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 […]

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 […]

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 […]

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 […]

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 […]

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 […]

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 […]

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, […]

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 […]

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 […]

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