2024 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
CY 2025 Hospital Outpatient Prospective Payment System
Agency: Centers for Medicare & Medicaid Services (CMS)
Date Submitted: September 9, 2024
This annual proposed rule revises the CY 2025 Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems; quality reporting programs, including the Hospital Inpatient Quality Reporting Program; health and safety standards for obstetrical services in hospitals and critical access hospitals; prior authorization; requests for information; Medicaid and CHIP continuous eligibility; Medicaid clinic services four walls exceptions; individuals currently or formerly in custody of penal authorities; revision to Medicare special enrollment period for formerly incarcerated individuals; and all-inclusive rate add-on payment for high-cost drugs provided by Indian Health Service and tribal facilities.
- UnityPoint Health Comment Letter
- CY 2025 Hospital Outpatient Prospective Payment System Proposed Rule
CY 2025 Home Health Prospective Payment System
Agency: Centers for Medicare & Medicaid Services (CMS)
Date Submitted: August 26, 2024
This annual proposed rule revises the CY 2025 Home Health Prospective Payment System rate update; Home Health Quality Reporting Program requirements; Home Health Value-Based Purchasing Expanded Model requirements; Home Intravenous Immune Globulin (IVIG) items and services rate update; and other Medicare policies.
CY 2025 Physician Fee Schedule
Agency: Centers for Medicare & Medicaid Services (CMS)
Date Submitted: September 9, 2024
This annual proposed rule revises the CY 2025 payment policies under the Physician Fee Schedule and other changes to Part B payment and coverage policies; Medicare Shared Savings Program requirements; Medicare Prescription Drug Inflation Rebate Program; and Medicare overpayments.
MSSP Significant, Anomalous, and Highly Suspect Billing Activity
Agency: Centers for Medicare & Medicaid Services (CMS)
Date Submitted: July 29, 2024
This proposed rule sets forth methodology to mitigate the impact of Significant, Anomalous, and Highly Suspect (SAHS) billing activity on Medicare Shared Savings Program (MSSP) financial calculations in CY 2023.
- UnityPoint Health Comment Letter
- MSSP Significant, Anomalous, and Highly Suspect Billing Activity Proposed Rule
Increasing Organ Transplant Access (IOTA) Model
Agency: Centers for Medicare & Medicaid Services (CMS)
Date Submitted: July 16, 2024
This proposed rule solicits input on alternative payment model updates and the new Increasing Organ Transplant Access (IOTA) Model.
Cyber Incident Reporting for Critical Infrastructure Act (CIRCIA) Reporting Requirements
Agency: Cybersecurity and Infrastructure Security Agency (CISA)
Date Submitted: July 3, 2024
This proposed rule solicits input on cyber incident reporting and purports to implement requirements under the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (CIRCA).
Medicare Drug Price Negotiation Program – Draft Guidance
Agency: Centers for Medicare & Medicaid Services (CMS)
Date Submitted: July 2, 2024
This draft guidance proposes to implement the Inflation Reduction Act’s (IRA) maximum fair price provisions.
FY 2025 Hospital Inpatient Prospective Payment System
Agency: Centers for Medicare & Medicaid Services (CMS)
Date Submitted: June 10, 2024
This annual proposed rule revises the Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and policy changes and FY 2025 rates; quality programs requirements; and other policy-related changes, including to the Medicaid Program and the Children’s Health Insurance Program.
- UnityPoint Health Comment Letter
- FY 2025 Hospital Inpatient Prospective Payment System Proposed Rule
FY 2025 Hospice Wage Index and Payment Rate Update
Agency: Centers for Medicare & Medicaid Services (CMS)
Date Submitted: May 24, 2024
This annual proposed rule revises the FY 2025 Hospice Wage Index and payment rate update; Hospice Conditions of Participation updates; and Hospice Quality Reporting Program requirements.
340B Senate Bipartisan Discussion Draft and Request for Information (RFI) issued February 2, 2024
Agency: U.S. Senate – “Gang of Six”
Date Submitted: April 1, 2024
This discussion draft and supplemental request for information solicits input on the “Supporting Underserved and Strengthening Transparency, Accountability, and Integrity Now and for the Future of 340B Act” or the “SUSTAIN 340B Act”.
