RUPRI Health Panel Provided Comments to CMS-3442-P Proposed Rule: Medicare and Medicaid Programs; Minimum Staffing Standards for Long-Term Care Facilities and Medicaid Institutional Payment Transparency Reporting. November 6th, 2023. Read Comment Letter Here
The RUPRI Health Panel has offered comments and resources in response to the Physician-Focused Payment Model Request for Information (RFI) regarding rural participation in population-based total cost of care models. The Office of the Assistant Secretary for Planning and Evaluation in HHS convenes the PTAC. Find the Comments Here
The RUPRI Health Panel responded to a CMS proposed rule CY 2024 Payment Policies Under the PhysicianFee Schedule and Other Changes to Part B Payment and Coverage Policies; Medicare Shared Savings Program. READ COMMENTS HERE
RUPRI Health Panel Provided Comments to CMS-5540-NC Request for Information (RFI) seeking input regarding the design of a future episode-based payment model. August 15th, 2023. Read Comment Letter Here
The RUPRI Health Panel provided comments on the HHS 2023 Smoking Cessation Framework. Read the Comments Here. To be most impactful in rural communities, the Panel recommends a broader approach to tobacco cessation, not just smoking cessation. The prevalence of smokeless tobacco (e.g., snuff, dip, snus, and chewing tobacco) is higher in rural areas than …
Continue reading “RUPRI Health Panel Submits Comments on HHS Smoking Cessation Framework”
RUPRI Health Panel Provided Comments to CMS-2439-P Proposed Rule: Medicaid Program; Medicaid and Children’s Health Insurance Program (CHIP) Managed Care Access, Finance, and Quality. July 1st, 2023. Read Comment Letter Here
The RUPRI Health Panel submitted comments on CMS-1785-P: Medicare Program: Proposed Hospital PPS for Acute Care Hospitals and the Long-Term Care Hospital PPS and Policy Changes and Fiscal Year 2024 Rates Proposed Rule Read Comments HERE
RUPRI Health Panel provided comments to the U.S. Senate Committee on Health, Education, Labor, and Pensions to help identify bipartisan solutions to remedy the U.S. health care workforce shortages. March 20th, 2023. Read Comment Letter Here
RUPRI Health Panel Provided Comments to CMS-4201-P Proposed Rule: Contract Year 2024 Policy and Technical Changes to the Medicare Advantage Program; Medicare Prescription Drug Benefit Program; Medicare Cost Plan Program; Medicare Parts A, B, C, and D. February 13th, 2023. Read Comment Letter Here
The RUPRI Health Panel submitted a comment letter to CMS responding to Request For Information CMS-4203-NC: Medicare Program: Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems and Quality Reporting Programs… Rural Emergency Hospitals. READ THE COMMENT LETTER HERE
The RUPRI Health Panel has submitted a response to CMS -17700P Medicare and Medicaid Programs; CY 2023 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment Policies; Medicare Shared Savings Program Requirements. READ THE COMMENT LETTER HERE
The RUPRI Health Panel has responded to a CMS Request for Information on the Medicare Advantage program. READ COMMENT LETTER HERE Rural Perspective on Medicare AdvantageOur comments and feedback are offered from the rural perspective, where Medicare Advantage is an increasingly important source of health care coverage. As of March 2022, MA accounted for 45.7 …
Continue reading “Comment to CMS on Medicare Advantage Program. RUPRI Health Panel. August 2022.”
RUPRI Health Panel Provided Comments to HHS Request for Information (RFI): Initiative to Strengthen Primary Health Care. July 31st, 2022. Read Comment Letter Here
RUPRI Health Panel Provided Comments to CMS-1765-P Proposed Rule: Medicare Program; PPS and Consolidated Billing for Skilled Nursing Facilities; Request for Information on Revising Requirements for Long-Term Facilities to Establish Mandatory Minimum Staffing Levels. June 8th, 2022. Read Comment Letter Here
RUPRI Health Panel Provided Comments to CMS-1771-P Proposed Rule: Medicare Program; Hospital Inpatient PPS for Acute Care Hospitals and the Long-Term Care Hospital PPS and Proposed Policy Changes and Fiscal Yar 2023 rates; Quality Programs and Medicare Promoting Interoperability Program Requirements for Eligible Hospitals and Critical Access Hospitals. June 8th, 2022. Read Comment Letter Here
Click Here for Comment Letter The Panel underscores the importance of recognizing the variance in demand for Medicaid access and coverage across non-metro and metro areas. In 2019, the percent of Medicaid coverage in non-metro areas was 22.4 percent, whereas in metro areas the percent of Medicaid coverage was 19.1. The three percent difference signifies …
Click Here for Comment Letter on 47 CFR Part 54 The Panel is encouraged by the efforts of the FCC to increase broadband access for rural providers. We encourage FCC to lead an effort to quantify the actual costs of connecting and operating broadband capacity supporting access to healthcare services. With that information subsidies could …
RUPRI Health Panel Provided Comments to CMS-4192-P: Medicare Program; Contract Year 2023 Policy and Technical Changes to the Medicare Advantage and Medicare Prescription Drug Benefit Programs. February 2022. Read Comment Letter Here
The Panel is pleased to comment in response to the proposed rule for Medicare hospital outpatient prospective payment system (OPPS) program and the Request for Information (RFI) on Rural Emergency Hospitals (REH). Our comments will focus only on the latter, Section XVII of the proposed rule, Federal Register pages 42285 – 42289. We also limit …
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Read comment letter here.
