2016 Sign On Letters

On December 1, 2016, CPR, the Habilitation Benefits (HAB) Coalition and the Independence Through Enhancement of Medicare and Medicaid (ITEM) Coalition submitted joint comments on the 2018 Draft Letter to Issuers to the Centers for Medicare & Medicaid Services at the Department of Health and Human Services (CMS).  The letter received forty-one (41) sign-ons, 28 of which were CPR members.

On November 7, the CPR Steering Committee, in conjunction with American Academy of Physical Medicine and Rehabilitation (AAMP&R), American Medical Rehabilitation Providers Association (AMRPA), and Brain Injury Association of America (BIAA), submitted a request for a meeting to Andy Slavitt, Acting Administrator of the Centers for Medicare and Medicaid Services, to discuss unintended consequences of ICD-10 Conversion on access to inpatient hospital rehabilitation for Medicare beneficiaries with brain injuries and select orthopedic conditions.

On October 6, 2016, CPR, the Habilitation Benefits (HAB) Coalition and the Independence Through Enhancement of Medicare and Medicaid (ITEM) Coalition submitted joint comments on the proposed rule HHS Notice of Benefit and Payment Parameters for 2018 to the Centers for Medicare & Medicaid Services at the Department of Health and Human Services (CMS).  The letter received forty-nine (49) sign-ons, 33 of which were CPR members.

On October 3, 2016, CPR submitted comments on the proposed rule Medicare Program; Advancing Care Coordination Through Episode Payment Models (EPMs); Cardiac Rehabilitation Incentive Payment Model; and Changes to the Comprehensive Care for Joint Replacement Model (CJR) to the Centers for Medicare & Medicaid Services at the Department of Health and Human Services (CMS).  The letter was signed by the members of CPR’s Steering Committee.

On September 21, 2016, CPR submitted comments on post-acute care value-based purchasing, in both a written statement on the Medicare Post-Acute Care Value-Based Purchasing Act of 2015 (H.R. 3298), in connection to the September 6 Ways and Means Health Subcommittee hearing entitled “Evolution of Quality in Medicare Part A,” and as comments to members of the House Ways and Means Committee.  The letter ultimately contained twenty-six (26) sign-ons.

On September 6, 2016, CPR submitted comments on the proposed rule Medicare Program; Revisions to Payment Policies Under the Physician Fee Schedule and Other Revisions to Part B for CY 2017; Medicare Advantage Pricing Data Release; Medicare Advantage and Part D Medical Low Ratio Data Release; Medicare Advantage Provider Network Requirements; Expansion of Medicare Diabetes Prevention Program Model to the Centers for Medicare & Medicaid Services at the Department of Health and Human Services (CMS).  Supporting non-CPR organizations signed the letter as well.  There were 26 sign-ons for the letter, including 24 CPR members.

On June 20, 2016, CPR submitted comments on the Inpatient Rehabilitation Facility [IRF] Prospective Payment System for Federal Fiscal Year 2017 and the Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities (SNFs) for FY 2017, SNF Value-Based Purchasing Program, SNF Quality Reporting Program, and SNF Payment Models Research to the Centers for Medicare & Medicaid Services at the Department of Health and Human Services (CMS).  In contrast to last year, supporting non-CPR organizations signed the letters as well.

There were 40 sign-ons for the IRF letter (including 30 CPR members), and 37 sign-ons for the SNF letter (including 29 CPR members).  In comparison, sign-ons for the IRF and SNF proposed rule letters last year numbered 18 and 17, respectively.
On May 25, 2016, one hundred and fourteen (114) members of the House signed onto a Dear Colleague Letter initiated by Congressmen Tom Price and James McGovern to Secretary of the Department of Health and Human Services (HHS) Sylvia Burwell and Acting Administrator of the Centers for Medicare & Medicaid Services (CMS) Andrew Slavitt.  This letter called for the repeal of a notice implementing prior authorization in home health.  On May 18, the CPR Steering Committee sent an advocacy letter to the House in support of the Dear Colleague letter.  CPR’s comment letter on the notice, submitted on April 5, received 33 sign-ons.
On April 5, 2016, CPR submitted comments on the notice entitled, Medicare Probable Fraud Measurement Pilot; CMS–10599 Medicare Prior Authorization of Home Health Services Demonstration to the Centers for Medicare & Medicaid Services at the Department of Health and Human Services (CMS).  In total, 33 members of CPR signed onto the letter.
On March 29, 2016, CPR submitted comments on the Summary of Benefits and Coverage and Uniform Glossary to the Internal Revenue Service at the Department of the Treasury (IRS), the Employee Benefits Security Administration at the Department of Labor (EBSA), and the Centers for Medicare & Medicaid Services at the Department of Health and Human Services (CMS).  The comment letter was co-signed with organizations from the Habilitative Benefits (HAB) Coalition, the Independence through Enhancement of Medicare & Medicaid (ITEM) Coalition, and the Consortium for Citizens with Disabilities (CCD) Health Task Force.  In total, 45 groups signed on, with 32 of those groups being members of CPR.
On March 29, 2016, CPR published its Medicare Advantage (MA) Statement of Principles.  This document will serve as CPR’s position paper on MA, as well as a foundation for future testimony and sign-on letters.    In total, 36 members of CPR signed onto the Statement.
On March 4, 2016, CPR submitted comments to CMS on proposed updates to the Medicare Advantage (MA) program through the 2017 Advance Notice and Draft Call Letter.  In total, 33 members of CPR signed onto the comments.  That same day, Representative Glenn (G.T.) Thompson (R-PA) submitted similar comments to CMS as well.
On February 19, 2016, CPR submitted comments on post-acute care site-neutral payments to the House Energy and Commerce Committee.  In total, 20 members of CPR signed onto the comments.
On January 17, 2016, CPR submitted comments to the Centers for Medicare and Medicaid Services (CMS) division of the U.S. Department of Health and Human Services (HHS) on the Draft 2017 Letter to Issuers in the Federally-facilitated Marketplaces.  In total, 24 members of CPR signed onto the comments.
On January 4, 2016, the CPR Steering Committee submitted comments to the Centers for Medicare and Medicaid Services (CMS) division of the U.S. Department of Health and Human Services (HHS) on the proposed rule Revisions to Requirements for Discharge Planning for Hospitals, Critical Access Hospitals, and Home Health Agencies.