2020 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
Economic Mobility
Agency: US Department of Health and Human Services (HHS)
Request for Information on Federal Coordination to Promote Economic Mobility for All Americans (85 FR 43242)
Additional Information on the Economic Mobility Request for Information
CY 2021 Payment Policies Under the Physician Fee Schedule
Agency: Centers for Medicare & Medicaid Services
Proposed Medicare CY 2021 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment Policies
CY 2021 Payment Policies Under the Physician Fee Schedule
Agency: Centers for Medicare & Medicaid Services
Proposed Medicare CY 2021 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment Policies
Hospital Outpatient Prospective Payment
Agency: Centers for Medicare & Medicaid Services
Proposed Medicare Hospital Outpatient Prospective Payment Program
CY 2021 Home Health
Agency: Centers for Medicare & Medicaid Services
Proposed Home Health Rules for Calendar Year 2021
Direct Primary Care Arrangements
Agency: Internal Revenue Service
Proposed Regulations Relating to Section 213 to the Internal Revenue Code
COVID-19 CDC Laboratory Reporting
Agency: Centers for Disease Control and Prevention
COVID-19 Pandemic Response, Laboratory Data Reporting: CARES Act Section 18115 (CDC-2020-0062)
Hospital Inpatient Rates
Agency: Centers for Medicare and Medicaid Services
Medicare Program; Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Proposed Policy Changes and Fiscal Year 2021 Rates; Quality Reporting and Medicare and Medicaid Promoting Interoperability Programs Requirements for Eligible Hospitals and Critical Access Hospitals
COVID-19 Pandemic Response
Agency: Department of Health and Human Services
COVID-19 Pandemic Response, Laboratory Data Reporting: CARES Act Section 18115
Additional Information on COVID-19 Patient Utilization Reporting
- COVID-19 Pandemic Response, Laboratory Data Reporting: CARES Act Section 18115
- Frequently Asked Questions: Laboratory Data Reporting for COVID-19 Testing
COVID-19 Utilization Reporting
Agency: Centers for Disease Control and Prevention
CDC Reporting of Patient Impact Module for COVID-19 Surveillance in Healthcare Facilities (CDC-2020-0039-0001))
Additional Information on COVID-19 Patient Utilization Reporting
Hospice Medicare Rates FY2021
Agency: Centers for Medicare & Medicaid Services
FY2021 Hospice Wage Index and Payment Rate Update (CMS-1733-P)
Additional Information on the FY2021 Hospice Wage Index and Payment Rate Update
Medicaid Medically Complex Children
Agency: Centers for Medicare & Medicaid Services
Coordinating Care from Out-of-State Providers for Medicaid-Eligible Children with Medically Complex Conditions (CMS-2324-NC)
Additional Information on the Medicaid Medically Complex Children Request for Information
340B Hospital Survey
Agency: Centers for Medicare & Medicaid Services
340B Hospital Survey for Specified Covered Outpatient Drugs (CMS-10709)
Additional Information on the 340B Hospital Survey
- See “340B Drug Program Reporting”
340B Drug Program Reporting
Agency: Centers for Medicare & Medicaid Services (CMS)
Proposed Information Collection on Hospital Survey for Specified Covered Outpatient Drugs (SCODs)
Additional Information
Transparency in Coverage
Agency: Department of Health & Human Services; Department of the Treasury; Department of Labor
Proposed Rule on Transparency in Coverage for Health Plans
Additional Information
Scope of Practice
Agency: Centers for Medicare & Medicaid Services (CMS)
Request for Feedback on Elimination of Supervision and Licensure Requirements that Limit Top of Licensure Practice
Additional Information
State Comments
Recommendations for Proposed COVID-19 Pandemic Strategies
Agency: Public Health and Healthcare Workgroup
Request for Written Feedback from Hospitals and Health Systems Regarding
Recommendations for Proposed COVID-19 Pandemic Strategies
Additional Information on Request for Recommendations Regarding Proposed COVID-19 Pandemic Strategies
Medicaid State Plan Amendment
Agency: Iowa Department of Human Services
Medicaid State Plan Amendment, Integrated Health Homes
Additional Information on Medicaid State Plan Amendment, Integrated Health Homes
Legislative Positions and Collaborative Sign-On Letters
Physician Self-Referral Law and Anti-Kickback Statute Final Regulations
Lead Organization: Academy Advisors
Audience: Secretary Azar and Ranking Members Meadows and Vought
Sign-on letter dated September 3, 2020 to expedite the issue of final rules to modernize changes to the Physician Self-Referral Law (Stark Law) and the Anti-Kickback Statute (AKS).
