2022 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
National Directory of Healthcare Providers and Services RFI
Agencies: Centers for Medicare & Medicaid Services (CMS), Health and Human Services (HHS)
CMS solicits public comments on establishing a National Directory of Healthcare Providers & Services (NDH) that could serve as a ‘‘centralized data hub’’ for healthcare provider, facility, and entity directory information nationwide.
- UnityPoint Health Comment Letter
- CMS-0058-NC: National Directory of Healthcare Providers and Services Request of Information
- American Hospital Association (AHA) Comment Letter
- Premier Inc. Comment Letter
No Surprises Request of Information
Agencies: Department of the Treasury, U.S. Department of Labor, Department of Health, and Human Services (Departments) and Office of Personnel Management (OPM)
The Departments and OPM have requested information on transferring data from providers and facilities to plans, issuers, and carriers as well as a number of other policies considerations around Advance Explanation of Benefits and Good Faith Estimates.
- UnityPoint Health Comment Letter
- CMS-9900-NC: Advance Explanations of Benefits and Good Faith Estimates for Covered Individuals Request
Cyber Incident Reporting for Critical Infrastructure Request of Information
Agency: Cybersecurity and Infrastructure Security Agency
CISA has requested public input on potential aspects of the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (CIRCIA) proposed regulation.
- UnityPoint Health Comment Letter
- CISA-2022-0010: Cyber Incident Reporting for Critical Infrastructure Request
MACRA Request for Information
Requesters: Representatives Bera, Bucshon, Schrier, Burgess, Blumenauer, Wenstrup, Schneider, and Miller-Meeks
Members of Congress have requested feedback on actions Congress could take to stabilize the Medicare payment system, without dramatic increases in Medicare spending, while ensuring successful value-based care incentives are in place.
Medicaid Program and Children’s Health Insurance Program (CHIP) Core Set Reporting
Agencies: Centers for Medicare and Medicaid Services (CMS)
CMS has requested comment on their proposed requirements for mandatory reporting on core sets of measures that assess the quality of health care provided to child beneficiaries in Medicaid and CHIP, the quality of behavioral health care for Medicaid-eligible adults, and the quality of health or behavioral health services for Medicaid-eligible individuals enrolled in health home programs.
Nondiscrimination in Health Programs and Activities
Agencies: Centers for Medicare and Medicaid Services (CMS); Office for Civil Rights (OCR), The Department of Health and Human Services (HHS)
HHS is requesting comment on proposed regulations to implement the nondiscrimination requirements of Section 1557.
2023 Outpatient Prospective Payment System (OPPS)
Agency: Centers for Medicare & Medicaid Services (CMS)
CMS requests comments on the 2023 Hospital Outpatient Prospective Payment System proposed rules.
2023 Physician Fee Schedule (PFS)
Agency: Centers for Medicare & Medicaid Services (CMS)
CMS requests comments on the 2023 Physician Fee Schedule proposed rules.
- UnityPoint Health Comment on PFS 2023
- CMS-1770-P CMS 2023 Physician Fee Schedule Rule
- CMS-1770-F PFS Final Rule
Rural Emergency Hospitals (REH) Conditions of Participation (CoPs)
Agency: Centers for Medicare & Medicaid Services (CMS)
CMS requests comments on the Conditions of Participation (CoPs) for Rural Emergency Hospitals (REH) and Critical Access Hospital CoP Updates.
2023 Home Health
Agency: Centers for Medicare & Medicaid Services (CMS)
CMS requests comments on the 2023 Home Health Prospective Payment Rate Updates.
- UnityPoint Health Comment on FY 2023 HH
- CMS-1766-P 2023 Home Health Prospective Payment Rate Rule
- CMS-1766-F 2023 HH Final Rule
2023 Clinical Laboratory Improvement Amendments (CLIA)
Agency: Centers for Medicare & Medicaid Services (CMS)
CMS requests comments on the Clinical Laboratory Improvement Amendments of 1988 (CLIA) Fees; Histocompatibility, Personnel, and Alternative Sanctions for Certificate of Waiver Laboratories 2023 proposals.
