UnityPoint Health | 2018 Public Comments

2018 Public Comments

When relevant legislation, regulations, guidance, and other opportunities to shape policy related to health services research arise, UnityPoint Health may decide it is appropriate to develop an official position. The UnityPoint Health Government & External Affairs department serves as the primary liaison for regulatory submissions in response to state and federal rule-making and public requests for information, as well as communications advocating changes in state and federal policy direction or strategic initiatives.

Federal Comments

340B Drug Pricing Program

Agency:  Health Resources and Services Administration (HRSA)
Proposed Changes to 340B Drug Pricing Program Ceiling Price and Manufacturer Civil Monetary Penalties

Additional Information on the Proposed Rule for the 340B Drug Pricing Program

CMS Red Tape

Agency: Centers for Medicare & Medicaid Services (CMS)
Proposed Changes to Eliminate Regulatory Barriers

Additional Information on the Proposed Rule to Eliminate Regulatory Barriers

IMPACT Act and Social Risk Factors

Agency: Health & Human Services (HHS)
Request for Information (RFI) on Approaches to Beneficiaries with Social Risk Factors

Additional Information on the RFI on Approaches to Beneficiaries with Social Risk Factors

Medicare Shared Savings Program

Agency: Centers for Medicare & Medicaid Services (CMS)
Proposed Changes to Medicare Shared Savings Program; Accountable Care Organizations Pathways to Success

Additional Information on the Proposed Rule for the Medicare Shared Savings Program

Medicare Outpatient Prospective Payment System

Agency: Centers for Medicare & Medicaid Services (CMS)
Proposed Changes to Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems and Quality Reporting Programs

Additional Information on the Proposed Rule for the Medicare Outpatient Prospective Payment System

Medicare Physician Fee Schedule

Agency: Centers for Medicare & Medicaid Services (CMS)
Proposed Rule for the Physician Fee Schedule and Other Revisions to Part B for Calendar Year 2019, Medicare Shared Savings Program Requirements, and the Quality Payment Program

Additional Information on the Proposed Rule for the Medicare Physician Fee Schedule

Medicare Advantage Quality Payment Arrangement Incentive (MAQI) Demonstration Information Collection

Agency: Centers for Medicare & Medicaid Services (CMS)
Proposed Information Collection for MAQI Demonstration

Additional Information on the Proposed Information Collection for MAQI Demonstration

Medicare Home Health Prospective Payment System (HH PPS)

Agency: Centers for Medicare & Medicaid Services (CMS)
Proposed Rule for the 2019 Home Health Payment and Case-Mix Adjustments Update and Other Home Health Regulations on Value-Based Purchasing, Home Infusion Therapy, and National Accrediting Organizations

Additional Information on the HH PPS Proposed Rule

Physician Self-Referral Law Request for Information

Agency: Centers for Medicare & Medicaid Services (CMS)
Request for public input on current regulatory barriers for coordinated care under the Physician Self-Referral Law, also known as the Stark Law.

Additional Information on the Physician Self-Referral Law Request for Information

Home Health Pre-Claim Review Demonstration

Agency: Centers for Medicare & Medicaid Services (CMS)
Reinstatement of a proposed Demonstration to institute a voluntary pre-claim or post-payment review process for Home Health Agencies in five states, including Illinois.

Additional Information on the Home Health Pre-Claim Review Demonstration

Drug Pricing Blueprint Request for Information (RFI)

Agency: Health & Human Services (HHS)
Request for Information for HHS Drug Pricing Blueprint to increase competition, better negotiations, create incentives to lower list prices, and reduce patient out-of-pocket spending.

Additional Information on the HHS Drug Pricing Blueprint

Medicare Hospice Payment Update

Agency: Centers for Medicare & Medicaid Services (CMS)
Proposed Rule for FY 2019 Hospice Wage Index and Payment Rate Update and Hospice Quality Reporting Requirements.

Additional Information on the Hospice Proposed Rule

Medicare Inpatient Prospective Payment System (IPPS)

Agency: Centers for Medicare & Medicaid Services (CMS)
Proposed Rule for Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and Proposed Policy Changes and Fiscal Year 2019 Rates

Additional Information on the IPPS Proposed Rule

Direct Provider Contracting (DPC)

Agency: Centers for Medicare & Medicaid Services (CMS)
Request for input on DPC between payers and primary care or multi-specialty groups to inform potential testing of a DPC model within the Medicare fee-for-service (FFS) program (Medicare Parts A and B), Medicare Advantage program (Medicare Part C), and Medicaid.