The RUPRI Population and Place Analytics Panel and the RUPRI Health Panel jointly provided comments to the Census Bureau on the proposed definition of Urban Places. Read the Comment Letter Here
Read comment letter here.
RUPRI, led by the Rural Health Panel and the Population and Place Analytics Panel, has released comments on Recommendations from the Metropolitan and Micropolitan Statistical Area Standards Review Committee to Changes in Metropolitan and Micropolitan Area Standards. Read Comments Here In our comments, we recommend that OMB not implement a change in the metropolitan statistical …
Read comment letter here.
RUPRI Health Panel Provided Comments to 85 FR 59806 Request for Public Comments on Revised Geographic Eligibility for Federal Office of Rural Health Policy Grants. October 22nd, 2020. Read Comment Letter Here
RUPRI Health Panel Provided Comments to CMS-1734-F Proposed Rule: Medicare Program; CY 2021 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment Policies. September 23rd, 2020. Read Comment Letter Here
RUPRI Health Panel Provided Comments to CMS-1730-P Proposed Rule: Medicare and Medicaid Programs; CY 2021 Home Health Prospective Payment System Rate Update, Home Health Quality Reporting Program Requirements. July 19th, 2020. Read Comment Letter Here
In May 2020, the Health Panel offered comments in response to the CMS Maternal and Infant Health Care in Rural Communities Request for Information. View Comment Letter
The Health Panel is pleased to offer comments in response to the proposed rule CMS-4190-P related to Medicare Advantage (Part C), Medicare Prescription Drug Benefit (Part D), Medicaid, Medicare Cost Plan, among other policy areas. View Comment Letter
The Panel is pleased to offer comments in response to the proposed 2020-2025 Federal Health IT Strategic Plan. View Comment Letter
The Panel is pleased to provide comment on the proposed rule Revisions to Safe Harbors Under the Anti-Kickback Statute, and Civil Monetary Penalty Rules Regarding Beneficiary Inducements. The Panel is encouraged by OIG’s recognition that there are certain circumstances that warranttreating rural providers differently than those in urban geographies. The Panel offers comments ontwo specific …
Continue reading “Health Panel Comment Letter – Anti-Kickback Statute – December 2019”
The Panel is pleased to provide comments on the proposed rule Modernizing and Clarifying the Physician Self-Referral Regulations.The Panel is encouraged by CMS’s recognition throughout the proposed rule of the unique ruralhealth care environment. The Panel agrees that circumstances exist in which it is appropriate to treatrural providers differently than other kinds of providers. View …
Continue reading “Health Panel Comment Letter – Stark Law – December 2019”
RUPRI Health Panel Provided Comments to HRSA Request for Information (RFI) regarding health access and core health care services needed in rural communities. October 9th, 2019. Read Comment Letter Here
The Panel is pleased to offer comments in response to the proposed updates to the CY 2020 Revisions to Payment Policies Under the Physician Fee Schedule (PFS) The Panel applauds CMS’s attention to rural issues throughout the proposed rule. CMS hasdemonstrated its commitment to rural areas in considering innovative telehealth care delivery foropioid use disorder …
Continue reading “Health Panel Comment Letter – PFS Proposed Rule 2020 Revisions – September 2019”
The Panel welcomes the opportunity to submit comments on Addressing the Low Case-Volume Challenge in Healthcare Performance Measurement of Rural Providers: Recommendations from the MAP Rural Health Technical Expert Panel. The RUPRI Health Panel strongly supports the NQF Measure Applications Partnership Rural Health Workgroup. Valid and reliable quality performance measures are critically important to rural …
Continue reading “Health Panel Comment Letter – NQF Draft Report – February 2019”
RE: 42 CFR Parts 438 and 457 – Medicaid Program; Medicaid and Children’s Health Insurance Plan (CHIP)Managed Care The Panel welcomes the opportunity to submit comments on the Medicare Advantage, 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 proposed …