- UnityPoint Health Comment on FY 2023 CLIA
- CMS-3326-P Clinical Laboratory Improvement Amendments Rule
2023 Inpatient Prospective Payment System (IPPS)
Agency: Centers for Medicare & Medicaid Services (CMS)
CMS requests comments on the Medicare FY 2023 proposed rule related to IPPS rates and quality reporting program requirements.
- UnityPoint Health Comment on FY 2023 IPPS Proposed Rule
- CMS-1771-P Medicare Program: FY 2023 Inpatient Prospective Payment System
- The Academy Advisors (TAA) Comment Letter: FY 2023 IPPS Proposed Rule
- CMS-1771-F FINAL 2023 IPPS Rule
2023 Skilled Nursing Facilities (SNF)
Agency: Centers for Medicare & Medicaid Services (CMS)
CMS requests comments on the Medicare FY 2023 proposed rule related to SNF rates and quality reporting.
- UnityPoint Health Comment on FY 2023 SNF Proposed Rule
- CMS-1765-P Medicare Program: FY 2023 Skilled Nursing Facility
- CMS-1765-F FINAL 2023 SNF Rule
2023 Hospice
Agency: Centers for Medicare & Medicaid Services (CMS)
Published: April 4, 2022
Submitted: May 31, 2022
CMS requests comments on the Medicare FY 2023 proposed rule related to Hospice rates and quality reporting.
2023 Inpatient Rehabilitation Facilities (IRF)
Agency: Centers for Medicare & Medicaid Services (CMS)
Published: April 6, 2022
Submitted: May 31, 2022
CMS requests comments on the Medicare FY 2023 proposed rule related to IRF rates and quality reporting.
2023 Inpatient Psychiatric Facilities (IPF)
Agency: Centers for Medicare & Medicaid Services (CMS)
Published: April 4, 2022
Submitted: May 31, 2022
CMS requests comments on the Medicare FY 2023 proposed rule related to IPF rates and quality reporting.
OSHA: Occupational Exposure to COVID-19; ETS – Additional Comments
Agency: Occupational Safety and Health Administration (OSHA)
Published: March 23, 2022
Submitted: April 22, 2022
OSHA is requesting additional information regarding the need for, and impact of the potential provisions and approaches specified in the ETS as well as additional studies, information and data related to the delta and omicron variants since the close of OSHA’s initial comment period in August 2021.
CDC: Clinical Practice Guideline for Prescribing Opioids
Agency: Centers for Disease Control and Prevention (CDC)
Published: February 10, 2022
Submitted: April 11, 2022
The CDC is requesting information on the 2022 Clinical Practice Guidelines for Prescribing Opioids.
- UnityPoint Health Comment Letter
- CDC Clinical Practice Guideline for Prescribing Opioids – Draft
- CDC Overview of Community Engagement and Public Comments
ONC: Electronic Prior Authorization
Agency: Office of the National Coordinator for Health Information Technology (ONC)
Published: January 24, 2022
Submitted: March 25, 2022
ONC is requesting information on electronic prior authorization standards, implementation specifications, and certification criteria.
CMS: CY 2023 MA and Part D Benefit Programs
Agency: Centers for Medicare & Medicaid Services (CMS)
Published: January 12, 2022
Submitted: March 7, 2022
CMS is requesting comments on contract year 2023 proposed changes for MA and Part D.
White House OSTP: Connected Health RFI
Agency: White House Office of Science and Technology Policy (OSTP)
Published: January 5, 2022
Submitted: February 28, 2022
The White House OSTP requests input from community health stakeholders, technology developers, and other interested parties about how digital health technologies are used, or could be used in the future, to transform community health, individual wellness, and health equity.
CMS: Transplant Programs & Organ Procurement
Agency: Centers for Medicare & Medicaid Services (CMS)
Published: December 3, 2021
Submitted: February 1, 2022
CMS requests information on health and safety requirements for transplant programs, organ procurement organizations, and end-stage renal diseases facilities, published December 3, 2021.
- UnityPoint Health comment on CMS Transplant Programs & Organ Procurement
- CMS-3409-NC Request for Information Transplant Program and Organ Procurement
OIG: Modernization Initiative RFI
Agency: Office of Inspector General (OIG)
Published: September 24, 2021
Submitted: January 31, 2022
OIG requests information on it’s modernization initiative to improve its publicly available resources, published September 24, 2021.
