Policy & Research
We fight for policies that protect and strengthen Medicare for everyone — informed by the real experiences of people we serve every day.
What we're fighting for
Our policy team monitors and responds to developments across all areas of Medicare, with special attention to these critical issues.
Denials and Appeals
Largely driven by prior authorization, MA and Part D coverage denials leave beneficiaries with only bad options: paying out-of-pocket, going without, or getting embroiled in a daunting and…
Medicare Advantage
People who choose Medicare Advantage (MA) face additional hurdles during the initial enrollment and annual plan selection processes. The MA plan choice landscape is cluttered, complicated, and confusing.…
Coverage and Benefits
Medicare provides health coverage to over 67 million older adults and people with disabilities, paying for important medical care in hospital and outpatient settings. Nearly 12.5 million beneficiaries…
Prescription Drug Coverage
The Inflation Reduction Act (IRA) takes important steps to reduce drug prices and lower costs for people with Medicare and the program, such as capping beneficiary out-of-pocket spending;…
What the policy team is watching
Reports, press statements, and Medicare Watch posts — the policy team’s latest work, in date order.
Policy Series
In-depth research collections exploring critical Medicare policy issues through reports, data analysis, and multimedia resources.
Reports, Testimony & Analysis
Search by title and filter by topic and document type.
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Positions and Publications
What the Affordable Care Act Means for Older Adults
The Affordable Care Act (ACA) strengthened Medicare and Medicaid and created important coverage avenues and consumer protections for people of all ages. Despite these successes, the health law continues to face opposition from some policy corners in Congress, the states, some presidential administrations, and the courts.
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Positions and Publications
What Medicare Premium Support Means for Older Adults and People With Disabilities
Some policymakers support turning Medicare into a premium support system, also called a defined contribution system or a voucher program. These programs would give people with Medicare a voucher or coupon to purchase health coverage. If the voucher did not cover the full cost—a certainty, given the aim of such programs is to save Medicare dollars—the person would presumably have to pay the rest or go without coverage. Though touted as a cost saver, a hallmark of these policies is to instead shift significant expenses onto consumers.
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Positions and Publications
What Administrative Barriers Mean for Older Adults and People With Disabilities
Policymakers often overlook or disregard the problems people may face when they try to enroll or stay enrolled in public programs or to get the care they need. Issues around Medicare and Medicaid enrollments and appeals are legion and can run the gamut from minor one-time annoyances to recurrent bureaucratic nightmares.
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Positions and Publications
What Medicaid Financing Means for Older Adults and People With Disabilities
Medicaid is financed and administered through a federal-state partnership. Under current law, the federal government matches state Medicaid spending based on a statutory formula, without a pre-set limit. If state spending increases, for example due to increased enrollment or unexpectedly high program costs, then federal spending increases as well.
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Positions and Publications
What Raising the Medicare Eligibility Age Means for Older Adults and People With Disabilities
Medicare is a nearly universal program for people 65 and over, guaranteeing health care for older adults who have paid into the system during their working lives. This ensures that older adults do not have to continue to rely on employer health insurance and can retire at 65 without risking coverage loss. Some policymakers want to delay access to Medicare by raising the eligibility age from 65 to 67 or even 70. This would disproportionately harm people who can least afford it, including people who work in physically demanding jobs and older adults of color.
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Positions and Publications
What the Inflation Reduction Act Means for Older Adults and People With Disabilities
The Inflation Reduction Act (IRA) of 2022 made key changes in Medicare law and coverage to improve prescription drug affordability for older adults and people with disabilities. Since its passage, however, some stakeholders and lawmakers have targeted IRA policies for revision or repeal, especially the law’s Medicare Drug Price Negotiation Program.
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Positions and Publications
What Medicaid Cuts Mean for Older Adults and People With Disabilities
With the passage of HR 1, Congress is cutting around $1 trillion from Medicaid over the course of the next 10 years. The cuts will affect Medicaid at every level, restricting eligibility and enrollment, driving up the cost of covered services for beneficiaries and states, and damaging the health care system nationwide. These cuts harm the people who rely on the program, including millions of older adults and people with disabilities who are dually eligible for Medicare and Medicaid, as well as people nearing Medicare eligibility who have coverage through expansion Medicaid.
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Positions and Publications
What Medicaid Waivers Mean for Older Adults and People With Disabilities
Many states have expanded Medicaid coverage and care through Medicaid “Section 1115” waivers, but some states are inclined to move in the opposite direction, to limit eligibility or restrict coverage.
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Positions and Publications
What Medicare Private Contracting Means for Older Adults and People With Disabilities
Some policymakers endorse proposals to give Medicare providers the right to charge beneficiaries more for care than is currently allowed, either through balance billing or private contracting. Under these reforms, providers could require their Medicare patients to negotiate a contract for the cost of their care, or simply charge more for Medicare-covered services, leaving those beneficiaries with additional costs on top of their premiums, copayments, and coinsurance.
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Positions and Publications
What Medicare Means Testing Means for Older Adults and People With Disabilities
A core component of Medicare is its universality. Some policy ideas would undermine that promise by limiting benefits to people with lower incomes or requiring higher income enrollees to pay more for their care or coverage.
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Comments
Comments on HHS Notice of Benefit and Payment Parameters for 2027
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Comments
Comments on the 2027 Advance Notice
Medicare Rights strongly supports proposed actions to limit some gaming in Medicare Advantage payment.
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Comments
Comments on Guarding U.S. Medicare Against Rising Drug Costs (GUARD) Model
The Medicare Rights Center submitted these comments in opposition to the GUARD model for raising beneficiary drug costs.
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Positions and Publications
Improving Care Coordination
In <em>Improving Care Coordination</em>, the case study contrasts the consequences of weak versus effective care coordination across Medicare and Medicaid. Ms. T’s experience shows how limited integration and inadequate plan support can lead to improper billing, unresolved provider issues, and ultimately a disruption in care when her therapist drops her. In contrast, Mr. Y’s story demonstrates how strong care coordination within a fully integrated plan can proactively protect access to critical services, including uninterrupted 24-hour home care. Together, these examples highlight the essential role of care coordination in reducing administrative burden, preventing care disruptions, and improving outcomes for dually eligible individuals.
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Positions and Publications
Stopping Coverage Loss and Disruption
In <em>Stopping Coverage Loss and Disruption</em>, the case study focuses on “churn,” or the loss and regaining of coverage, and how it can interrupt care and destabilize integrated plans. Mrs. E’s experience shows how administrative errors in Medicaid recertification can lead to the loss of both Medicaid and integrated D-SNP coverage, resulting in higher costs, missed care, and fragmented services. Mr. V’s story highlights how misleading marketing and confusion about plan options can push beneficiaries out of highly integrated coverage into less coordinated plans, putting critical services like home care at risk. Together, these cases underscore the need for stronger safeguards, clearer communication, and streamlined processes to prevent unnecessary coverage disruptions and protect access to care.
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Positions and Publications
Closing Gaps in Benefits and Services
In <em>Closing Gaps in Benefits and Services</em>, the case study examines how differences in Medicare and Medicaid coverage rules, vendors, and plan structures can create barriers to essential services like transportation. Mrs. W’s experience shows how limited integration and misleading expectations around supplemental benefits can leave beneficiaries with less access to care than before, while Mr. L’s story demonstrates how more aligned or integrated plans can simplify access and reduce administrative burdens. Together, these examples highlight the need for clearer plan information, stronger oversight of supplemental benefits, and greater alignment between Medicare and Medicaid to ensure beneficiaries receive the services they need.
