2018 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
Medicare Advantage (MA)
Agency: Centers for Medicare & Medicaid Services (CMS)
Proposed Changes Policy and Technical Changes to the MA, Medicare Prescription Drug Benefit, Program of All-Inclusive Care for the Elderly (PACE), Medicaid Fee-for-Service, and Medicaid Managed Care Programs for Years 2020 and 2021
- UnityPoint Health Comment on MA, December on MA, December 2018
- UnityPoint Health Comment proposing Future State for ACOs and MA – “MA Plus” Model, December 2018
Additional Information on the Proposed Rule for MA
- Proposed Rule on MA, November 2018
International Pricing Index (IPI) Model – Part B Drug Pricing Transparency
Agency: Centers for Medicare & Medicaid Services (CMS)
Advanced Notice of Proposed Rulemaking for Payment related to Certain Separately Payable Part B Drugs
Additional Information on the Advanced Notice of Proposed Rulemaking on the IPI Model
- Advanced Notice of Proposed Rulemaking on the IPI Model, October 2018
Home Infusion Therapy Requirements
Agency: Centers for Medicare & Medicaid Services (CMS)
Proposed Changes to Definition of “Infusion Drug Administration Calendar Day”
Additional Information on the Final Rule with Comment Period for Home Infusion Therapy Requirements
Health Reimbursement Arrangements (HRAs)
Agency: Internal Revenue Service; Employee Benefits Security Administration; Centers for Medicare & Medicaid Services (CMS)
Proposed Changes to Allow Integrating HRAs with Individual Health Insurance Coverage
Additional Information on the Proposed Rule for HRAs
- Proposed Rule on HRAs, October 2018
Section 1332 Waivers – State Relief and Empowerment Waivers
Agency: Centers for Medicare & Medicaid Services (CMS)
Proposed Changes to State Relief and Empowerment Waivers
Additional Information on the Proposed Rule for State Relief and Empowerment Waivers
- Proposed Rule for State Relief and Empowerment Waivers, October 2018
Direct to Consumer (DTC) Prescription Drug Advertising
Agency: Centers for Medicare & Medicaid Services (CMS)
Proposed Changes to Drug Pricing Transparency
- UnityPoint Health Comment on Drug Pricing Transparency, December 2018
Additional Information on the Proposed Rule for Drug Pricing Transparency
- Proposed Rule for Drug Pricing Transparency, October 2018
340B Drug Pricing Program
Agency: Health Resources and Services Administration (HRSA)
Proposed Changes to 340B Drug Pricing Program Ceiling Price and Manufacturer Civil Monetary Penalties
Additional Information on the Proposed Rule for the 340B Drug Pricing Program
- Proposed Rule for the 340B Drug Pricing Program, November 2018
CMS Red Tape
Agency: Centers for Medicare & Medicaid Services (CMS)
Proposed Changes to Eliminate Regulatory Barriers
Additional Information on the Proposed Rule to Eliminate Regulatory Barriers
- Proposed Rule to Eliminate Regulatory Barriers, September 2018
IMPACT Act and Social Risk Factors
Agency: Health & Human Services (HHS)
Request for Information (RFI) on Approaches to Beneficiaries with Social Risk Factors
- UnityPoint Health Comment on Social Risk Factor RFI, November 2018
Additional Information on the RFI on Approaches to Beneficiaries with Social Risk Factors
Medicare Shared Savings Program
Agency: Centers for Medicare & Medicaid Services (CMS)
Proposed Changes to Medicare Shared Savings Program; Accountable Care Organizations Pathways to Success
- UnityPoint Accountable Care Comment on Proposed Rule for the Medicare Shared Savings Program, October 2018
- UnityPoint Health Comment proposing Future State for ACOs – “MA Plus” Model, October 2018
Additional Information on the Proposed Rule for the Medicare Shared Savings Program
Medicare Outpatient Prospective Payment System
Agency: Centers for Medicare & Medicaid Services (CMS)
Proposed Changes to Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems and Quality Reporting Programs
