Regulatory Comments

CMS Letter, September 17, 2021 – Read our letter to Centers for Medicare & Medicaid Services Administrator Chiquita Brooks-LaSure on the OPPS Proposed Rule.

CMS Letter, September 13, 2021 – Read our letter to Centers for Medicare & Medicaid Services Administrator Chiquita Brooks-LaSure on the 2022 PFS Proposed Rule.

CMS Letter, March 1, 2021 – Read our letter to Centers for Medicare & Medicaid Services Administrator-Designate Chiquita Brooks-LaSure to implement the e-PA Rule as expeditiously as possible and to expand the scope of the e-PA Rule to include Medicare Advantage (MA) plans.

CMS Letter, January 4, 2021 – Read our letter to Centers for Medicare & Medicaid Services Administrator Seema Verma on the prior authorization (PA) Proposed Rule.

CMS Letter, November 30, 2020 – Read our comments to Demetrios Kouzoukas on the Medicare Advantage (MA) advance notice of methodological changes for CY 2022.

Open Letter to All Heath Plans, May 2020 – Read the Regulatory Relief Coalition letter to all health plans requesting a suspension of prior authorization until normalcy is restored in the health care delivery system.

House Small Business Committee Letter, May 4, 2020 – Read the House Small Business Committee letter to CMS Administrator Seema Verma on prior authorization.

Letter to the Governor, April 16, 2020 – Read our letter to the Governor requesting that all health plans licensed in each state waive prior authorization requirements for all health services for the duration of the national emergency.

Letter to the Insurance Commissioner, April 16, 2020 – Read our letter to the Insurance Commissioner requesting that all health plans licensed in each state waive prior authorization requirements for all health services for the duration of the national emergency.

CMS Letter, March 27, 2020 – Read our letter to Centers for Medicare & Medicaid Services Administrator Seema Verma requesting wavier of Medicare Advantage prior authorization requirements during the COVID-19 national emergency.

CMS RFI Comments, August 12, 2019 – Read our comments on the Centers for Medicare & Medicaid Services’ Patients over Paperwork Request for Information.

CMS Advance Notice Comments, 2019 – Read our comments on the Centers for Medicare & Medicaid Services’ Advance Notice of Methodological Changes for Calendar Year (CY) 2019 for Medicare Advantage (MA) Capitation Rates, Part C and Part D Payment Policies and 2019 Call Letter (“Draft Call Letter”)

Reps. Roe Bera Sign-on Letter, October 10, 2018 – Read the Congressional letter led by Representatives David P. Roe (R-TN) and Ami Bera (D-CA) to the Centers for Medicare & Medicaid Services

CMS Comments, September 27, 2018 – Read our comments to Demetrios Kouzoukas re improving prior authorization.

CMS Comments, May 24, 2018 – Read our comments on the Centers for Medicare & Medicaid Services’ Medicare Part C Reporting Requirements.

CMS Comments, April 3, 2018 – Read our comments on the Centers for Medicare & Medicaid Services’ Prior Authorization under Medicare Advantage and the Patients over Paperwork initiative