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Positions and Publications
Fixing the Appeals Process
In <em>Fixing the Appeals Process</em>, the case study contrasts two beneficiary experiences to show how fragmented versus integrated systems impact access to care. Mr. H’s story illustrates the confusion and delays that arise when Medicare and Medicaid appeals operate separately, leaving him caught between two plans and unsure how to secure coverage for a medically necessary wheelchair feature. In contrast, Mrs. Z benefits from an integrated appeals system that streamlines decision-making and reduces administrative burden, ultimately improving her access to needed services. Together, these examples underscore the importance of aligning Medicare and Medicaid processes and inform policy recommendations aimed at simplifying appeals and strengthening care coordination.
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Comments
Comments on Proposed 2027 Medicare Advantage and Part D Policy Changes
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Comments
Comments on the Nondiscrimination on the Basis of Disability in Programs or Activities Receiving Federal Financial Assistance Notice of Proposed Rulemaking
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Positions and Publications
Medicare Advantage Marketing, Brokers, and Agents
Agents and brokers for MA plans receive commissions per enrollment and often receive additional “administrative” bonuses that balloon MA spending. These financial incentives drive aggressive and misleading marketing aimed at people looking for coverage. As a result, beneficiaries fall into the “MA Trap,” finding themselves enrolled in an MA plan that doesn’t meet their needs and without an efficient way to switch back to Original Medicare.
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Positions and Publications
Beneficiary Experiences With Medicare Advantage Marketing
As the cost of care rises, beneficiaries increasingly look for plans that promise discounts or additional benefits. MA plans take advantage of this and flood potential beneficiaries with marketing calls, mailers, ads, and even in-person solicitation that can be deceptive and easily misunderstood.
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Positions and Publications
Beneficiary Experiences with Medicare Advantage Supplemental Benefits
Original Medicare has significant gaps in coverage, including very limited coverage of dental, vision, and hearing care. By advertising supplemental benefits that seem to fill these gaps and help tackle the cost of care and living, MA plans captivate the attention of beneficiaries struggling to afford care. But these benefits are not standardized or clearly communicated, falling short of their original promises.
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Comments
Comments on 2026 Outpatient Prospective Payment System (OPPS)
Our comments are informed by our work helping callers to our National Helpline navigate and afford their care. These experiences drive us to support efforts within this rule to bring more sustainability and rationality to Medicare payment, including by establishing greater site neutrality.
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Comments
Comments on the Proposed 2026 Physician Fee Schedule
Our comments are informed by our work helping beneficiaries, including callers to our National Helpline, navigate, understand, access, and afford their care. Based on this experience, we know many people with Medicare want and need to maintain deep and trusting relationships with their providers. Finding the right provider fit, spending time with that provider, and staying with that provider over the years is a priority for many people across Original Medicare and Medicare Advantage.
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Positions and Publications
Medicare Savings Programs: A Lifeline for Millions
To make it clear what a difference MSP enrollment can have in the lives of older adults and people with disabilities, and to support advocacy efforts to expand MSP eligibility and enrollment, Medicare Rights has compiled a set of case studies from its national helpline. These cases show what obstacles beneficiaries commonly face when trying to enroll and stay enrolled in MSPs and reinforce the role the benefit plays in real people’s lives.
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Positions and Publications
Medicare Advantage Proliferation: Too Much of a Complicated Thing
In recent years, insurance companies have flooded the MA market with plans that are difficult to tell apart, creating overwhelm and confusion that costs both beneficiaries and the Medicare program more than Original Medicare. This part addresses the causes and consequences of the rapid proliferation of Medicare Advantage (MA) plans in the absence of adequate consumer guidance and federal regulation.
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Positions and Publications
Medicare Financing: Shifting the Focus to Sustainability in Addition to Solvency
This part of the series explores the origins and structure of Medicare financing. Through an issue brief, infographic, and video, it outlines the various sources of funding for the three major parts of Medicare and lays out how projections and costs have fluctuated over the program’s history.
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Positions and Publications
Medicare Site Neutrality: Pursuing a More Rational Payment System
Under current site-specific payment rates, the same service can cost patients and Medicare vastly different amounts based on the location and hospital affiliation of the provider. This part of the series explains how these payment rules incentivize hospitals to vertically integrate routine care in order to drive up profits. Site-neutral payments offer a more rational alternative that would minimize arbitrary differences in cost and protect Medicare sustainability.
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Positions and Publications
A Cut to Medicaid is a Cut to Medicare
Without Medicaid, many Medicare enrollees—especially those with limited income—would struggle to afford care, risking their health or having to choose between medical care and housing, food and other essentials. Cutting Medicaid would directly harm millions of Medicare enrollees and increase costs for the Medicare program and state budgets.
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Positions and Publications
Medicare & Medicaid in New York
Medicare guarantees access to health care for older adults and people with disabilities. Together with the Affordable Care Act (ACA) and Medicaid, Medicare builds health security and well-being for New Yorkers of all ages. Any changes to these programs, whether at the state or federal level, must aim for healthier people, better care, and smarter spending—not paying more for less.
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Comments
Comments on the 2026 Advance Notice
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Comments
Comments on Proposed 2026 Medicare Advantage Part D Policy Changes
A comprehensive commentary by the Medicare Rights Center on the Centers for Medicare & Medicaid Services (CMS) proposed rule for Contract Year 2026 (CMS–4208–P). The document outlines feedback and recommendations on changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, and related policies. Topics include consumer protections, health equity, benefit transparency, drug affordability, and the integration of AI in healthcare services. This submission emphasizes safeguarding beneficiary access to affordable, equitable, and transparent healthcare.
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Positions and Publications
Medicare Trends and Recommendations
This report features the top helpline trends and highlights the most commonly sought helpline and Medicare Interactive answers, providing a glimpse into the various questions and needs of Medicare beneficiaries, caregivers, and the professionals assisting them in the community in 2023.
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Positions and Publications
Medicare Savings Program Enrollment
This case study focuses on how automatic enrollment in Medicare Savings Programs can remove many individuals' barriers when enrolling. Simplifying the enrollment process is essential to increasing participation and ensuring that more people can benefit from these vital programs.
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Positions and Publications
Medicare Savings Program Recertification
Medicare Savings Program recertification varies widely nationwide. This case study compares two experiences—one with automatic recertification and one with a more complex process—to illustrate the need for nationwide Medicare Savings Program recertification improvements.
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Positions and Publications
Medicaid Renewal
Renewing Aged, Blind, and Disabled Medicaid is necessary to maintain benefits. This case study contrasts a complicated renewal process with one eased by COVID-19 public health emergency flexibilities, arguing for lasting reforms in Medicaid renewal procedures.
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Positions and Publications
Medicare-Medicaid Integration
Coordinating benefits and services for dually eligible individuals is often complex and disjointed. This study examines the challenges of poorly integrated care and offers recommendations for improving integration at both state and federal levels.
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Comments
2025 Outpatient Prospective Payment System
Our comments focus on the important proposals in support of formerly incarcerated individuals. We appreciate the Centers for Medicare & Medicaid Services (CMS) working to ensure Medicare payment and enrollment rules align with the lived experiences of this population and their responsibility for their own health care costs.
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Comments
2025 Physician Fee Schedule
As science and medicine progress, they reveal the interconnectedness of bodily systems and expose the folly of historic silos in care. We greatly appreciate the Centers for Medicare & Medicaid Services (CMS) focusing on mental health and substance use disorder treatment and to medically necessary dental services.
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Letters
Letter Asking House Ways and Means Committee to Revisit Recent Medicare Bills
On June 27, the U.S. House Committee on Ways and Means advanced several bipartisan bills intended to improve Medicare coverage and affordability. While Medicare Rights applauds this important goal, we are concerned that several of the bills run counter to it. As outlined in the letter, we urged lawmakers to correct those misalignments.
