Comments on the Advance Notice of Methodological Changes for
Calendar Year (CY) 2023 for Medicare Advantage (MA) Capitation Rates and Part C and Part D Payment Policies

Comments on the 2023 C&D rule: Medicare Program; Contract Year 2023 Policy and Technical Changes to the Medicare Advantage and Medicare Prescription Drug Benefit Programs.

We provided comments on the 2023 Notice of Benefit and Payment Parameters for Affordable Care Act Marketplace plans.

We provided comments supporting CMS revoking the Georgia 1332 Medicaid waiver which would eliminate access to HealthCare.gov for Georgia residents.

Home health is a valuable and necessary benefit that can help people with Medicare live safely in their homes and communities. But far too many beneficiaries lack meaningful access to needed services. Often, this is due to due to misaligned financial incentives that make serving people with chronic conditions who are not expected to improve less profitable than delivering short-term care to people who are recovering from illness or injury. We are concerned the proposed rule could exacerbate this dynamic.

Comments on the Updating Payment Parameters proposed rule that would make changes to ACA marketplace enrollment, assistance, and standards.

The need to address equity has never been clearer. The COVID-19 pandemic, entrenched economic exploitation, rising income inequality, and violent and systemic racism must be a call to action to build new pathways to equity and justice. We are glad to see this RFI’s focus on ways to see, assess, and redress inequities throughout our governmental systems.

Medicare has aided the country before as we attempted to move past the horrors of Jim Crow and other segregation and racial and ethnic barriers. But disparities persist, and more must be done to improve access to health care and coverage, build well-being, support dignity, and enhance economic stability for all.

Comments on the proposed use of an indirect estimation algorithm for racial and ethnic demographics as well as a clarification of the requirement for states to enroll all Medicare-eligible providers for purposes of determining reimbursement.

Comments on changes to the HIPAA proposed rule that would speed up individual access to records but create inappropriate laxity in some aspects of the rule.