- UnityPoint Health Comment on Proposed Rule for the Outpatient Prospective Payment System, September 2018
Additional Information on the Proposed Rule for the Medicare Outpatient Prospective Payment System
- Proposed Rule for the Medicare Outpatient Prospective Payment System, July 2018
- Final Rule and CMS Summary for the Medicare Outpatient Prospective Payment System, November 2018
Medicare Physician Fee Schedule
Agency: Centers for Medicare & Medicaid Services (CMS)
Proposed Rule for the Physician Fee Schedule and Other Revisions to Part B for Calendar Year 2019, Medicare Shared Savings Program Requirements, and the Quality Payment Program
Additional Information on the Proposed Rule for the Medicare Physician Fee Schedule
- Proposed Rule for the Medicare Physician Fee Schedule, July 2018
- Final Rule and CMS Summary for the Medicare Physician Fee Schedule, November 2018
Medicare Advantage Quality Payment Arrangement Incentive (MAQI) Demonstration Information Collection
Agency: Centers for Medicare & Medicaid Services (CMS)
Proposed Information Collection for MAQI Demonstration
Additional Information on the Proposed Information Collection for MAQI Demonstration
Medicare Home Health Prospective Payment System (HH PPS)
Agency: Centers for Medicare & Medicaid Services (CMS)
Proposed Rule for the 2019 Home Health Payment and Case-Mix Adjustments Update and Other Home Health Regulations on Value-Based Purchasing, Home Infusion Therapy, and National Accrediting Organizations
- UnityPoint Health Comment on the HH PPS, August 2018
Additional Information on the HH PPS Proposed Rule
- Proposed Federal Rule on the HH PPS, July 2018
- Final Rule and CMS Summary for the HH PPS Proposed Rule, November 2018
Physician Self-Referral Law Request for Information
Agency: Centers for Medicare & Medicaid Services (CMS)
Request for public input on current regulatory barriers for coordinated care under the Physician Self-Referral Law, also known as the Stark Law.
Additional Information on the Physician Self-Referral Law Request for Information
Home Health Pre-Claim Review Demonstration
Agency: Centers for Medicare & Medicaid Services (CMS)
Reinstatement of a proposed Demonstration to institute a voluntary pre-claim or post-payment review process for Home Health Agencies in five states, including Illinois.
Additional Information on the Home Health Pre-Claim Review Demonstration
Drug Pricing Blueprint Request for Information (RFI)
Agency: Health & Human Services (HHS)
Request for Information for HHS Drug Pricing Blueprint to increase competition, better negotiations, create incentives to lower list prices, and reduce patient out-of-pocket spending.
Additional Information on the HHS Drug Pricing Blueprint
Medicare Hospice Payment Update
Agency: Centers for Medicare & Medicaid Services (CMS)
Proposed Rule for FY 2019 Hospice Wage Index and Payment Rate Update and Hospice Quality Reporting Requirements.
Additional Information on the Hospice Proposed Rule
- Proposed Federal Rule on the Hospice Payment Update, May 2018
- Final Rule and CMS Summary for the Hospice Payment Update, August 2018
Medicare Inpatient Prospective Payment System (IPPS)
Agency: Centers for Medicare & Medicaid Services (CMS)
Proposed Rule for Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and Proposed Policy Changes and Fiscal Year 2019 Rates
Additional Information on the IPPS Proposed Rule
- Proposed Federal Rule on the IPPS, May 2018
- Final Rule and CMS Summary for the IPPS, August 2018
Direct Provider Contracting (DPC)
Agency: Centers for Medicare & Medicaid Services (CMS)
Request for input on DPC between payers and primary care or multi-specialty groups to inform potential testing of a DPC model within the Medicare fee-for-service (FFS) program (Medicare Parts A and B), Medicare Advantage program (Medicare Part C), and Medicaid.
