The RUPRI Health Panel has provided comments to CMS on the Medicare and Medicaid Programs Contract Year 2026 policy and technical changes to the Medicare Advantage program, Prescription Drug Benefit Program, PACE and the Medicare Cost Plan Program. Find the Comments Here
Category Archives: Comment Letter
Comments to CMS on Minimum Staffing Standards for Long-Term Care Facilities and Medicaid Institutional Payment Transparency Reporting. RUPRI Health Panel. November 2023.
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
RUPRI Health Panel Submits Comments to Physician-Focused Payment Model TA Committee. October 2023
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
CMS Proposed Rule on 2024 Physician Fee Schedule and Medicare Part B. RUPRI Health Panel. September 2023.
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
Comments to CMS on a Future Episode-Based Payment Model. RUPRI Health Panel. August 2023.
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
RUPRI Health Panel Submits Comments on HHS Smoking Cessation Framework
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 …
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Comments to CMS on Medicaid and CHIP Access, Finance, and Quality. RUPRI Health Panel. July 2023.
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
Comments on Medicare PPS Proposed Rule. RUPRI Health Panel. June 2023.
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 Provides Comments to the U.S. Senate HELP Commitee to Identify Bipartisan Solutions to Remedy Our Nation’s Health Care Workforce Shortages. March 2023.
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
Comments to CMS on Policy and Technical Changes to the Medicare Advantage Program for Contract Year 2024. RUPRI Health Panel. February 2023.
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
Comments to CMS on Hospital PPS. RUPRI Health Panel. September 2022
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
Comments to CMS RFI 1770-P Medicare and Medicaid Programs; CY 2023 Payment Policies Under the Physician Fee Schedule; Medicare Shared Savings Program Requirements. RUPRI Health Panel. September 2022.
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
Comment to CMS on Medicare Advantage Program. RUPRI Health Panel. August 2022.
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 …
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RUPRI Health Panel Provides Comments to HHS on Delivering Primary Care in Rural Communities. July 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
Comments to CMS on Revising the Requirements for Long-Term Care Facilities to Establish Mandatory Minimum Staffing Levels. RUPRI Health Panel. June 2022.
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
Comments to CMS on the Changes to Hospital and Critical Access Hospital Conditions of Participation. June 2022.
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
Comment to CMS on Access to Coverage and Care in Medicaid & CHIP. RUPRI Health Panel. April 2022
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 …
RUPRI Health Panel Releases Comment Letter to Federal Communications Commission RFI on Promoting Telehealth in Rural America. April 2022
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 Provides Comments to CMS on Policy and Technical Changes to Medicare Advantage and Medicare Prescription Drug Benefit Programs for Contract Year 2023. February 2022.
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
RUPRI Health Panel Releases Comments on Rural Emergency Hospital RFI
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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RUPRI Health Panel Comment Letter on proposed changes in the CY 2021 Payment Policies Under the Physician Fee Schedule Rule. September 2021
Read comment letter here.
RUPRI Panels Provide Comments on Census Bureau Proposed Urban Definition
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
RUPRI Health Panel Comment Letter on Census Bureau Urban Definition. May 2021
Read comment letter here.
RUPRI Releases Comments on Office Of Management & Budget Proposal to Revise Metropolitan and Micropolitan Area Standards. March 2021
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 …
RUPRI Health Panel Comment Letter Responding to HHS RFI to Assess Temporary Deregulatory Actions in Response to COVID-19. December 2020.
Read comment letter here.
RUPRI Health Panel Provides Comments to FORHP on the Definition of Rural Areas Used to Determine Eligibility for Grant Programs. October 2020.
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 Provides Comments to CMS on the Payment Policies Under the Physician Fee Schedule for Calendar Year 2021. September 2020.
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 Provides Comments to CMS on the Home Health Prospective Payment System Rate for Calendar Year 2021. July 2020.
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
Health Panel Comment Letter – Maternal and Infant Health Care in Rural Communities
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
Health Panel Comment Letter – Medicare Advantage & Part D – April 2020
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
Health Panel Comment Letter – ONCHIT Strategic Plan – March 2020
The Panel is pleased to offer comments in response to the proposed 2020-2025 Federal Health IT Strategic Plan. View Comment Letter
Health Panel Comment Letter – Anti-Kickback Statute – December 2019
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 …
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Health Panel Comment Letter – Stark Law – 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 …
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RUPRI Health Panel Provides Comments to HRSA on Rural Health Access RFI. October 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
Health Panel Comment Letter – PFS Proposed Rule 2020 Revisions – September 2019
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 …
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Health Panel Comment Letter – NQF Draft Report – February 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 …
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Health Panel Comment Letter – Medicare, Medicaid & CHIP – January 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 …
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Health Panel Comment Letter – Medicare, Part D & Medicaid – December 2018
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, …
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Health Panel Comment Letter – ACO Proposed Rule – October 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 …
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Health Panel Comment Letter – Outpatient Payment & Interoperability – Septembe 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 …
Health Panel Comment Letter – Revisions to Physician Payments – September 2018
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 …
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Health Panel Comment Letter – FCC Promoting Telehealth in Rural America – January 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 Provides Comments to CMS on HHS Notice of Benefit and Payment Parameters for 2019. November 2017.
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 Provides Comments to CMS on Updates to the Quality Payment Program for Calendar Year 2018. August 2017.
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 Provides Comments to CMS on the Revision to the Medicare Hospital Inpatient Prospective Payment Systems (IPPS). May 2017.
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 Provides Comments to CMS on Additional Reforms and Policy Options to Help Accelerate the Provision of Home and Community Based Services (HCBS) to Medicaid Beneficiaries. January 2017.
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 Provides Comments to CMS on MACRA and the Quality Payment Program. December 2016.
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 Provides Comments to CMS on Benefit and Payment Parameters for 2018. October 2016.
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 Provides Comments to CMS on Hospital and Critical Access Hospital Changes to Promote Innovation, Flexibility, and Improvement in Patient Care. August 2016.
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 on the Revisions to Payment Policies Under the Physician Fee Schedule for Calendar Year 2017. July 2016.
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
