UnityPoint Health has submitted comments letters in response to multiple state and federal agency proposals listed below. Click the links to learn more about our comment letters as well as agency proposed rules.
STATE OF IOWA
DHS: Community Mental Health Centers & Integrated Chronic Health Homes Amendments
Agency: Iowa Department of Human Services
Published: February 23, 2022
Submitted: March 15, 2022
Iowa DHS is requesting comments on proposed rule making related to Community Mental Health Centers (ARC 6211C) & Integrated and Chronic Health Homes (ARC 6206C).
- UnityPoint Health Comment Letter on IDHS ARC 6211C & ARC 6206C
- Notice of Intended Action on ARC 6211C
- Notice of Intended Action on ARC 6206C
STATE OF WISCONSIN
WI GOV: Enactment of SB 259 Genetic Counseling Licensure
Agency: Wisconsin Governor Tony Evers
Letter Sent: March 10, 2022
UnityPoint Health Meriter, in partnership with UW Health, encourages Governor Tony Evers to sign SB 259 (licensure of genetic counselors) into law.
OSHA: Occupational Exposure to COVID-19; ETS – Additional Comments
Agency: Occupational Safety and Health Administration (OSHA)
Published: March 23, 2022
Submitted: April 22, 2022
OSHA is requesting additional information regarding the need for, and impact of the potential provisions and approaches specified in the ETS as well as additional studies, information and data related to the delta and omicron variants since the close of OSHA’s initial comment period in August 2021.
CDC: Clinical Practice Guideline for Prescribing Opioids
Agency: Centers for Disease Control and Prevention (CDC)
Published: February 10, 2022
Submitted: April 11, 2022
The CDC is requesting information on the 2022 Clinical Practice Guidelines for Prescribing Opioids.
- UnityPoint Health Comment Letter
- CDC Clinical Practice Guideline for Prescribing Opioids – Draft
- CDC Overview of Community Engagement and Public Comments
ONC: Electronic Prior Authorization
Agency: Office of the National Coordinator for Health Information Technology (ONC)
Published: January 24, 2022
Submitted: March 25, 2022
ONC is requesting information on electronic prior authorization standards, implementation specifications, and certification criteria.
CMS: CY 2023 MA and Part D Benefit Programs
Agency: Centers for Medicare & Medicaid Services (CMS)
Published: January 12, 2022
Submitted: March 7, 2022
CMS is requesting comments on contract year 2023 proposed changes for MA and Part D.
DOJ & FTC’s Request for Information on Merger Enforcement
Lead Organization: The Academy Advisors (TAA)
Audience: Department of Justice and Federal Trade Commission
A sign-on letter dated April 19, 2022 was submitted by TAA on behalf of members in response to the DOJ and FTC’s request of information on merger enforcement.
The UnityPoint Health Government and External Affairs team is actively partnering with operational leaders on the following annual proposals currently open for comment:
- FY 2023 Hospice Payment Rate Update Proposed Rule
- FY 2023 Inpatient Psychiatric Facility Prospective Payment System Proposed Rule
- FY 2023 Inpatient Rehabilitation Facility Prospective Payment System Proposed Rule
- FY 2023 Skilled Nursing Facilities Prospective Payment System Proposed Rule
- FY 2023 Hospital Inpatient Prospective Payment Systems Proposed Rule
The Government & External Affairs team works with subject matter experts from across UnityPoint Health to review these proposed regulations and provide formal input on behalf of the system. For transparency and awareness, past UnityPoint Health comment letters are accessible on the Government & External Affairs webpage.
For more information on the CMS rule making process or if you would like to participate as a UnityPoint Health content expert, please contact Cathy Simmons, executive director of government & external affairs for UnityPoint Health or Stephanie Collingwood, government relations specialist for UnityPoint Health