The Medicare Rights Center (Medicare Rights) appreciates this opportunity to comment on the Medicare Program; Medicare Coverage of Innovative Technology (MCIT) and Definition of “Reasonable and Necessary” (CMS–3372–P) proposed 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.

Comments in opposition to approving Georgia’s proposal to eliminate HealthCare.gov access for Georgians.

Comments in opposition to reclassifying payments for health care sharing ministries as payments for medical insurance for tax purposes.

The Medicare Rights Center (Medicare Rights) appreciates this opportunity to comment on Oklahoma’s Sooner Care 2.0 Medicaid Section 1115 Demonstration Waiver application. While we support state Medicaid expansions, we believe that the U.S. Department of Health and Human Services (HHS) should reject the Sooner Care 2.0 Demonstration application as being inaccurate, incomplete, outside of the scope of the Secretary’s authority, not in keeping with the purpose of Medicaid, and against the interests of the Medicaid population and program— as well as health systems and public health generally—in Oklahoma and nationally.

Medicare Rights generally supports the transition of many of the provisions in this proposed rule from subregulatory guidance to notice-and-comment rulemaking. While we recognize that formal rulemaking can lack the flexibility and nimbleness of guidance, we believe that the standardization, transparency, and predictability of formal rulemaking makes it a more appropriate vehicle for most provisions that make significant changes to the Medicare program.