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Positions and Publications
Medicare Reforms in the Inflation Reduction Act
The Inflation Reduction Act (IRA) of 2022 made key changes in Medicare law and coverage to improve prescription drug affordability for older adults and people with disabilities. Since its passage, some stakeholders and lawmakers have targeted IRA policies for revision or repeal, especially the law’s Medicare Drug Price Negotiation Program. Depending on the provisions targeted, this would increase beneficiary costs and increase Medicare spending.
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Positions and Publications
Medicare Private Contracting
Some policies would give Medicare providers the right to charge beneficiaries more for care than is currently allowed through balance billing or private contracting arrangements. Under Medicare private contracting, providers could charge their Medicare patients more than they currently pay or require them to negotiate a contract for the cost of their care.
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Positions and Publications
Medicare Means Testing
A core component of Medicare is its universality. Some policy ideas would undermine that promise by limiting certain benefits to people with lower incomes or requiring those with higher incomes to pay more for care. Means testing any portion of Medicare would add administrative complexity and access barriers.
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Positions and Publications
Raising the Medicare Eligibility Age
A commonly discussed reform would raise the Medicare eligibility age from 65 to 67 or even 70. This would reduce access to care and disproportionately harm some who can least afford it, including people who work in physically demanding jobs and older adults of color.
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Positions and Publications
Medicare Premium Support
Proposals to turn Medicare into a premium support system, also called a defined contribution system or a voucher program, are evergreen. Such programs would give people with Medicare a voucher or coupon worth a certain amount toward the purchase of health coverage. If the voucher did not cover the full cost, the person would presumably have to pay the rest or go without coverage.
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Positions and Publications
Affordable Care Act Coverage Expansions and Consumer Protections
The Affordable Care Act (ACA) strengthened Medicare and Medicaid and created important coverage avenues and consumer protections for people of all ages. Despite these successes, the health law continues to face opposition from some policy corners in Congress, the states, and the courts. If repealed, people would lose protections, including free preventive services in Medicare.
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Positions and Publications
Medicaid Financing
Proposals to restructure Medicaid’s financing often recommend transforming the program from a guaranteed benefit to a fixed payment system, coupled with new limitations on costs or care. Such changes can put access to care at risk, especially for older adults and people with disabilities.
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Positions and Publications
Medicaid Waivers
Many states have expanded coverage and care through Medicaid 1115 waivers, but some have attempted to use them to limit eligibility or restrict coverage, which could prevent people from accessing needed care.
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Positions and Publications
Medicaid Work Requirements
State and federal support for conditioning Medicaid eligibility on compliance with monthly employment and reporting requirements persists, with strategies like 1115 waivers and statutory changes among the most prominently discussed. Such requirements create unnecessary barriers to care while increasing the administrative burden for enrollees and states.
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Comments
Comments on the Medicare Savings Program Application Redesign
Medicare Rights' comments are informed by our work helping thousands of people with Medicare apply for Medicare Savings Programs (MSPs). As the Centers for Medicare & Medicaid Services (CMS) has documented, MSP processes are notoriously confusing for applicants, as well as many advocates and eligibility workers.
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Comments
Health Care Consolidation Request for Information
Consolidation and market concentration impact many aspects of the U.S. health care system. Our response to the RFI focuses on the consequences for Medicare and its enrollees. We discuss opportunities for policymakers to better protect older adults, people with disabilities, and the range of public programs that support their access to care.
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Comments
Medicare Rights Center Response to Medicare Advantage Data Request for Information
It is evident Medicare Advantage (MA) enrollment and costs are growing, that access issues abound, and that transparency is long overdue. To ensure MA works well for those it is supposed to serve, the Medicare Rights Center urges the immediate and thorough collection and publication of additional data on (I) Equity, (II) Provider Directories and Networks, (III) Marketing, (IV) Utilization Management and Appeals, (V) Supplemental Benefits, (VI) Dually Eligible Individuals and D-SNPs, and (VII) Favorable Selection and Risk Adjustment. This information should be granular, regularly reported, and used to guide MA and program-wide improvements. CMS must finally hold plans accountable for the public dollars they use and the promises they make.
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Positions and Publications
Improving Integrated Care for the Dually Eligible: Policy Recommendations for New York
In 2022, the New York State Department of Health (NYSDOH) released its Dual Eligible Integrated Care Roadmap, which outlined the state’s many priorities for improving integrated care for those dually eligible for Medicare and Medicaid.[i] By promoting integrated care for duals, they hoped to improve health outcomes, enhance member satisfaction, and reduce costs. One of the most ambitious goals was a 250% increase in the number of dually eligible individuals receiving integrated care through an aligned contract—meaning that the individual’s Medicare and Medicaid benefits are provided by the same company—by the end of 2023. These aligned contracts include the state’s Integrated Benefits for Dually Eligible Enrollees (IB-Dual) program and Medicaid Advantage Plus (MAP) plans.
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Letters
Medicare Advantage 2025 Rate Announcement Sign-on Letter
The Medicare Rights Center joined 47 organizations representing people with Medicare, families, advocates, and providers in a letter thanking the U.S. Department of Health and Human Services for the improvements in the 2025 Medicare Advantage rate announcement and urging additional reforms to further improve plan accountability and payment accuracy.
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Statements & Testimony
Testimony: Legislative Proposals to Support Patient Access to Telehealth Services
Testimony of Frederic Riccardi, President Medicare Rights Center, on “Legislative Proposals to Support Patient Access to Telehealth Services” before the United States House of Representatives Committee on Energy & Commerce, Subcommittee on Health.
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Comments
Comments on the 2025 Advance Notice
The Medicare Rights Center welcomes CMS’s efforts to refine Medicare Advantage payment methodology and supports further action to improve costs and the beneficiary experience, program wide.
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Comments
Comments Supporting the Complete Rescission of the 2018 Association Health Plan Final Rule
The Medicare Rights Center (Medicare Rights) appreciates this opportunity to comment on the Proposed Rescission of the 2018 Association Health Plan Final Rule. We applaud this full rescission of the final 2018 Association Health Plan (AHP) rule. Though the rule was never fully implemented, this rescission will eliminate any uncertainty regarding applicable definitions and standards.
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Comments
Comments on Proposed Changes to Medicare Advantage and Part D for 2025
The Medicare Rights Center commented on the Contract Year 2025 Policy and Technical Changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, Medicare Cost Plan Program, and Programs of All-Inclusive Care for the Elderly proposed rule.
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Statements & Testimony
Statement for the Record on Medicare Advantage Marketing and the Enrollee Experience
The Medicare Rights Center submitted a statement for the record to the Senate Finance Committee regarding the October 18, 2023 hearing titled “Medicare Advantage Annual Enrollment: Cracking Down on Deceptive Practices and Improving Senior Experiences.”
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Medicare Prescription Payment Plan (MPPP) Draft Guidance
The Medicare Rights Center (Medicare Rights) appreciates this opportunity to comment on the Medicare Prescription Payment Plan (MPPP) draft guidance. Medicare Rights is a national, nonprofit organization that works to ensure access to affordable and equitable health care for older adults and people with disabilities through counseling and advocacy, educational programs, and public policy initiatives. Each year, Medicare Rights provides services and resources to over three million people with Medicare, family caregivers, and professionals.
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2022 Medicare Trends and Recommendations
In 2022, Medicare Rights staff and volunteers addressed more than 27,000 questions through its national helpline and professional email channels. Additionally, Medicare Rights’ free and independent online reference tool, Medicare Interactive (MI), provided more than 2.6 million answers for beneficiaries, their caregivers, and professionals. This report features the top helpline trends and highlights the most commonly sought helpline and Medicare Interactive answers, providing a glimpse into the various questions and needs of Medicare beneficiaries, caregivers, and the professionals assisting them in the community in 2022.
