2015 Advocacy Efforts

On December 21, 2015, CPR submitted comments to CMS on the proposed rule Notice of Benefit and Payment Parameters for 2017.  In total, 22 members of CPR signed onto the comments.

On November 9, 2015, CPR submitted comments to the Office for Civil Rights (OCR) division of the U.S. Department of Health and Human Services (HHS) on the proposed rule Nondiscrimination in Health Programs and Activities.  In total, 31 members of CPR signed onto the comments.

On October 14, 2015, CPR submitted comments to CMS on the proposed rule Medicare and Medicaid Programs; Reform of Requirements for Long-Term Care Facilities.  In total, 16 members of CPR signed onto the comments.

On September 30, 2015, CPR submitted comments to the Center for Consumer Information & Insurance Oversight (CCIO) on the proposed 2017 Essential Health Benefits (EHB) benchmark plans for all 50 states and Washington, DC.  In total, 29 members of CPR signed onto the comments.

On September 8, 2015, CPR submitted comments to CMS on the proposed rule Medicare Program; Comprehensive Care for Joint Replacement Payment Model for Acute Care Hospitals Furnishing Lower Extremity Joint Replacement Services.  In total, 23 members of CPR signed onto the comments.

On July 27, 2015, CPR submitted comments to CMS on the proposed rule Medicaid Managed Care, CHIP Delivered in Managed Care, Medicaid and CHIP Comprehensive Quality Strategies, and Revisions Related to Third Party Liability.  CPR’s comments were limited to definitions of habilitative and rehabilitative services and devices, network adequacy, and prohibition of discrimination.  The comments were submitted as a steering committee letter.

On June 23, 2015, CPR submitted comments to CMS on the proposed rule Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long Term Care Hospital Prospective Payment System Policy Changes and Fiscal Year 2016 Rates.  CPR’s comments were limited to the Solicitation of Public Comments on Expanding the Bundled Payment for Care Improvement (BPCI) Initiative section of the proposed rule.  The comments were submitted as a steering committee letter.

On June 22, 2015, CPR submitted comments to CMS on the proposed rule Inpatient Rehabilitation Facility Prospective Payment System for Federal Fiscal Year 2016.  In total, 18 members of CPR signed onto the comments.

On June 19, 2015, CPR submitted comments to CMS on the proposed rule Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities (SNFs) for FY 2016.  In total, 17 members of CPR signed onto the comments.

On June 11, 2015, Rep. Martha Roby (R-AL) and Rep. Bill Pascrell (D-NJ) sent a Dear Colleague letter to House Speaker John Boehner (R-OH) and Minority Leader Nancy Pelosi (D-CA) expressing support for the Improving Medicare Post-Acute Care Transformation (IMPACT) Act of 2014, as well as their concern with Congress establishing “site neutral” payments for select conditions treated in inpatient rehabilitation hospitals and units (IRFs) and skilled nursing facilities (SNFs) before the implementation of the IMPACT Act.  The Dear Colleague Letter was supported by CPR advocacy efforts, and garnered 58 sign-ons.

On March 16, 2015, CPR submitted comments to House leadership on CPR’s support for a sustainable growth rate (SGR) fix with reasonable reforms to post-acute care.  In total, 17 members of CPR signed onto the comments.

On March 2, 2015, CPR submitted comments on the proposed rule, Summary of Benefits and Coverage and Uniform Glossary. In total, 25 members of CPR signed onto the comments.