Center for Medicare Advocacy Submits Comments on CMS COVID-19 Rule

On June 1, 2020, the Center for Medicare Advocacy submitted comments to the Centers for Medicare & Medicaid Services’ (CMS) Interim Final Rule with Comment: Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency (CMS-1744-IFC). The rule, at 85 Federal Register 19230 (April 6, 2020), is available here. While the Interim Final Rule contains only some of the waivers and other flexibilities CMS has issued in response to the COVID-19 pandemic, the Center included comments on CMS’s waivers more generally.

As noted in the Center’s comments, “From a beneficiary standpoint, some of these rule changes and waivers have improved eligibility for and access to services (such as waiver of the 3-day inpatient stay and extended coverage allowance re: skilled nursing facilities). We urge CMS to expand such changes after the end of the Public Health Emergency (PHE).
Some changes can improve access to care for beneficiaries, such as broadened telehealth coverage, but should not be used as a substitute for necessary in-person visits, nor should they be used to further weaken Medicare Advantage network adequacy standards […]. 
Other changes give us great pause, such as those aimed at easing so-called “burdens” on providers – like suspending certain reporting requirements – and CMS’s suspension of many oversight activities. We urge CMS to reinstate these provisions as soon as possible.”

The Center’s full comments are available at: https://medicareadvocacy.org/center-comments-on-policy-and-regulatory-revisions-in-response-to-covid-19/