Continue reading “Health Panel Comment Letter – Medicare, Medicaid & CHIP – January 2019”
RE: 42 CFR Parts 422, 423, 438, and 498: Medicare and Medicaid Programs; Policy and Technical Changes tothe Medicare Advantage, 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 The Panel welcomes the opportunity to submit comments on the Medicare Advantage, …
Continue reading “Health Panel Comment Letter – Medicare, Part D & Medicaid – December 2018”
RE: 42 CFR Part 414 and 425: Medicare Program; Medicare Shared Savings Program; Accountable CareOrganizations – Pathways to Success The Panel is pleased to offer comments in response to this particular proposed rule. Our comments are limited to rural-specific issues and are structured to parallel questions posed, or issues stated, by CMS (not technical comments …
Continue reading “Health Panel Comment Letter – ACO Proposed Rule – October 2018”
RE: 42 CFR Part 416 and 419: Medicare Program; Proposed Changes to Hospital Outpatient ProspectivePayment and Ambulatory Surgical Center Payment Systems and Quality Reporting Programs; Requests forInformation on Promoting Interoperability and Electronic Health Care Information, Price Transparency, andLeveraging Authority for the Competitive Acquisition Program for Part B Drugs and Biologicals for a PotentialCMS Innovation Center …
RE: 42 CFR Part 405, 410, 411, 414, 415, and 495: Medicare Program; Revisions to Payment Policies Under thePhysician Fee Schedule and Other Revisions to Part B for CY 2019; Medicare Shared Savings ProgramRequirements; Quality Payment Program; and Medicaid Promoting Interoperability Program The Panel is pleased to offer comments in response to the proposed rules …
Continue reading “Health Panel Comment Letter – Revisions to Physician Payments – September 2018”
Promoting Telehealth in Rural America 47 CFR Part 54 The Panel is pleased to offer comments in response to the proposed rule for Promoting Telehealth in Rural America, specifically the Federal Communications Commission (FCC) Rural Healthcare (RHC) Program. View Comment Letter
RUPRI Health Panel Provided Comments to CMS-9930-P Proposed Rule: Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters for 2019. November 27th, 2017. Read Comment Letter Here
RUPRI Health Panel Provided Comments to CMS-5522-P Proposed Rule: Medicare Program; CY 2018 Updates to the Quality Payment Program. August 11th, 2017. Read Comment Letter Here
RUPRI Health Panel Provided Comments to CMS-1677-P Proposed Rule: Medicaid 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 2018 Rates. May 18th, 2017. Read Comment Letter Here
RUPRI Health Panel Provided Comments to CMS-2404-NC Request for Information (RFI): Federal Government Interventions to Ensure the Provision of Timely and Quality Home and Community Based Services. January 9th, 2017. Read Comment Letter Here
RUPRI Health Panel Provided Comments to CMS-5517-FC Finalized Rule with Comment Period: Medicare Program; Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive Under the Physician Fee Schedule, and Criteria for Physician-Focused Payment Models. December 14th, 2016. Read Comment Letter Here
RUPRI Health Panel Provided Comments to CMS-1631-P Proposed Rule: Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters for 2018. October 4th, 2016. Read Comment Letter Here
RUPRI Health Panel Provided Comments to CMS–3295–P Proposed Rule: Medicare and Medicaid Programs; Hospital and Critical Access Hospital (CAH) Changes to Promote Innovation, Flexibility, and Improvement in Patient Care. August 9th, 2016. Read Comment Letter Here
RUPRI Health Panel Provides Comments to CMS-1631-P Proposed Rule: Medicare Program; Revisions to Payment Policies Under the Physician Fee Schedule and Other Revisions to Part B for CY 2017 (Part II). July 22nd, 2016. Read Comment Letter Here
RUPRI Health Panel Provided Comments to CMS Request for Information on Concepts for Regional Multi-Payer Prospective Budgets. May 13th, 2016. Read Comment Letter Here
Rural Policy Research Institute
The University of Iowa
College of Public Health
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