Additional Information on Potential Models for DPC

Price and Information Transparency

Agency: U.S. Senate
Request for Stakeholder Input on Health Care Pricing and Information Transparency from a Bipartisan Group of Senators.

Additional Information on Price and Information Transparency

Clinical Laboratory Improvement Amendments (CLIA) Modernization

Agency: Centers for Medicare and Medicaid Services
Request for Information on Revisions to Personnel Regulations, Proficiency Testing Referral, Histocompatibility Regulations and Fee Regulations Under CLIA.

Additional Information on CLIA

Association Health Plans

Agency: Department of Labor
Definition of ''Employer'' Under Section 3(5) of the Employee Retirement Income Security Act of 1974 (ERISA)—Association Health Plans.

Additional Information on Association Health Plans

Anti-Kickback Statute (AKS)

Agency: Office of the Inspector General (OIG), Health and Human Services (HHS)
Solicitation of New Safe Harbors and Special Fraud Alerts.

Additional Information on the AKS

Hospital-Wide Mortality Measurement

Agency: Center for Medicare & Medicaid Innovation (CMS Innovation Center)
Two measures of hospital-wide mortality (patient deaths) were developed.

Additional Information on Hospital-Wide Mortality Measurement

State Comments

3-Month Retroactive Coverage for Skilled Nursing Facility Residents

Agency: Iowa Department of Human Services
Reinstate a 3-month retroactive Medicaid coverage benefit for applicants who are residents of a nursing facility at the time of application and are otherwise Medicaid-eligible.

Additional Information on the 3-Month Retroactive Coverage Amendment

Program of All-Inclusive Care for The Elderly (PACE) State Plan Amendment

Agency: Iowa Medicaid Enterprise, Iowa Department of Human Services
Request for input on the PACE State Plan Amendment related to development of PACE capitation rates, counties served by the PACE program, and alignment of approved methodologies and processes.

Additional Information on PACE State Plan Amendment

Legislative Position and Collaborative Sign-On Letters

Emergent Diagnosis Codes

Lead Organizations: UnityPoint Health, Genesis Health System, Mercy Health Network and the Iowa Chapter of the American College of Emergency Physicians
Audience: Iowa Medicaid Enterprise
Sign on letter and list of requested codes for reinstatement from August 2018 requesting to reinstate specific codes as emergent.

Rural Health Care in America: Challenges and Opportunities

Lead Agency: United States Senate Committee on Finance
Audience: Congressional Leadership
Submitted testimony and opening statement to the United States Senate Committee on Finance by Ms. Susan Thompson, Senior Vice President of Integration and Optimization, UnityPoint Health, and Chief Executive Officer, UnityPoint Accountable Care. Ms. Thompson provided testimony as part of the Committee hearing, "Rural Health Care in America: Challenges and Opportunities" on May 24, 2018. Video of the entire hearing can be found here.

Reinsurance

Lead Agency: National Coalition on Health Care
Audience: Congressional Leadership
Sign-on letter dated March 2018 to urge Congressional action to stabilize the Health Insurance Marketplace.

Cigarette Tax – Iowa

Lead Agencies: American Cancer Society Cancer Action Network, Iowa Cigarette Tax Coalition
Audience: Iowa Legislators
Sign-on letter from January 2018 to encourage increase in cigarette tax and to invest in tobacco use prevention and cessation program.

Extenders Package

Lead Agency: American Academy of Family Physicians
Audience: Congressional Leadership
Sign-on letter dated January 2018 to support retroactive and future funding for federal health care programs and services, including the Community Health Center Fund, Medicaid Disproportionate Share Hospital (DSH) payment funding, Medicare Therapy Cap Extension, Teaching Health Center Graduate Medical Education Program, Maternal Infant and Early Childhood Home Visiting Program, National Health Service Corps, and Physician Fee Schedule (PFS) GPCI Parity Policy.


For Further Information:

Please email Cathy Simmons, Executive Director of Regulatory Affairs.