2025 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 2026 Policy and Technical Changes to the Medicare Advantage Program

Agency: Centers for Medicare & Medicaid Services (CMS)
Date Submitted: January 27, 2025

This proposed rule offers Contract Year 2026 Policy and Technical Changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, Medicare Cost Plan Program, and Programs of All-Inclusive Care for the Elderly.

State Comments
Legislative Positions and Collaborative Sign-On Letters

Wisconsin 12-Month Postpartum Extension

Leading Organization: 12-Month Postpartum Extension coalition

Audience: Wisconsin Assembly

UnityPoint Health-Meriter 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.

Rural Hospital Support Act

Leading Organization: Senator Chuck Grassley

Audience: Public

Senator Chuck Grassley (IA) re-introduced the bipartisan Rural Hospital Support Act (S. 335) with Senator. Peter Welch (VT). This legislation would permanently extend the Medicare-dependent Hospital (MDH) and Low-Volume Hospital (LVH) designations and establish a new rebasing year for Sole Community Hospitals (SCH) and MDHs. This specifically impacts UnityPoint Health hospitals in Fort Dodge, Marshalltown and Muscatine. UnityPoint Health supports this legislation and are impacted hospitals are quoted in the Senator Grassley’s press release.

Medicare Telehealth Services

Leading Organization: Alliance for Connected Care

Audience: Congressional Leadership

UnityPoint Health signed on to a Stakeholder Letter, along with nearly 350 other organizations, urging Congressional leadership to take action in March to establish permanent or long-term access to telehealth. Many Medicare telehealth services are set to expire without Congressional action. Continuing telehealth services provide certainty for Medicare beneficiaries, bolster the healthcare workforce, encourage ongoing investment in technology tools and infrastructure, and allow health plans and employers to leverage telehealth in their benefit offerings.

Audio-Only Telehealth Access Act

Leading Organization: Congressman Randy Feenstra

Audience: Public

Congressman Randy Feenstra (IA-4) introduced the bipartisan Audio-Only Telehealth Access Act with Congressman Chris Pappas (D-NH). This legislation makes Medicare’s coverage of audio-only telehealth services permanent. The current waiver – which is set to expire on March 31, 2025 – allows the Centers for Medicare & Medicaid Services (CMS) to reimburse healthcare providers for patient evaluation, patient management, and behavioral health services over the phone. UnityPoint Clinic supports the continuance of this important service mode for our patients and is included in Congressman Feenstra’s press release.

Medicare Advantage Payment Denials And Delays

Leading Organization: Premier, Inc.

Audience: Center for Medicare and Medicaid Services (CMS)

UnityPoint Health signed on to a Stakeholder Letter, dated April 4, 2025, along with 80 other organizations, describing the findings of the national survey on providers’ experiences with reimbursement delays and denials that Premier conducted in partnership with our member hospitals and health systems. The letter also includes recommendations for policy changes in the Medicare Advantage program, supported by analysis of the survey data.

Medical Supply Chains and Nearshoring

Leading Organization: Premier, Inc.

Audience: Congress

The Medical Supply Chain Resiliency Act (S. 998/H.R. 2213) would enable the President to enter into trade agreements with trusted trade partner countries to diversify sourcing for critical medical devices and pharmaceuticals, protect public health and bolster national security. UnityPoint Health signed on to a Stakeholder Letter, dated April 7, 2025, indicating our support for this legislation along with our appreciation to the legislative co-sponsors.

Compact Licensure Flexibilities

Leading Organization: Interstate Healthcare Collaborative

Audience: Congress

UnityPoint Health participated in a Sign-On Letter urging congressional leaders to support the States Handling Access to Reciprocity for Employment (SHARE) Act (S. 1101/H.R. 2332). 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.

ACO Accurate Benchmarks

Leading Organization: National Association of ACOS (NAACOS)

Audience: CMS Administrator Oz

UnityPoint Accountable Care participated in a Sign-On Letter dated May 12, 2025, asking that the Accountable Care Prospective Trend (ACPT) be reweighted to 0%. The ACPT significantly underestimated Medicare cost growth. While the 2024 ACPT estimated Medicare cost growth to be 4.9%, actual growth was nearly double (8%). This means that the ACPT will artificially and unfairly reduce ACO benchmarks by 1.03%, which, for the average ACO, could reduce revenue earned by 25%.

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For Further Information:

Please email Cathy Simmons, Executive Director, Government & External Affairs.

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UnityPoint Health
Government & External Affairs
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