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Statements & Testimony
Statement for the Record on Medicare Revenues and Program Sustainability
The Medicare Rights Center submitted a statement for the record to the Senate Budget Committee regarding a September 27, 2023 hearing on opportunities to improve Medicare solvency through revenue changes. In our statement, we note that any efforts to bolster Medicare’s financing must maintain the program’s universality, safeguard current benefits and cost protections, and modernize coverage to meet the evolving, diverse, and whole-body needs of beneficiaries.
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Comments
Comments on 2024 Physician Fee Schedule
Medicare Rights comments on medically necessary dental and mental health and substance use disorder provisions in the 2024 Physician Fee Schedule.
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Comments
Comments on the Short-Term, Limited-Duration Insurance Proposed Rule
Medicare Rights comments in support of provisions in the Short-Term, Limited-Duration Insurance proposed rule.
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Comments
Comments on Health and Human Services Grants Regulation
Medicare Rights comments in support of the Health and Human Services Grants Regulation proposed rule.
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Positions and Publications
Increasing Access to Medicare Savings Programs: Lessons Learned and Policy Recommendations from New York
Last year, New York State passed a landmark budget that expanded income eligibility for Medicare Savings Programs (MSPs), a long-overdue reform that the Medicare Rights Center championed alongside partner organizations, with the goal of increasing health access and economic security. Upon taking effect in January 2023, this expansion immediately made around 300,000 additional New Yorkers eligible for MSPs, programs that help enrollees afford Medicare premiums and other costs, and lead to automatic enrollment in the federal Extra Help drug subsidy.
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Positions and Publications
Comparing Original Medicare and Medicare Advantage
Around half of people with Medicare get their health coverage from Original Medicare and the other half from Medicare Advantage, also known as a Medicare private health plan or Part C. Individual needs, preferences, and priorities typically guide these enrollment choices. This fact sheet outlines key considerations beneficiaries often keep in mind when deciding between the two coverage pathways.
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Positions and Publications
Medicare Advantage History: Legislative Milestones
Created in 1965, Medicare initially included Inpatient/Hospital insurance (Part A) and Outpatient/Medical insurance (Part B) and paid providers directly on a fee-for-service basis. The program has seen many legislative reforms over the years, including the addition of Medicare Advantage (Part C) in 1996. Although this change formally allowed enrollees to receive their Medicare benefits from a private insurance plan that contracts with the federal government, health plans have long played an important role in Medicare. In this fact sheet, we trace that evolution.
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Positions and Publications
The Beneficiary Experience with Medicare Advantage Enrollment and Access
Many people can struggle to choose a Medicare Advantage plan that best meets their needs. For both newly eligible enrollees and those re-evaluating their options, the plan comparison process can be complex and burdensome, undermining active, informed coverage choices. Once enrolled, these decisions and Medicare Advantage-specific features—such as restrictions on providers and barriers to services—may limit enrollee access to care in unanticipated and harmful ways. Learn more about the beneficiary experience with Medicare Advantage in this fact sheet.
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Positions and Publications
Payments to Medicare Advantage: The Methodology
Under Original Medicare, Medicare pays providers a fixed rate for each service rendered to enrollees. By contrast, Medicare pays private Medicare Advantage plans a fixed monthly rate for each enrollee; the plans then pay providers to deliver care. The Medicare Advantage payment rates are set annually through a complicated series of determinations and adjustments that have significant bearing on Medicare financing. In this fact sheet, we review those processes and impacts.
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Positions and Publications
The Overpayment Cycle: Payments to Medicare Advantage
Flaws in the Medicare Advantage payment formula yield inflated plan payments that grow with enrollment. Plans use these additional dollars to offer services Original Medicare does not cover. They heavily and successfully market these “supplemental benefits,” boosting enrollment and triggering even more overpayments. Plans invest those funds to attract more enrollees, and the cycle begins again. This fact sheet explains this harmful pattern and what it means for Medicare solvency.
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Positions and Publications
Promise and Pitfalls of Dual Eligible Special Needs Plans (D-SNPs)
Like other Medicare enrollees, people who are dually eligible for Medicare and Medicaid can choose to receive their Part A and Part B benefits through Original Medicare (OM) or from a private Medicare Advantage (MA) plan. Some who select MA may have access to a Dual Eligible Special Needs Plan (D-SNP) which is an MA plan exclusive to people enrolled in both programs. In this fact sheet we examine D-SNPs’ potential to improve integrated care and the beneficiary experience.
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Positions and Publications
Congress Must Streamline and Simplify Medicare Enrollment
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Statements & Testimony
Statement for the Record on Inaccurate Medicare Advantage Provider Directories
The Medicare Rights Center urges immediate action to address the long-standing problem of inaccurate MA provider directories. This misinformation derails thoughtful coverage choices and access to care. It also prevents proper oversight, as insufficient data may hide non-compliance with network adequacy and other requirements.
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Comments
Separate Licensing Standards for Relative or Kinship Foster Family Homes
These comments from the Medicare Rights Center are in support of separate licensing standards for relative or kinship foster family homes.
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Comments
Omitting Food From In-Kind Support and Maintenance Calculations
Medicare Rights comments in support of removing food from the calculation of in-kind benefits for Supplemental Security Income (SSI).
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Comments
The Medicare Drug Price Negotiation Program
Callers to our national helpline regularly report struggling to afford the prescription medications they need to maintain their health and well-being. The Inflation Reduction Act’s (IRA) Medicare Drug Price Negotiation Program could offer much-needed relief. In our comments, we offer recommendations to implement this program in a way that enhances affordability, ensures accuracy, and maximizes transparency.
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Comments
Interoperability and Prior Authorization Proposed Rule
The Medicare Rights Center (Medicare Rights) appreciates this opportunity to comment on the Advancing Interoperability and Improving Prior Authorization Processes proposed rule. Prior authorization is creating an ever-increasing burden on patients. We support many of the Centers for Medicare & Medicaid Services (CMS) provisions in this proposed rule that would reduce this burden by improving processes, timelines, access to information, and communication.
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Comments
Proposed Coverage of Power Seat Elevation Equipment
Medicare Rights applauds CMS for proposing to extend Medicare coverage of power seat elevation. This feature is critical to promoting beneficiary health, safety, and independence.
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Comments
Part D Medicare Prescription Drug Inflation Rebate Program
The Inflation Reduction Act’s (IRA) Rebate Program will require drug companies to pay a rebate if they raise certain Part D drug prices faster than inflation, reining in the industry practice of sky-high annual price adjustments. This deterrent will strengthen beneficiary and program finances.
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Comments
Part B Medicare Prescription Drug Inflation Rebate Program
The Inflation Reduction Act’s (IRA) Rebate Program will require drug companies to pay a rebate if they raise certain Part B drug prices faster than inflation, reining in the industry practice of sky-high annual price adjustments. This deterrent will strengthen beneficiary and program finances.
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Comments
Comments on the Conscience Proposed Rule
The Medicare Rights Center appreciates this opportunity to comment on the Safeguarding the Rights of Conscience as Protected by Federal Statutes proposed rule. We applaud this proposal by the Department of Health and Human Services (HHS) to rescind the most damaging aspects of the 2019 final rule Protecting Statutory Conscience Rights in Health Care; Delegations of Authority.
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Comments
Comments on the 2024 Advance Notice
Medicare Rights strongly supports the proposals in the Advance Notice (AN) that would improve Medicare Advantage (MA) payment accuracy. Modest but important, these changes would begin to correct the decades-long problem of MA overpayments.
