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.

The Medicare Rights Center (Medicare Rights) appreciates this additional opportunity to comment on the Medicare Program; Medicare Coverage of Innovative Technology (MCIT) and Definition of “Reasonable and Necessary”; Delay of Effective Date; Public Comment Period (CMS-3372-IFC) interim final rule. Medicare Rights is a national, nonprofit organization that works to ensure access to affordable health care for older adults and people with disabilities through counseling and advocacy, educational programs, and public policy initiatives. Each year, Medicare Rights provides services and resources to nearly three million people with Medicare, family caregivers, and professionals.
We reaffirm our support for ensuring greater access to appropriate innovative technologies and necessary care for people with Medicare.

The COVID-19 public health emergency continues to demonstrate the need for reliable access to health care, especially for older adults and people with disabilities. The pandemic makes it crucial to protect Medicare’s ability to provide guaranteed coverage and meet the changing and urgent needs of the populations it serves. The Department of Health and Human Services (HHS) also must have the bandwidth to shift focus and respond quickly to immediate and emergent issues. Thousands of lives are at stake.

As the current COVID-19 public health emergency continues to reveal, the need for health care can arise at any moment and may be the difference between life and death. People without comprehensive health coverage may delay or forgo care, worsening their own and public health outcomes. Those who do seek treatment may face extreme financial hardships, impacting patient, program, and taxpayer costs.