RUPRI Health Panel Provides Comments to CMS on Minimum Staffing Standards for Long-Term Care Facilities and Medicaid Institutional Payment Transparency Reporting. 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 House Ways & Means Committee on Improving Access to Health Care in Rural and Underserved Areas. October 2023.

The RUPRI Health Panel offers comments in response to the Committee on Ways and Means Request for Information regarding Improving Access to Health Care in Rural and Underserved Areas. The comments focus on all five topics included in the RFI. The five topics include comments on: Geographic Payment Difference: The Panel recommends that changes to …

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

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 …

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

RUPRI Health Panel Provides Comments to CMS on Policy and Technical Changes to the Medicare Advantage Program for Contract Year 2024. 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

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 …

RUPRI Health Panel Provides Comments to CMS on Revising the Requirements for Long-Term Care Facilities to Establish Mandatory Minimum Staffing Levels. 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

RUPRI Health Panel Provides 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

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 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 …

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 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 – 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 – 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

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 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