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Comments
Social Security Administration Learning Agenda Request for Information
Medicare enrollment can be a difficult and daunting task. Year after year, among our most frequent helpline calls are from or on behalf of people trying to navigate this confusing system. Missteps are common and have serious repercussions—yet few remedies exist. As part of its Learning Agenda, we encourage the Social Security Administration (SSA) to explore ways to prevent and cure Medicare enrollment errors, including by examining gaps in consumer education, enrollment outreach, and data collection.
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Positions and Publications
Medicare Coverage Gaps: Care Inside the Home and DME in the Community
Medicare does not cover most long-term services and supports (LTSS) or durable medical equipment for use outside of the home. While home health should be more widely available, beneficiaries often find coverage inaccessible because of information gaps and onerous requirements, and the benefit is not integrated into other care and supports that people need in their homes. This results in patchworks of coverage that are difficult to manage, confusing and inefficient.
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Positions and Publications
Medicare and Health Equity
Medicare eligibility translates into meaningful gains in health equity. But the COVID-19 pandemic in particular has demonstrated that racial, ethnic, gender, LGBTQ+ status, disability status, and income disparities in health outcomes and access to care remain.
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Positions and Publications
Filling Gaps in Medicare Coverage: Dental, Vision, and Hearing
Medicare does not cover many of the essential services that older adults and people with disabilities need in order to live healthy lives. In addition to the direct impacts in terms of beneficiary well-being, gaps in access to these services can bring on or worsen other health concerns. Furthermore, this lack of coverage puts Medicare out-of-step with most private insurance and Medicaid which reflect a more modern understanding of patient needs and the interconnected nature of the human body.
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Positions and Publications
Simplifying Medicare Advantage Enrollment
The proliferation of Medicare Advantage (MA) plans and the variation across plans makes enrollment decisions based on a beneficiary’s individual circumstances overly complex, resulting in sub-optimal choices or unwillingness to shop for coverage.
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Positions and Publications
Improving the Effectiveness of Extra Help for Prescription Drugs
Medicare’s Low-Income Subsidy (LIS) program (also called “Extra Help”) can be a lifeline, helping low- and moderate-income beneficiaries pay for coverage they would not otherwise be able to afford. But aspects of the program are woefully outdated, making it difficult for low- and moderate-income beneficiaries to access the help they need.
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Positions and Publications
Improving Access to Extra Help for Prescription Drugs
Current Medicare policies expose low- and moderate-income beneficiaries to excessive out-of-pocket costs. For those who qualify, the Low-Income Subsidy(LIS) program (also called “Extra Help”) can be a lifeline, helping them pay for Medicare coverage they would not otherwise be able to afford. But accessing this program presents challenges of its own. The application process is complex and fragmented, and the eligibility requirements are woefully outdated. As a result, many who need this assistance aren’t able to get it.
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Positions and Publications
Medicare Part D Appeals Problems and Options to Correct Them
The Medicare Part D appeals process is an essential safety valve, allowing access to needed prescription medications—such as those that are not on the plan’s formulary, or are subject to high cost sharing, when formulary or lower cost alternatives are not appropriate. However, Part D enrollees often struggle to successfully navigate this overly complex, multi-step, process, and it can also prove burdensome for pharmacists, plans, and prescribing physicians. This can result in delayed access to needed prescriptions, abandonment of prescribed medications, reduced adherence to treatment protocols, worse health outcomes, and higher costs for the patient and the Medicare program.
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Positions and Publications
Medicare Part B Enrollment: Pitfalls and Solutions
While most people newly eligible for Medicare are automatically enrolled in Part B—because they are collecting Social Security retirement benefits at or before age 65—a growing number are working later in life and deferring their Social Security benefits. Unlike those who are auto-enrolled, these individuals must make an active Medicare enrollment choice, taking into consideration specific timelines and existing coverage. If this transition is mismanaged, individuals new to Medicare may face lifetime late enrollment penalties, higher health care costs, gaps in coverage, and disruptions in care continuity.
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Positions and Publications
Medicare Coverage Gaps: The Need to Curb Beneficiary Out-of-Pocket Spending
Unlike most modern health insurance coverage, Original Medicare has no out-of-pocket maximum, exposing beneficiaries to limitless financial risk. While Medicare Advantage (MA) plans do include an out-of-pocket maximum in their benefit packages, the threshold is too high. This means people with high health care needs can be forced to make impossible choices between paying for rent, food, or their essential health care or medicines. Policies that cap out-of-pocket costs are already in place for the employer and individual markets, including Marketplace plans under the Affordable Care Act (ACA). People with Medicare must not be left behind.
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Positions and Publications
Medicare Hospital Outpatient and Observation Status: The Three-Day Stay Problem
Medicare benefits for skilled nursing facilities (SNFs) hinge on a complicated concept, the three-day rule. This rule requires beneficiaries to be hospital inpatients for three consecutive days before Medicare will cover SNF admittance. But Medicare beneficiaries needing hospital care often find themselves classified as “outpatients,” and/or in “Observation Status” rather than admitted as inpatients. Observation Status patients often receive care that is indistinguishable from the care provided to individuals who have been formally admitted as inpatients, and observation stays can last for several days. This penalizes patients who have no control over how they will be classified and makes the Medicare distinction between the two statuses illogical and punitive.
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Positions and Publications
Improving Medicare Savings Programs
Current Medicare policies expose low- and moderate-income beneficiaries to excessive out-of-pocket costs. For those who qualify, the Medicare Savings Programs (MSPs) can be a lifeline, helping them pay premiums and, in some cases, cost sharing for Medicare coverage they would not otherwise be able to afford. But the application process in most states is complex and burdensome, and the eligibility requirements leave far too many people who need this assistance unable to get it.
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Positions and Publications
Access to Medicare Supplemental Insurance Policies (Medigaps)
While it is relatively easy for a Medicare beneficiary to enroll into and disenroll from a Medicare Advantage (MA) plan on an annual basis, there are limited windows of opportunity to join a Medigap plan. This means that people who want to switch from MA to traditional Medicare may not have the option for supplemental coverage they need, which may lock them into MA coverage. In order for Medicare beneficiaries to have true freedom of choice concerning their coverage options, Medigap plan access must be strengthened.
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Comments
Comments on Proposed Changes to Medicare Advantage and Part D for Contract Year 2024
The Medicare Rights Center comments on the Medicare Program; Contract Year 2024 Policy and Technical Changes proposed rule.
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Letters
Letter to CMS on Medicare Coverage of At-Home COVID-19 Tests
A letter from the Medicare Rights Center asking CMS to explore maintaining no-cost Medicare coverage of at-home COVID-19 tests beyond the public health emergency period.
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Comments
Comments on Streamlining Medicaid & MSP Applications Proposed Rule
Comments supporting changes to streamline Medicaid and MSP applications, determinations, and redeterminations.
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Comments
Temporary Increase in Federal Medical Assistance Percentage in Response to the COVID-19 Public Health Emergency
Medicare Rights comments in support of reverting the interpretation of Medicaid maintenance of effort to the original CMS interpretation.
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Letters
Letter in Support of House Ways & Means Markup of Mental Health Legislation
Access to behavioral health care is a significant, ongoing challenge for many people with Medicare. Swift legislative action is needed to address this, in ways that strengthen coverage and modernize services. Several of the bills to be considered at the September 21, 2022 Markup of Worker and Family Support and Health Legislation would advance these goals.
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Comments
Comments on the 2023 Physician Fee Schedule
Medicare Rights Center's comments on the medically necessary dental and expanded access to behavioral health providers topics in the 2023 Physician Fee Schedule.
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Comments
Medicare Advantage Request for Information
Medicare Rights appreciates the opportunity to comment on CMS's Request for Information (RFI) on Medicare Advantage (MA). In our response, we offer suggestions and recommendations to improve the program, based on our direct experience helping MA enrollees navigate their coverage and access needed care.
