brown and Representatives Butterfield and McKinley
Sign-on letter dated June 28, 2021 expresses support for the Pharmacy and Medically Underserved Areas Enhancement Act (S. 1362/H.R. 2759). This legislation would remove barriers to providing optimal medication management to our patients.
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White Bagging and DSCSA
Lead Organization: American Society of Hospital Pharmacists (ASHP)
Audience: Food and Drug Administration (FDA)
Sign-on letter dated March 22, 2021 expresses concern that the payer-mandated drug distribution model, known as “white bagging” is jeopardizing patient safety and exacerbating supply chain security challenges that the Drug Supply Chain Security Act (DSCSA) sought to address.
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Making CMS Virtual Supervision Flexibility Permanent
Lead Organization: American Society of Hospital Pharmacists (ASHP)
Audience: Biden Transition Team – Department of Health and Human Services Agency Review Team
Sign-on letter dated January 5, 2021 requests to make permanent the current temporary regulatory flexibility provided by the Centers for Medicare & Medicaid Services (CMS) by allowing physicians to provide direct supervision of clinical staff virtually, using real-time audio/video technology.
Executive Order Summaries
Health Care Executive Order & Memorandum – January 28, 2021
Executive Orders Text:
Memorandum Text:
COVID-19 Executive Orders, Memorandum & Directive – January 20 & 21, 2021
Executive Orders Text:
- Organizing and Mobilizing the United States Government to Provide a Unified and Effective Response to Combat COVID-19 and to Provide United States Leadership on Global Health and Security
- Protecting the Federal Workforce and Requiring Mask-Wearing
- Supporting the Reopening and Continuing Operation of Schools and Early Childhood Education Priorities
- Ensuring a Data-Driven Response to COVID-19 and Future High Consequence Public Health Threats
- Promoting COVID-19 Safety in Domestic and International Travel
- Establishing the COVID-19 Pandemic Testing Board and Ensuring a Sustainable Public Health Workforce for COVID-19 and Other Biological Threats
- Improving and Expanding Access to Care and Treatment for COVID-19
- A Sustainable Public Health Supply Chain
- Protecting Worker Health and Safety
- Ensuring an Equitable Pandemic Response and Recovery
Memorandum Text:
Directive Text:
For Further Information:
Please email Cathy Simmons, Executive Director of Government and External Affairs.
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Government & External Affairs
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