2017 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

Program of All-Inclusive Care for the Elderly (PACE) Stream 3 Quality Measures

Agency: Centers for Medicare & Medicaid Services (CMS)
Requests input on three new PACE quality measures on emergency department (ED) use and flu immunizations for participants and staff.

Additional Information on the PACE quality measures

Program of All-Inclusive Care for the Elderly (PACE) Stream 2 Quality Measures

Agency: Centers for Medicare & Medicaid Services (CMS)
Requests input on four new PACE quality measures related to advanced directives and their review, nursing home status, and depression treatment.

Additional Information on the PACE quality measures

New Direction Request for Information (RFI)

Agency: Center for Medicare & Medicaid Innovation (CMS Innovation Center)
Solicit input on future organizational direction for the CMS Innovation Center.

Additional Information on the New Direction RFI

Program of All-Inclusive Care for the Elderly (PACE) Application Modifications

Agency: Centers for Medicare & Medicaid Services (CMS)
Request for public comment on modifications to the PACE application.

Additional Information on the PACE Application Modifications

Protecting Access to Medicare Act (PAMA) 2018 Regulations

Agency: Centers for Medicare & Medicaid Services (CMS)
Calendar Year 2018 Medicare Clinical Laboratory Fee Schedule (CLFS) Final Payment Rates and Cross-walking / Gap-filling Determinations.

Additional Information on the PAMA 2018 Regulations

Mandatory Bundled Payment Cancellation

Agency: Center for Medicare & Medicaid Innovation (CMS Innovation Center)
Cancels the Episode Payment Models (EPMs) and Cardiac Rehabilitation (CR) Incentive Payment Model and rescinds the regulations governing these models.

Additional Information on the Mandatory Bundled Payment Cancellation

Medicare Home Health Prospective Payment System (PPS)

Agency: Centers for Medicare & Medicaid Services (CMS)
Revisions to Calendar Year 2018 PPS Rate Update, Calendar Year 2019 Case-Mix Adjustment Methodology Refinements, and Quality Reporting Requirements.

Additional Information on the Home Health PPS

Medicare Outpatient Prospective Payment System (OPPS)

Agency Centers for Medicare & Medicaid Services (CMS)
Revisions to the Hospital OPPS, Ambulatory Surgical Center (ASC) Payment System, and Quality Reporting Programs for Calendar Year 2018.

Additional Information on the Medicare OPPS

Medicare Physician Fee Schedule (PFS)

Agency: Centers for Medicare & Medicaid Services (CMS)
Revisions to PFS and other Medicare Part B Payment Policies for Calendar Year 2018; Medicare Shared Savings Program Requirements; and Medicare Diabetes Prevention Program.

Additional Information on the Medicare PFS

Medicaid Retroactive Eligibility

See State Comments – Comments to Centers for Medicare & Medicaid Services (CMS) were submitted September 2017 in conjunction with Iowa Department of Human Services (DHS) comments.

Medicaid Disproportionate Share Hospitals (DSH)

Agency: Centers for Medicare & Medicaid Services (CMS)
Provides methodology to implement the Affordable Care Act (ACA) requirement for annual allotment reductions to state Medicaid DSH beginning Fiscal Year 2018.

Additional Information on Medicaid DSH

Medicare Red Tape Relief Project

Agency: U.S. House of Representatives – Ways and Means Health Subcommittee
An initiative to deliver relief from the regulations and mandates that impede care for Medicare beneficiaries.

Additional Information on the Medicare Red Tape Relief Project

Quality Payment Program (QPP)

Agency: Centers for Medicare & Medicaid Services (CMS)
Updates for the second and future years of the QPP, including the All-Payer Model, to provide annual payment adjustments for Medicare Part B providers as envisioned under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).

Additional Information on the Quality Payment Program

Federal Regulatory Relief

Agency: Health and Human Services (HHS)
Regulatory barrier list provided to HHS Secretary Tom Price during Quincy, Illinois visit to Quincy Medical Group.

Market Stabilization Request for Information (RFI)

Agency: Centers for Medicare & Medicaid Services (CMS)
Solicit input on the regulatory structure of the individual and small group health plan markets.

Additional Information on the Market Stabilization RFI

Medicare Hospice Payment Update

Agency: Centers for Medicare & Medicaid Services (CMS)
2018 updates for Hospice wage and payments as well as quality measures.

Additional Information on the Medicare Hospice Payment Update

Mandatory Bundled Payments Delay Interim Final Rule

Agency: Centers for Medicare & Medicaid Services (CMS)
Delay mandatory bundled payment models until October 1, 2017.

Additional Information on the Mandatory Bundles Payment Delay

Pediatric Alternative Payment Model Request for Information (RFI)

Agency: Center for Medicare & Medicaid Innovation (CMS Innovation Center)
Solicit input on integrated pediatric service delivery, payment and incentive arrangements, and quality measures.

Additional Information on the Pediatric Alternative Model RFI

Program of All-Inclusive Care for the Elderly (PACE) Innovation Model Request for Information (RFI)

Agency: Centers for Medicare & Medicaid Services (CMS)
Solicit input on parameters for a population health, capitated-payment model that would be similar to the PACE model but targeted to different populations, including a model for a younger disabled population.

Additional Information on the PACE Innovation Model RFI

State Comments

Medicaid Retroactive Eligibility

Agency: Iowa Medicaid Enterprise (IME)
Agency: Centers for Medicare & Medicaid Services (CMS)
Eliminate the provision of three months of retroactive benefits for all Iowa Medicaid eligibility groups.

Additional Information on Medicaid Retroactive Eligibility

Family Planning Program

Agency: Iowa Department of Human Services (DHS)
Change the definition of entities that can participate in the Family Planning Program (FPP) provider.

Additional Information on the Family Planning Program

Legislative Positions and Collaborative Sign-On Letters

Integrated Health Homes (IHH) – Iowa

Audience: Health Policy Oversight Committee of the Iowa Legislature

UnityPoint Health position letter dated December 2017 in opposition to program changes proposed by the Managed Care Organizations (MCO) related to patient eligibility and scope and intensity of care coordination services. UnityPoint Health is affiliated with five Community Mental Health Centers across Iowa that provide IHH services.

Creating High-Quality Results and Outcomes Necessary to Improve Chronic (CHRONIC) Care Act of 2017

Lead Agencies: Healthcare Leadership Council, National Coalition on Health Care
Audience: U.S. House Leadership

Sign-on letter dated October 2017 to support advancement of the CHRONIC Care Act, which included flexibilities for Medicare Advantage (MA) plans and Fee-For-Service (FFS) providers to deliver care.

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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