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Positions and Publications
Principles of Medicare Parity
Principles for Medicare coverage parity for substance use disorder and behavioral health.
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Letters
Letter to Congressional Leaders on Improving Medicare Coverage of Substance Use Disorder and Mental Health Care
Letter to the Senate Finance and House Ways and Means Committee leaders urging them to take action to improve Medicare coverage for people with substance use disorder and mental health needs.
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Comments
Comments on CAA/BENES Act Proposed Rule
Comments on the enrollment changes made by BENES Act provisions and other matters.
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Positions and Publications
2020-2021 Medicare Trends and Recommendations
This report features select helpline trends and highlights the most commonly sought helpline and Medicare Interactive answers, providing a glimpse into the information and coverage needs of Medicare beneficiaries and their families in 2020 and 2021.
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Letters
Letter to US Senators on Home and Community-Based Services
This letter expresses Medicare Rights' strong and unified support for including a robust investment in Medicaid Home and Community-Based Services (HCBS) in the next legislative package.
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Letters
Joint Letter on Medicare Enrollment and the PHE Unwinding
In a letter to CMS, the Medicare Rights Center and other leading beneficiary advocacy groups share concerns about the Medicare-related impacts of unwinding of the Public Health Emergency (PHE) and outline administrative solutions.
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Comments
Comments on the 2023 Advance Notice
Comments on the Advance Notice of Methodological Changes for Calendar Year (CY) 2023 for Medicare Advantage (MA) Capitation Rates and Part C and Part D Payment Policies
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Comments
Comments on 2023 C&D Rule
Comments on the 2023 C&D rule: Medicare Program; Contract Year 2023 Policy and Technical Changes to the Medicare Advantage and Medicare Prescription Drug Benefit Programs.
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Positions and Publications
Community Statement on Medicare Coverage for Medically Necessary Oral and Dental Health Therapies
Statement from advocacy, medical, and dental organizations showing the need for coverage for medically necessary oral and dental care in Medicare.
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Letters
Letter to Senators Urging Drug Pricing Reform
Medicare Rights joined over 90 groups to urge US Senators to pass drug pricing reforms through reconciliation.
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Comments
Comments on the 2023 Notice of Benefit and Payment Parameters
We provided comments on the 2023 Notice of Benefit and Payment Parameters for Affordable Care Act Marketplace plans.
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Letters
Advocacy Organizations Urge Better Medicare Coverage of COVID-19 Services
Join letter to the Department of Health & Human Services (HHS) and the Centers for Medicare & Medicaid Services (CMS) from 67 advocacy organizations urging better Medicare coverage of COVID-19 services, including at-home testing.
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Comments
Comments on Revocation of Georgia 1332 Medicaid Waiver
We provided comments supporting CMS revoking the Georgia 1332 Medicaid waiver which would eliminate access to HealthCare.gov for Georgia residents.
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Positions and Publications
Medicare Savings Programs in New York State: <br/>Policy Recommendations from the Medicare Rights Center
The COVID-19 public health emergency (PHE) and the resultant economic fallout has highlighted longstanding barriers affecting Medicare beneficiaries, older adults and people with disabilities, especially individuals with low incomes and people of color. However, the pandemic has also provided an opportunity to address these challenges with renewed purpose and vigor. It is imperative that New York State act to support older adults and people with disabilities by continuing to invest in state and local programs that meaningfully improve health and economic well-being.
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Comments
Comments on the 2022 Physician Fee Schedule
Comments on the Physician Fee Schedule for 2022 which extends a glidepath for temporary telehealth services until the end of 2023 and makes permanent certain audio-only mental health and substance use disorder telehealth services.
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Comments
Home Health Comments
Home health is a valuable and necessary benefit that can help people with Medicare live safely in their homes and communities. But far too many beneficiaries lack meaningful access to needed services. Often, this is due to due to misaligned financial incentives that make serving people with chronic conditions who are not expected to improve less profitable than delivering short-term care to people who are recovering from illness or injury. We are concerned the proposed rule could exacerbate this dynamic.
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Comments
Comments on Updating Payment Parameters Proposed Rule
Comments on the Updating Payment Parameters proposed rule that would make changes to ACA marketplace enrollment, assistance, and standards.
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Positions and Publications
Improving Access to Medicare Coverage Act
The Improving Access to Medicare Coverage Act of 2021 (H.R. 3650/S. 2048) would count the time Medicare beneficiaries spend in the hospital under “observation” status toward the three-day stay requirement for SNF coverage, improving access to critical, needed care.
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Letters
Joint Letter on Medicare Improvements
Medicare Rights and other leading beneficiary advocate groups urged the Administration and Congress to keep improvements to the Medicare program central in ongoing discussions about creating a more equitable and affordable health care and prescription drug system.
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Letters
Joint Letter on Medicaid HCBS
Medicare Rights joined over 150 leading advocacy organizations in calling on Congress to fully fund the $400 billion investment in Medicaid Home and Community Based Services (HCBS) requested by the Administration. This level of investment is essential for building a sustainable HCBS infrastructure system that can begin to address the magnitude of need in communities across the country, by both increasing access to Medicaid HCBS and addressing the direct care workforce crisis.
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Comments
Comments on the Office of Management and Budget Request for Information on Methods and Leading Practices for Advancing Equity and Support for Underserved Communities Through Government
The need to address equity has never been clearer. The COVID-19 pandemic, entrenched economic exploitation, rising income inequality, and violent and systemic racism must be a call to action to build new pathways to equity and justice. We are glad to see this RFI’s focus on ways to see, assess, and redress inequities throughout our governmental systems. Medicare has aided the country before as we attempted to move past the horrors of Jim Crow and other segregation and racial and ethnic barriers. But disparities persist, and more must be done to improve access to health care and coverage, build well-being, support dignity, and enhance economic stability for all.
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Comments
Comments on 2022 IPPS Proposed Rule
Comments on the proposed use of an indirect estimation algorithm for racial and ethnic demographics as well as a clarification of the requirement for states to enroll all Medicare-eligible providers for purposes of determining reimbursement.
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Comments
Comments on Changes to the HIPAA Proposed Rule
Comments on changes to the HIPAA proposed rule that would speed up individual access to records but create inappropriate laxity in some aspects of the rule.
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Statements & Testimony
Statement for the Record “Negotiating a Better Deal: Legislation to Lower the Cost of Prescription Drugs”
Immediate action is needed to transform the nation’s drug pricing system in ways that will lower prices, strengthen Medicare, and promote the well-being of those who rely on its coverage. H.R. 3 would significantly advance these goals, in part by authorizing Medicare to negotiate prices for certain drugs; imposing inflationary rebates; and restructuring Part D to cap beneficiary out-of-pocket costs at $2,000 per year, reduce the federal government’s liability, and better align pricing incentives.
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Comments
Comments on the HCBS Access Act Discussion Draft
If enacted, the HAA would greatly expand access to HCBS, helping people who need supports to stay in their communities, age in place, and live the lives they choose. The Medicaid program must be made more equitable and better meet the needs of those it serves. We are fully committed to this vision and offer the following suggestions to tweak the HAA to better achieve it.
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Comments
Comments on Interim Final Rule on MCIT and Definition of “Reasonable and Necessary” (CMS-3372-IFC)
The Medicare Rights Center (Medicare Rights) appreciates this additional opportunity to comment on the Medicare Program; Medicare Coverage of Innovative Technology (MCIT) and Definition of “Reasonable and Necessary”; Delay of Effective Date; Public Comment Period (CMS-3372-IFC) interim final rule. 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. Each year, Medicare Rights provides services and resources to nearly three million people with Medicare, family caregivers, and professionals. We reaffirm our support for ensuring greater access to appropriate innovative technologies and necessary care for people with Medicare.
