UnityPoint Health | Public Comments
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2020 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

Medicare Program Proposed Rule Related to Hospital Inpatient Rates

Agency: Centers for Medicare and Medicaid Services

Medicare Program; Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Proposed Policy Changes and Fiscal Year 2021 Rates; Quality Reporting and Medicare and Medicaid Promoting Interoperability Programs Requirements for Eligible Hospitals and Critical Access Hospitals

COVID-19 Pandemic Response

Agency: Department of Health and Human Services

COVID-19 Pandemic Response, Laboratory Data Reporting: CARES Act Section 18115

Additional Information on COVID-19 Patient Utilization Reporting

COVID-19 Utilization Reporting

Agency: Centers for Disease Control and Prevention

CDC Reporting of Patient Impact Module for COVID-19 Surveillance in Healthcare Facilities (CDC-2020-0039-0001))

Additional Information on COVID-19 Patient Utilization Reporting

Hospice Medicare Rates FY2021 

Agency: Centers for Medicare & Medicaid Services

FY2021 Hospice Wage Index and Payment Rate Update (CMS-1733-P)

Additional Information on the FY2021 Hospice Wage Index and Payment Rate Update

Medicaid Medically Complex Children

Agency: Centers for Medicare & Medicaid Services

Coordinating Care from Out-of-State Providers for Medicaid-Eligible Children with Medically Complex Conditions (CMS-2324-NC)

Additional Information on the Medicaid Medically Complex Children Request for Information

340B Hospital Survey

Agency: Centers for Medicare & Medicaid Services

340B Hospital Survey for Specified Covered Outpatient Drugs (CMS-10709)

Additional Information on the 340B Hospital Survey

  • See "340B Drug Program Reporting"

340B Drug Program Reporting

Agency: Centers for Medicare & Medicaid Services (CMS)

Proposed Information Collection on Hospital Survey for Specified Covered Outpatient Drugs (SCODs)

Additional Information

Transparency in Coverage

Agency: Department of Health & Human Services; Department of the Treasury; Department of Labor

Proposed Rule on Transparency in Coverage for Health Plans

Additional Information

Scope of Practice

Agency: Centers for Medicare & Medicaid Services (CMS)

Request for Feedback on Elimination of Supervision and Licensure Requirements that Limit Top of Licensure Practice

Additional Information

State Comments

Medicaid State Plan Amendment

Agency: Iowa Department of Human Services

Medicaid State Plan Amendment, Integrated Health Homes

Additional Information on Medicaid State Plan Amendment, Integrated Health Homes

Legislative Positions and Collaborative Sign-On Letters

COVID-19: Lessons Learned to Prepare for the Next Pandemic

Lead Organization: The Academy Advisors

Audience:  United States Senate HELP Committee

Sign-on letter dated June 26, 2020 to express sincere appreciation for your leadership and Congress' response to the novel 2019 coronavirus (COVID-19) pandemic. The purpose of this letter is to commend the committee for publishing the white paper, Preparing for the Next Pandemic, and for hosting the June 23 hearing, COVID-19: Lessons Learned to Prepare for the Next Pandemic.

Federal COVID Telehealth Continuation

Lead Organization: Interstate Healthcare Collaborative

Audience: Health & Human Services; Centers for Medicare & Medicaid Services

Sign-on letter dated June 15, 2020 to expand telehealth services through the Medicare program. Specifically, the purpose of this letter is to formally request the continuation of the flexibilities regarding telehealth services that have been afforded to providers during the COVID-19 pandemic response.

Crisis Care Improvement and Suicide Prevention Act of 2020 Endorsement

Lead Organization: Congresswoman Cheri Bustos (IL-17) and Susan Wild (PA-07)

Audience: Congress

Press Release dated June 10, 2020 to support the introduction of the Crisis Care Improvement and Suicide Prevention Act of 2020. Specifically, the legislation directs states to utilize five percent of their Mental Health Block Grant for crisis care services to allow states to upgrade crisis care programs and strategies. Both UnityPoint Place and the Robert Young Center are quoted in this press release.

Rural Community Hospital Demonstration Extension Act of 2020

Lead Organization: Congresswoman Abby Finkenauer (IA-1)

Audience: Congress

Press Release dated May 7, 2020 to support the introduction of the Rural Community Hospital Demonstration Extension Act of 2020. Specifically, the legislation extends the original RCH Demonstration Program for an additional five years. Both Grinnell Regional Medical Center and UnityPoint Health are quoted in this press release. 

Prompt Pay Discount

Lead Organization: Wisconsin Hospital Association

Audience: Wisconsin Legislature

Sign-on memo dated February 2020 to urge the Assembly to include AB 841 to the Assembly floor calendar. This legislation clarifies a health care provider's ability to offer prompt-pay discounts to patients for out-of-pocket costs owed to a provider. This issue is included the UnityPoint Health 2020 State Legislative Agenda.

Drug Efficacy Study Implementation (DESI) drugs

Lead Organization: Civica Rx

Audience: Key Congressional Leaders, including Senator Chuck Grassley

Sign-on letter dated February 2020 to urge Congress to close loopholes that lead to unreasonable price increases for decades-old drugs as a result of periods of exclusivity grants by the Federal Drug Administration for former Drug Efficacy Study Implementation (DESI) drugs.

Iowa Immunizes

Lead Organization: Iowa Public Health Association

Audience: Iowa Legislature

Sign-on letter dated January 2020 to urge the Iowa Legislature to base their vaccine-related policy decisions on criteria that will:

  • Reduce barriers to giving safe and effective vaccines.
  • Encourage adherence to evidence-based vaccine recommendations.
  • Support providing accurate, science-based immunization information.

Executive Order Summaries

At the Federal level, Executive Orders (EOs) are issued by the President. The EOs listed below announce regulatory and administrative priorities and often foreshadow future administrative rule-making efforts. UnityPoint Health often summarizes EOs impacting healthcare to inform advocacy efforts.

There are currently no summaries of EOs available for 2020.

For Further Information:

Please email Cathy Simmons, Executive Director of Regulatory Affairs.