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
Category Archives: Comment Letter
RUPRI Health Panel Responds to CMS Proposed Rule on 2024 Physician Fee Schedule and Medicare Part B
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 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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RUPRI Health Panel Submits Comments on Medicare PPS Proposed Rule
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 Submits Comment Letter on Hospital PPS. 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
RUPRI Health Panel Submits Comments to CMS RFI 1770-P Medicare and Medicaid Programs; CY 2023 Payment Policies Under the Physician Fee Schedule; Medicare Shared Savings Program Requirements. 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
RUPRI Health Panel Comment Letter on Medicare Advantage Program
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 Comment Letter on Access to Coverage and Care in Medicaid & CHIP. 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 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.
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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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 Rural Health Panel: Comments responding to Request for Information Regarding Accountable Care Organizations and the Medicare Shared Saving Program: CMS‐1345‐NC. December 2010
Click Here for Comment Letter
RUPRI Rural Health Panel Comment Letter: Reply to request for comments regarding Exchange‐related provisions of the ACA. October 2010
Click Here for Comment Letter
American Recovery and Reinvestment Act of 2009 Broadband Initiatives: Comments by RUPRI to NTIA and Rural Utilities Services. April 2009.
This comment letter was authored by Brian Dabson. Click Here for Comment Letter.
RUPRI Rural Health Panel Response to CMS Report to Congress: Plans to Implement Medicare Hospital Value-Based Purchasing Program. October 2008.
Click Here for Comments