- UnityPoint Health Comment Letter
- Senate Letter to 340B Stakeholders
- SUSTAIN 340B Act Discussion Draft
- 340B Discussion Draft Explanatory Document
Medicare Appeal Rights for Certain Changes in Patient Status
Agency: Department of Health and Human Services
Date Submitted: February 26, 2024
These proposed notice and appeals processes would apply to certain Medicare beneficiaries who are initially admitted as hospital inpatients but are subsequently reclassified as outpatients receiving observation services during their hospital stay and meet other eligibility criteria.
21st Century Cures Act: Establishment of Disincentives for Health Care Providers That Have Committed Information Blocking
Agency: Department of Health and Human Services
Date Submitted: January 2, 2024
This proposed rule would implement the provision of the 21st Century Cures Act specifying that a health care provider determined by the HHS Inspector General to have committed information blocking shall be referred to the appropriate agency to be subject to appropriate disincentives set forth through notice and comment rulemaking.
State Comments
___________________________________________________________
No formal comments submitted
Legislative Positions and Collaborative Sign-On Letters
Compact Licensure Flexibilities
Leading Organization: Interstate Healthcare Collaborative
Audience: Congressional Leaders
UnityPoint Health participated in a Sign-On Letter dated February 22, 2024, urging congressional leaders to support of the States Handling Access to Reciprocity for Employment (SHARE) Act, H.R. 1310. This legislation is aimed to help address workforce shortages by improving licensure compact implementation. Specifically, the SHARE Act requires the Federal Bureau of Investigation (FBI) to make available criminal history record information to a state occupational or professional licensing authority for background checks of individuals seeking a license under an interstate compact.
Telehealth Flexibilities
Leading Organization: Alliance for Connected Care
Audience: Congressional Leaders
UnityPoint Health participated in a Sign-On Letter dated February 22, 2024, urging congressional leaders to act on telehealth earlier this year, to allow for implementation time prior to the expiration of statutory restriction on December 31, 2024. Without timely congressional action, access to telehealth services would be jeopardized due to challenges with 2024 timelines needed to ensure 2025 benefits – such as federal payment rules, employer and health plan benefit decisions, and health provider workforce decisions.
Wisconsin 12-Month Postpartum Extension
Leading Organization: 12-Month Postpartum Extension coalition
Audience: Wisconsin Assembly
UnityPoint Health signed on to a Coalition Memo sent to Assembly members to urge their support of 12-month postpartum Medicaid coverage. Wisconsin is one of only two states that does not provide this coverage. Presently pregnant women who are eligible for Medicaid have coverage only through the end of the month in which their 60-day postpartum period ends. Meriter houses the largest birthing center in the state of Wisconsin.
Advanced APM Promoting Interoperability and Certified EHR Technology Requirements
Leading Organization: American Medical Association
Audience: Centers for Medicare & Medicaid Services (CMS)
UnityPoint Accountable Care (UAC) participated in a Sign-On Letter dated April 10, 2024, urging CMS to repeal new Promoting Interoperability (PI) and Certified EHR Technology (CEHRT) requirements for Advanced Alternative Payment Models (APMs). The letter had over 100 ACO signatories, including UnityPoint Accountable Care, along with over 30 stakeholder groups.
Support for PACE Center Expansion Site in Bettendorf, Iowa
Leading Organization: Congresswoman Mariannette Miller-Meeks, Congresswoman Ashley Hinson, Congressman Zach Nunn, Congressman Randy Feenstra, and Senator Joni Ernst
Audience: Centers for Medicare & Medicaid Services (CMS)
UnityPoint Health applied to expand new Program of All-Inclusive Care for the Elderly (PACE) location in the Quad Cities. Iowa’s Congressional delegation led by Congresswoman Miller-Meeks penned a Letter of Support urging timely approval of the Bettendorf Center by CMS. This support was also crucial to enable the future openings of PACE Center locations in Hiawatha and Waterloo, Iowa. UnityPoint Health has operated a PACE Center in Sioux City, Iowa, since 2008.
Genetic Counselors Recognition as Providers under Medicare
Leading Organization: National Society of Genetic Counselors
Audience: Congress
UnityPoint Health participated in a Sign-On Letter urging Congress to include federal legislation in the 2024 end-of-year package to have genetic counselors recognized as providers by Medicare. This would create a pathway to allow providers to bill Medicare & Medicaid for genetic counseling services. UnityPoint Health employs genetic counselors in our Cedar Rapids (IA), Des Moines (IA) and Wisconsin (WI) markets.
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.
Contact Us
UnityPoint Health
Government & External Affairs
1776 West Lakes Parkway
West Des Moines, Iowa 50266