CMS: COVID-19 Health Care Staff Vaccination
Agency: Centers for Medicare & Medicaid Services (CMS)
Published: November 5, 2021
Submitted: January 4, 2022
CMS requests comments on Medicare and Medicaid; Omnibus COVID-19 Health Care Staff Vaccination, published November 5, 2021.
State Comments
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IA DHS: Community Mental Health Centers & Integrated Chronic Health Homes Amendments
Agency: Iowa Department of Human Services
Published: February 23, 2022
Submitted: March 15, 2022
Iowa DHS is requesting comments on proposed rule making related to Community Mental Health Centers (ARC 6211C) & Integrated and Chronic Health Homes (ARC 6206C).
- UnityPoint Health Comment Letter on IDHS ARC 6211C & ARC 6206C
- Notice of Intended Action on ARC 6211C
- Notice of Intended Action on ARC 6206C
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WI GOV: Enactment of SB 259 Genetic Counseling Licensure
Agency: Wisconsin Governor Tony Evers
Letter Sent: March 10, 2022
UnityPoint Health Meriter, in partnership with UW Health, encourages Governor Tony Evers to sign SB 259 (licensure of genetic counselors) into law.
Legislative Positions and Collaborative Sign-On Letters
Interstate Healthcare Collaborative Telehealth Letter to Congress
Leading Organization: Interstate Healthcare Collaborative
Audience: Congress- Leader Schumer, Leader McConnell, Speaker Pelosi and Leader McCarthy
A Sign-on letter dated November 3, 2022, was submitted to congressional leadership requesting the House and Senate work together in an end-of-year package to provide stability on telehealth policy by extending Medicare and other flexibilities through the end of 2024. In addition to Medicare fee-for-service telehealth flexibilities, the letter also requests a year end package to include extension of the Center for Medicare and Medicaid Services (CMS)’s Acute Hospital at Home program and a continuation of the Drug Enforcement Administration (DEA) in-person requirement waiver for prescribing of controlled substances via telehealth.
Telehealth Stakeholder Letter to Congress
Co-Leading Organizations: Alliance for Connected Care, American Telemedicine Association (ATA), College of Healthcare Information Management Executives (CHIME), Connected Health Initiative, Consumer Technology Association, Executives for Health Innovation, Health Innovation Alliance, HIMSS, and the Partnership to Advance Virtual Care.
Audience: Congress- Senate Majority Leader: Senator Charles Schumer & Senate Minority Leader: Senator Mitch McConnell
Sign-on letter dated September 13, 2022 was submitted to the Senate urging their action this fall to ensure certainty for telehealth services. Specifically, requesting the Senate to pass a two-year extension of important telehealth policies, while continuing to push for a permanent extension, that includes provisions to lift provider and patient location limitations, remove in-person requirements for tele-mental health, ensure continued access to clinically appropriate controlled substances without in-person requirements, and increase access to telehealth services in the commercial market.
Preserving Patient Access to Home Infusion Act Sign On Letter
Lead Organization: National Home Infusion Association (NHIA)
Audience: Congress
Sign-on letter dated August 24, 2022 was submitted by NHIA urging Congress to pass The Preserving Patient Access to Home Infusion Act (S. 2652 / H.R. 5067).
DOJ & FTC’s Request for Information on Merger Enforcement
Lead Organization: The Academy Advisors (TAA)
Audience: Department of Justice and Federal Trade Commission
Sign-on letter dated April 19, 2022 was submitted by TAA on behalf of members in response to the DOJ and FTC’s request of information on merger enforcement.
Hospital Acute Care at Home (AHCAH) Waiver
Lead Organization: Wisconsin Hospital Association
Audience: Congress- Senate Finance: Chairman-Wyden & Ranking Member Crapo, Ways & Means: Chairman Neal & Ranking Member Brady
Sign-on letter dated March 21, 2022 encourages the Senate Finance Committee and Ways and Means Committee to quickly advance the Hospital Inpatient Service Modernization Act (H.R. 7053 / SD. 3792) extend the Acute Hospital Care at Home (AHCAH) waiver 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).
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.
For Further Information:
Please email Cathy Simmons, Executive Director of Government and External Affairs.
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