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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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

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.

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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. 

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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
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.

 

Health Care Executive Order & Memorandum – January 28, 2021

UnityPoint Health Summary

Executive Orders Text:

Memorandum Text:

 

COVID-19 Executive Orders, Memorandum & Directive – January 20 & 21, 2021

UnityPoint Health Summary

Executive Orders Text:

Memorandum Text:

Directive Text:

 

 

 

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