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Comments on the Proposed Medicare Changes (HHS-2015-49)

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The Medicare Rights Center (Medicare Rights) is pleased to submit comments in response to the proposed rule “Medicare Program: Changes to the Medicare Claims and Entitlement, Medicare Advantage Organization Determination and Medicare Prescription Drug Coverage Determination Appeals Procedures.” Medicare Rights is a national, nonprofit organization that works to ensure access to affordable health care for older adults and people with disabilities through counseling and advocacy, educational programs, and public policy initiatives. Medicare Rights provides services and resources to over two million Medicare beneficiaries, family caregivers, and professionals annually.

The following comments are informed by our experience working with beneficiaries and their families, particularly those pursuing appeals after denials of coverage…

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