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.

The Medicare Rights Center (Medicare Rights) appreciates the opportunity to comment on the proposed rule Medicare and Medicaid Programs; Contract Year 2021 and 2022 Policy and Technical Changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, Medicaid Program, Medicare Cost Plan Program, and Programs of All-Inclusive Care for […]

The Medicare Rights Center (Medicare Rights) appreciates the opportunity to comment in response to the proposed Medicaid Fiscal Accountability Regulation. 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 […]

The Medicare Rights Center (Medicare Rights) appreciates the opportunity to comment on the proposed Rules Regarding the Frequency and Notice of Continuing Disability Reviews. 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 […]

The Medicare Rights Center (Medicare Rights) appreciates the opportunity to respond to the Agency Information Collection Activities: Proposed Collection; Comment Request, CMSR-131, OMB control number 0938-0566 (Advance Beneficiary Notice of Noncoverage (ABN)). Medicare Rights is a national, nonprofit organization that works to ensure access to affordable health care for older […]

The Medicare Rights Center (Medicare Rights) appreciates the opportunity to comment on the Office of the Inspector General’s (OIG’s) Medicare and State Healthcare Programs: Fraud and Abuse; Revisions To Safe Harbors Under the Anti-Kickback Statute, And Civil Monetary Penalty Rules Regarding Beneficiary Inducements. Medicare Rights is a national, nonprofit organization […]