Comments to federal officials regarding various health care reform issues

• March 15, 2012: MHA submits comments to the Minnesota Departments of Commerce, Health, and Human Services detailing its support of: 1) a Minnesota-based Exchange, 2) ensured affordability of health insurance by subsidizing consumers who require additional assistance to purchase coverage, and 3) a robust comprehensive, primary care-centered benefit set as proposed for the Essential Health Benefits: [PDF].
  
  
• Jan. 31, 2012: MHA submits comments to the CMS addressing mandatory benefit categories, the benchmark plan types, and a need to balance affordability with comprehensive coverage: [PDF]
  
  
• Oct. 31, 2011: MHA submits comments to the CMS regarding their proposed insurance mitigation rules setting forth standards related to reinsurance, risk corridors, and risk adjustment: [PDF].
  
  
• Oct. 28, 2011: MHA submits comments to the CMS regarding their proposed rule on state-level affordable health insurance exchanges, or HIXs, and qualified health plans. (MHA supports and has advocated for a viable, functioning and efficient exchange in Minnesota). [PDF]
  
  
• Sept. 23, 2011: MHA submits comments to the IRS regarding additional requirements for tax-exempt hospitals: [PDF].
  
  
• Aug. 30, 2011: MHA submits comments to the CMS regarding their proposed rule for the 2012 outpatient prospective payment system (OPPS): [PDF].
  
  
• Aug. 16, 2011: MHA submits comments to the CMS regarding their proposed Medicare Conditions of Participation (CoPs) for community mental health centers: [PDF].
  
  
• Aug. 16, 2011: MHA submits comments to the CMS regarding their proposal to add alcohol screening and behavioral counseling, as well as screening for depression to the package of prevention services offered to Medicare beneficiaries: [PDF ].
  
  
• Aug. 1, 2011: MHA submits comments to the U.S. Department of Health and Human Services regarding proposed changes to the HIPAA Privacy Rule for hospitals and other HIPAA-covered entities affecting the individual right to an accounting of disclosures: [PDF].
  

• July 5, 2011: MHA submits comments to the CMS regarding proposed influenza vaccination standards for certain participating providers and suppliers in Medicaid/Medicare programs. MHA does not support requiring all Medicaid and Medicare certified hospitals to offer all patients an annual flu vaccination as a condition of participation (CoP) in the federal programs: [PDF].

• July 1, 2011: MHA submits comments to the CMS regarding methods for assuring access to covered Medicaid services. [PDF].

• June 6, 2011: MHA submits specific comments to the CMS regarding individual provisions of the proposed rule for accountable care organizations that participate in the Medicare Shared Savings Program: [PDF].
  
  
• June 6, 2011: MHA submits comments to the CMS and Dept. of Health & Human Services regarding the need for waivers from certain fraud and abuse laws for accountable care organizations that participate in the Medicare Shared Savings Program: [PDF].
  
  
• May 31, 2011: MHA submits comments to the Federal Trade Commission in response to the proposed statement of antitrust enforcement policy regarding accountable care organizations participating in the Medicare Shared Savings Program: [PDF].
  
  
• May 31, 2011: MHA submits comments to the IRS regarding the implications of tax-exempt hospitals participating in accountable care organizations: [PDF].
  
  
• May 17, 2011: MHA submits comments to the National Association of Insurance Commissioners regarding issues and concerns that differ from or have additions to their draft white paper, "Health Insurance Exchanges under the Affordable Care Act: Governance Options and Issues": [PDF].
  
  
• March 8, 2011: MHA submits comments to CMS in response to a proposed rule on initial steps for a hospital inpatient value-based purchasing program: [PDF].
  
  
• March 4, 2011: MHA submits comments to the U.S. Dept. of Health and Human Services on the development and implementation of the Consumer Operated and Oriented Plan (CO-OP) program, as called for in the Patient Protection and Affordable Care Act. MHA supports development of CO-OPs, in conjunction with other insurance market reforms, as a potential avenue to provide affordable, consumer-focused health insurance for Minnesota residents: [PDF].
  