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Statements & Testimony
Testimony: The Future of Telehealth: How COVID-19 is Changing the Delivery of Virtual Care
Testimony of Frederic Riccardi, President Medicare Rights Center, on “The Future of Telehealth: How COVID-19 is Changing the Delivery of Virtual Care” for the United States House of Representatives Committee on Energy & Commerce Subcommittee on Health.
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Letters
Letter Urging Biden Administration to Take Immediate Action on Key Issues Facing Medicare Beneficiaries
In a letter sent to the U.S. Department of Health and Human Services (HHS) Acting Secretary Norris Cochran, two leading Medicare beneficiary advocacy organizations, the Medicare Rights Center and the Center for Medicare Advocacy, urge the Biden Administration to take swift action to strengthen Medicare, Medicaid, and the Affordable Care Act. As outlined in the letter, matters requiring immediate attention include simplifying Medicare transitions during the COVID-19 public health emergency, enhancing Medicare outreach and enrollment strategies, and increasing regulatory review efforts. Looming deadlines and unmet needs make these improvements urgent.
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Letters
Letter From 50 Organizations Calling on CMS to Ease Medicare Enrollment During the COVID-19 Pandemic
The Medicare Rights Center and 49 state and national organizations urge the Centers for Medicare & Medicaid Services (CMS) to reinstate two policies to help people sign up for Medicare amid the COVID-19 pandemic: a Special Enrollment Period (SEP) for Part C and Part D and Equitable Relief for Premium Part A and Part B.
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Positions and Publications
Improving Medicare Assistance Programs: Easing Access to LIS
For those who qualify, the Low-Income Subsidy (LIS) program (also called “Extra Help”) can be a lifeline, helping them pay for Medicare coverage they would not otherwise be able to afford. But accessing this program presents challenges of its own. The application process is complex and fragmented, and the eligibility requirements are woefully outdated. As a result, many who need this assistance aren’t able to get it.
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Positions and Publications
Address Disparities and Inequities
Medicare Rights urges the administration to address disparities and inequities in order to improve health care and coverage for all. Medicare has long been a powerful tool to reduce injustice and inequality. The program played a pivotal role in “forc[ing] the desegregation of every hospital in America virtually overnight” and continues to offer coverage to all who qualify. But inequities remain. Every day, we see the destructive and persistent effects of institutionalized racism, individual bias, and systemic oppression. Medicare Rights welcomes the Biden administration’s commitment to addressing these problems directly, in ways that advance equity, justice, and access to care—including by strengthening Medicare, Medicaid, and the Affordable Care Act.
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Positions and Publications
Reduce Barriers to Care
The Biden administration must reduce barriers to care by making coverage more available, accessible, and affordable. On our Helpline, we frequently hear from older adults and people with disabilities who live on modest or limited incomes and are struggling to access and afford their care. These financial challenges—which have in many cases been worsened by the coronavirus pandemic—along with rising health care and prescription drug costs, antiquated coverage rules, and burdensome program requirements can make it difficult for older adults and people with disabilities to obtain the care they need. The following reforms would help reduce these barriers to care by making Medicare stronger, easier to navigate, and more affordable.
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Positions and Publications
Simplify Medicare Enrollment
Medicare Rights asks the Biden administration to simplify Medicare enrollment in order to ensure active, informed, and meaningful beneficiary choice. A rapidly aging population, complex Medicare rules and timelines, and an ever-evolving health ca landscape means a growing number of individuals will face increasingly difficult Medicare coverage decisions in the coming months and years. The Biden administration must act without delay to better empower current and future beneficiaries to make optimal choices, both initially and annually.
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Positions and Publications
Immediately Respond to COVID-19
The Medicare Rights Center encourages the Biden administration to immediately respond to COVID-19 in ways that prioritize older adults and people with disabilities. The COVID-19 pandemic and its attendant economic fallout will have a lasting impact on people with Medicare and on the program itself. While additional interventions may be necessary as the situation evolves, the administration must first focus on reforms that are urgently needed to help people with Medicare maintain their health, safety, and independence.
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Positions and Publications
Policy Recommendations for the Biden Administration
The Medicare Rights Center (Medicare Rights) looks forward to working with the Biden administration to advance policies that protect and strengthen Medicare as well as the health and economic well-being of those who rely on its coverage. To facilitate this dialogue, we respectfully submitted a set of recommended actions for President-Elect Biden and his transition team’s consideration. While the majority are administrative, some require external collaboration. We encourage the new administration to work with Members of Congress, state policymakers, and stakeholders to advance these and other solutions.
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Comments
Comments on the Fourth COVID Interim Final Rule
The Families First Coronavirus Response Act (FFCRA), signed into law on March 18, includes an option for states to receive enhanced federal Medicaid funding. In exchange for these additional funds, states must comply with certain maintenance of effort (MOE) protections. These policies are intended to help ensure individuals can access coverage and care during the COVID-19 public health emergency (PHE). Specifically, Section 6008b(3) of the FFCRA requires states to preserve then-current enrollments and benefits through the end of the PHE: “an individual who is enrolled for benefits under such plan (or waiver) as of the date of enactment shall be treated as eligible for such benefits through the end of the month in which such emergency period ends.”
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Comments
Comments on SUNSET rule
The COVID-19 public health emergency continues to demonstrate the need for reliable access to health care, especially for older adults and people with disabilities. The pandemic makes it crucial to protect Medicare’s ability to provide guaranteed coverage and meet the changing and urgent needs of the populations it serves. The Department of Health and Human Services (HHS) also must have the bandwidth to shift focus and respond quickly to immediate and emergent issues. Thousands of lives are at stake.
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Comments
Comments on Notice of Benefit and Payment Parameters for 2022
As the current COVID-19 public health emergency continues to reveal, the need for health care can arise at any moment and may be the difference between life and death. People without comprehensive health coverage may delay or forgo care, worsening their own and public health outcomes. Those who do seek treatment may face extreme financial hardships, impacting patient, program, and taxpayer costs.
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Positions and Publications
Summary of Policy Recommendations for the Biden Administration
The Medicare Rights Center (Medicare Rights) looks forward to working with the Biden administration to advance policies that protect and strengthen Medicare as well as the health and economic well-being of those who rely on its coverage. To facilitate this dialogue, we compiled a set of administrative actions for their consideration. We will also outline our legislative priorities for the 117th Congress.
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Comments
Comments on Medicare Coverage of Innovative Technology (MCIT) and Definition of “Reasonable and Necessary”
The Medicare Rights Center (Medicare Rights) appreciates this opportunity to comment on the Medicare Program; Medicare Coverage of Innovative Technology (MCIT) and Definition of “Reasonable and Necessary” (CMS–3372–P) proposed rule. 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. Each year, Medicare Rights provides services and resources to nearly three million people with Medicare, family caregivers, and professionals.
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Positions and Publications
What’s at Stake in the Affordable Care Act: A Voter Guide
During the 2020 election cycle, voters should pay attention to candidates’ statements about the ACA, including their stance on its elimination. In this document, we present a few ways the ACA has changed health coverage and what’s at stake if it is repealed or eliminated.
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Positions and Publications
What’s at Stake in Medicare: A Voter Guide
Medicare has been a lifeline for millions since its inception in 1965, but threats and uncertainties persist. To determine candidates’ views on Medicare, voters should monitor their statements and the positions they have taken. This is especially important in the 2020 elections, as recent years have seen legislative and regulatory efforts to rework the program, often in ways that would undermine beneficiary protections.