Proposed Provisions to Keeping Medicare Patients’ Improved Access to Care through Telehealth
Lead Organization: Academy Advisors
Audience: Ranking Member, House Committee on Ways and Means
Sign-on letter dated July 28, 2020 to provide recommendations to the legislative draft “Keeping Medicare Patients’ Improved Access to Care through Telehealth”
Proposed Reforms to the Stark Law and Anti-Kickback Statute Regulations
Lead Organization: Various Health Systems Across Wisconsin
Audience: Secretary Azar and Acting Director Vought
Sign-on letter dated July 19, 2020 to encourage finalization of the Centers for Medicare & Medicaid Services (CMS) and Office of Inspector General (OIG) proposed reforms to the Stark Law and Anti-Kickback Statute (AKS) regulations.
COVID-19: Lessons Learned to Prepare for the Next Pandemic
Lead Organization: The Academy Advisors
Audience: United States Senate HELP Committee
Sign-on letter dated June 26, 2020 to commend the committee for publishing the white paper, Preparing for the Next Pandemic, and making recommendations
Federal COVID Telehealth Continuation
Lead Organization: Interstate Healthcare Collaborative
Audience: Health & Human Services; Centers for Medicare & Medicaid Services
Sign-on letter dated June 15, 2020 to formally request the continuation of the flexibilities regarding telehealth services that have been afforded to providers during the COVID-19 pandemic response.
Crisis Care Improvement and Suicide Prevention Act of 2020 Endorsement
Lead Organization: Congresswoman Cheri Bustos (IL-17) and Susan Wild (PA-07)
Audience: Congress
Press Release dated June 10, 2020 to support the introduction of the Crisis Care Improvement and Suicide Prevention Act of 2020. Specifically, the legislation directs states to utilize five percent of their Mental Health Block Grant for crisis care services to allow states to upgrade crisis care programs and strategies. Both UnityPoint Place and the Robert Young Center are quoted in this press release.
Rural Community Hospital Demonstration Extension Act of 2020
Lead Organization: Congresswoman Abby Finkenauer (IA-1)
Audience: Congress
Press Release dated May 7, 2020 to support the introduction of the Rural Community Hospital Demonstration Extension Act of 2020. Specifically, the legislation extends the original RCH Demonstration Program for an additional five years. Both Grinnell Regional Medical Center and UnityPoint Health are quoted in this press release.
Prompt Pay Discount
Lead Organization: Wisconsin Hospital Association
Audience: Wisconsin Legislature
Sign-on memo dated February 2020 to urge the Assembly to include AB 841 to the Assembly floor calendar. This legislation clarifies a health care provider’s ability to offer prompt-pay discounts to patients for out-of-pocket costs owed to a provider. This issue is included the UnityPoint Health 2020 State Legislative Agenda.
Drug Efficacy Study Implementation (DESI) drugs
Lead Organization: Civica Rx
Audience: Key Congressional Leaders, including Senator Chuck Grassley
Sign-on letter dated February 2020 to urge Congress to close loopholes that lead to unreasonable price increases for decades-old drugs as a result of periods of exclusivity grants by the Federal Drug Administration for former Drug Efficacy Study Implementation (DESI) drugs.
Iowa Immunizes
Lead Organization: Iowa Public Health Association
Audience: Iowa Legislature
Sign-on letter dated January 2020 to urge the Iowa Legislature to base their vaccine-related policy decisions on criteria that will:
- Reduce barriers to giving safe and effective vaccines.
- Encourage adherence to evidence-based vaccine recommendations.
- Support providing accurate, science-based immunization information.
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.
There are currently no summaries of EOs available for 2020.
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UnityPoint Health
Government & External Affairs
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