  
• Feb. 22, 2011: MHA submits comments to CMS on the need to revisit the agency's current policy concerning the applicability of the Emergency Medical Treatment and Labor Act (EMTALA) to hospital inpatients and the responsibilities of hospitals with specialized capabilities: [PDF].
  
  
• Jan. 31, 2011: MHA submits comments to the U.S. Dept. of Health and Human Services in response to interim final rule implementing the medical loss ratio provision of Section 2718 of the Public Health Service Act, as established by the Patient Protection and Affordable Care Act (ACA): [PDF].
  
  
• Jan. 7, 2011: In a letter to Minnesota's entire congressional delegation, MHA expresses its opposition to legislation that would repeal the Patient Protection and Affordable Care Act (ACA): [PDF]
  
  
• Jan. 7, 2011: MHA submits comments to CMS on the proposed rules regarding provisions in the Patient Protection and Affordable Care Act (ACA) related to the Medicaid Recovery Audit Contractor (RAC) program: [PDF].
  
  
• Dec. 3, 2010: MHA submits comments to CMS in response to a request for information from CMS which posed questions regarding the implementation of a new Medicare Shared Savings Program and regarding accountable care organizations. [PDF].
  
  
• Dec. 3, 2010: MHA, a member of The Healthcare Quality Coalition, submits comments to CMS on the need for the SSP, ACOs and other payment methodologies to take into account that some providers have already made significant quality and cost improvements and may not be motivated by the same incentives as providers who have not yet achieved substantial performance improvements: [PDF].
  
  
• Nov. 19, 2010: MHA comments to the National Committee for Quality Assurance (NCQA) regarding accountable care organizations (ACOs) and the need for ACO standards to remain as consistent as possible to avoid confusion and unnecessary duplication. In its comments, MHA urges HCQA to delay finalizing its criteria until CMS releases its regulations governing ACOs and NCQA has an opportunity to thoroughly examine how to best align its criteria with those regulations. [PDF].
  
  
• Nov. 16, 2010: MHA comments to CMS regarding the implementation of program integrity provisions in the Patient Protection and Affordable Care Act: [PDF].
  
  
• Oct. 7, 2010: MHA president Lorry Massa, along with Minnesota Council of Health Plans and Minnesota Medical Association leaders urge U.S. HHS Secretary Kathleen Sebelius to review and consider comments jointly prepared by Minnesota state agencies (departments of Human Services, Health and Commerce) regarding exchange-related provisions. See letter: [PDF] and comments: [PDF].
  
  
• Oct. 6, 2010: MHA comments to the National Association of Insurance Commissioners on its proposed language for a draft model act (the American Health Benefit Exchange Model Act) in regard to implementation of health benefit exchanges: [PDF].
  
  
• Oct. 4, 2010: MHA comments to the U.S. Dept. of Health & Human Services on the health insurance exchange-related provisions in the Patient Protection & Affordable Care Act: [PDF].
  
  
• Sept. 2, 2010: MHA comments to the Minnesota Department of Health regarding creation and implementation of a health benefit exchange: [PDF].
  
  
• July 26, 2010: MHA comments to CMS regarding proposed changes affecting hospitals' conditions of participation around credentialing and privileging of telemedicine physicians and practitioners: [PDF]
  
  
• July 21, 2010: MHA comments to the IRS regarding their proposal of new reporting and operations requirements for tax-exempt hospitals: [PDF]
  
  
• May 14, 2010: MHA comments to the U.S. Dept. of Health & Human Services on medical loss ratios and the need for a transparent process to develop standard definitions and methodology that health plans will use to report their expenditures and calculate their medical loss ratios: [PDF]
  
  
  
  back to health care reform page. Also, see MHA comments regarding state reform issues.