Additional Information on Potential Models for DPC
Price and Information Transparency
Agency: U.S. Senate
Request for Stakeholder Input on Health Care Pricing and Information Transparency from a Bipartisan Group of Senators.
Additional Information on Price and Information Transparency
Clinical Laboratory Improvement Amendments (CLIA) Modernization
Agency: Centers for Medicare and Medicaid Services
Request for Information on Revisions to Personnel Regulations, Proficiency Testing Referral, Histocompatibility Regulations and Fee Regulations Under CLIA.
Additional Information on CLIA
Association Health Plans
Agency: Department of Labor
Definition of ”Employer” Under Section 3(5) of the Employee Retirement Income Security Act of 1974 (ERISA)—Association Health Plans.
Additional Information on Association Health Plans
- Proposed Federal Rule on Association Health Plans, January 2018
- Final Rule and DOL Summary for Association Health Plans, June 2018
Anti-Kickback Statute (AKS)
Agency: Office of the Inspector General (OIG), Health and Human Services (HHS)
Solicitation of New Safe Harbors and Special Fraud Alerts.
Additional Information on the AKS
Hospital-Wide Mortality Measurement
Agency: Center for Medicare & Medicaid Innovation (CMS Innovation Center)
Two measures of hospital-wide mortality (patient deaths) were developed.
Additional Information on Hospital-Wide Mortality Measurement
State Comments
3-Month Retroactive Coverage for Skilled Nursing Facility Residents
Agency: Iowa Department of Human Services
Reinstate a 3-month retroactive Medicaid coverage benefit for applicants who are residents of a nursing facility at the time of application and are otherwise Medicaid-eligible.
Additional Information on the 3-Month Retroactive Coverage Amendment
Program of All-Inclusive Care for The Elderly (PACE) State Plan Amendment
Agency: Iowa Medicaid Enterprise, Iowa Department of Human Services
Request for input on the PACE State Plan Amendment related to development of PACE capitation rates, counties served by the PACE program, and alignment of approved methodologies and processes.
Additional Information on PACE State Plan Amendment
Legislative Positions and Collaborative Sign-On Letters
Emergent Diagnosis Codes
Lead Organizations: UnityPoint Health, Genesis Health System, Mercy Health Network and the Iowa Chapter of the American College of Emergency Physicians
Audience: Iowa Medicaid Enterprise
Sign on letter and list of requested codes for reinstatement from August 2018 requesting to reinstate specific codes as emergent.
Rural Health Care in America: Challenges and Opportunities
Lead Agency: United States Senate Committee on Finance
Audience: Congressional Leadership
Submitted testimony and opening statement to the United States Senate Committee on Finance by Ms. Susan Thompson, Senior Vice President of Integration and Optimization, UnityPoint Health, and Chief Executive Officer, UnityPoint Accountable Care. Ms. Thompson provided testimony as part of the Committee hearing, “Rural Health Care in America: Challenges and Opportunities” on May 24, 2018. Video of the entire hearing can be found here.
Reinsurance
Lead Agency: National Coalition on Health Care
Audience: Congressional Leadership
Sign-on letter dated March 2018 to urge Congressional action to stabilize the Health Insurance Marketplace.
Cigarette Tax – Iowa
Lead Agencies: American Cancer Society Cancer Action Network, Iowa Cigarette Tax Coalition
Audience: Iowa Legislators
Sign-on letter from January 2018 to encourage increase in cigarette tax and to invest in tobacco use prevention and cessation program.
Extenders Package
Lead Agency: American Academy of Family Physicians
Audience: Congressional Leadership
Sign-on letter dated January 2018 to support retroactive and future funding for federal health care programs and services, including the Community Health Center Fund, Medicaid Disproportionate Share Hospital (DSH) payment funding, Medicare Therapy Cap Extension, Teaching Health Center Graduate Medical Education Program, Maternal Infant and Early Childhood Home Visiting Program, National Health Service Corps, and Physician Fee Schedule (PFS) GPCI Parity Policy.
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