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Positions and Publications
What’s at Stake in Medicaid: A Voter Guide
For 2020, voters should pay close attention to candidates’ statements about Medicaid, including their vision for the future of the program. To help voters weigh in, this document outlines a few proposals to keep an eye out for that could transform the program for the worse.
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Positions and Publications
2018-2019 Medicare Trends and Recommendations
In 2018-2019, Medicare Rights staff and volunteers addressed more than 37,000 questions and issues through the organization’s national helpline. In addition, Medicare Rights’ free and independent online reference tool Medicare Interactive, designed to help older adults and people with disabilities navigate the complex world of health insurance, answered 6.1 million questions for people with Medicare, their caregivers, and professionals. This report will feature select helpline trends and highlight the most commonly sought Medicare Interactive answers, providing a glimpse into the information and coverage needs of Medicare beneficiaries and their families.
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Letters
Letter of Support for the Heroes Act
Medicare Rights is pleased to support the recently updated Heroes Act (H.R. 8406). It includes urgently-needed policy and program changes to better meet the unique needs of people with Medicare during and due to the COVID-19 pandemic.
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Comments
Comments on Georgia’s Proposed 1332 Waiver
Comments in opposition to approving Georgia's proposal to eliminate HealthCare.gov access for Georgians.
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Letters
Letter on Concerns About the Impact of USPS Operation Changes on Mail-Order Medication Delivery
Millions of people with Medicare currently rely on the U.S. Postal Service for timely delivery of their prescription medications. Any operational changes that result in delivery delays could put these individuals at risk. Such interruptions could hinder their access to needed therapies, potentially leading to the abandonment of medications, reduced adherence to treatment protocols, worse health outcomes, and higher costs.
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Comments
Comments on IRS Proposed Rule on “Certain Medical Care Arrangements”
Comments in opposition to reclassifying payments for health care sharing ministries as payments for medical insurance for tax purposes.
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Letters
Letter to Senate Leaders on COVID-19 Relief Priorities
We recognize the COVID-19 pandemic and its attendant economic downturn will have lasting impacts on people with Medicare and the program, and that additional policy solutions will be necessary as the situation evolves. In the next congressional relief package, however, we urge lawmakers to focus on reforms that are urgently needed to help people with Medicare maintain their health, safety, and independence during the crisis and beyond. To that end, in our July 29 letter we recommend specific strategies to improve Medicare enrollment; support beneficiary health, safety, and financial security; and strengthen Medicaid and other community living programs.
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Statements & Testimony
Joint Principles from the Center for Medicare Advocacy and the Medicare Rights Center: Medicare Expansion of Telehealth Helps Beneficiaries Access Care During the Pandemic–But Caution is Needed Before Making These Changes Permanent
As policymakers consider the post-pandemic Medicare telehealth landscape, the Medicare Rights Center and the Center for Medicare Advocacy offer our shared perspective on next steps. In these joint principles, we urge a cautious, thoughtful, and evidence-based approach that centers the unique and evolving needs of people with Medicare.
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Letters
BENES Act Letter of Support Signed by 106 Stakeholder Organizations
The undersigned organizations share a commitment to advancing the health and economic security of older adults, people with disabilities, their families, and caregivers. Together, we support and represent the 60 million Americans who rely on Medicare to access affordable, high-quality health care.
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Comments
Comments for the Telehealth Taskforce
Comments in response to the Taskforce on Telehealth Policy’s request for input from stakeholders.
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Letters
BENES Act Letter of Support from former CMS and HCFA Administrators
A July 9, 2020 letter of support for the BENES Act (S. 1280/H.R. 2477) signed by all ten former living Centers for Medicare & Medicaid Services (or Health Care Financing Administration) Administrators, Republicans and Democrats.
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Comments
Comments on the Second COVID-19 Interim Final Rule
Medicare Rights provided comments on the second Interim Final Rule with Comment that made changes to Medicare rules, payments, and reporting during the COVID-19 public health emergency.
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Comments
Comments on Oklahoma SoonerCare 2.0 1115 Waiver Application
The Medicare Rights Center (Medicare Rights) appreciates this opportunity to comment on Oklahoma’s Sooner Care 2.0 Medicaid Section 1115 Demonstration Waiver application. While we support state Medicaid expansions, we believe that the U.S. Department of Health and Human Services (HHS) should reject the Sooner Care 2.0 Demonstration application as being inaccurate, incomplete, outside of the scope of the Secretary’s authority, not in keeping with the purpose of Medicaid, and against the interests of the Medicaid population and program— as well as health systems and public health generally—in Oklahoma and nationally.
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Letters
Letter to CMS on Extending Medicare Enrollment Flexibilities
Medicare Rights and 40 leading advocacy organizations sent a letter to CMS, requesting extensions of several expiring enrollment flexibilities that are helping Medicare-eligible individuals connect with their coverage and care during the COVID-19 pandemic.
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Comments
Comments on Bipartisan Policy Center Integrated Care White Paper
The Medicare Rights Center (Medicare Rights) appreciates this opportunity to comment on the Bipartisan Policy Center’s white paper, “Policy Options for Integrating Care for Individuals with Both Medicare and Medicaid.”
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Comments
Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency
The novel coronavirus, “SARS-CoV-2,” has proven especially dangerous to populations that Medicare serves—people 65 years and older, people who live in a nursing home or long-term care facility, and people of all ages with serious underlying medical conditions, including those with permanent disabilities. Because of this, Medicare Rights greatly appreciates the efforts of the Centers for Medicare & Medicaid Services (CMS) to streamline and enhance Medicare coverage during the public health emergency (PHE).
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Comments
Comments on Advance Notice of Methodological Changes for Calendar Year (CY) 2021 for MedicareAdvantage (MA) Capitation Rates and Part C and Part D Payment Policies–Part II
Medicare Rights generally supports the transition of many of the provisions in this proposed rule from subregulatory guidance to notice-and-comment rulemaking. While we recognize that formal rulemaking can lack the flexibility and nimbleness of guidance, we believe that the standardization, transparency, and predictability of formal rulemaking makes it a more appropriate vehicle for most provisions that make significant changes to the Medicare program.
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Letters
Thank You Letter to SSA About Automatic Deposit of Stimulus Funds for SSA Recipients
On behalf of the Medicare Rights Center (Medicare Rights), thank you for clarifying that 2019 Social Security and Railroad Retirement beneficiaries do not have to file a federal tax return to receive the economic stimulus payment created by the Coronavirus Aid, Relief, and Economic Security (CARES) Act (P. L. 116-136).
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Letters
Letter to SSA About Automatic Deposit of Stimulus Funds for SSA Recipients
On behalf of the Medicare Rights Center (Medicare Rights), I am writing today to urge you to immediately clarify that 2019 Social Security beneficiaries do not have to file a federal tax return to receive the economic stimulus payment created by the Coronavirus Aid, Relief, and Economic Security (CARES) Act (P. L. 116-136).
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Comments
D-SNP Fast Complaint and Appeal Decision Comments
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Letters
Letter to CMS About COVID-19 Requests
On behalf of the Medicare Rights Center (Medicare Rights), thank you for your agency’s efforts to respond to the COVID-19 emergency. As this work continues, we write today to respectfully request several improvements to the Medicare enrollment process that are urgently needed to better facilitate access to coverage and care during this challenging time.
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Letters
Letter to Congress About COVID-19 Requests
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Positions and Publications
Improving Medicare Assistance Programs: Making LIS More Effective
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Comments
Comments on CMS-4190-P: Medicare and Medicaid Programs Contract Year 2021 and 2022
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Comments
Comments on Draft Update to Manual For State Payment of Medicare Premiums
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Comments
Substance Use Disorders and Report to Congress
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Comments
Ensuring Equal Treatment of Faith-Based Organizations
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Comments
Rules Regarding the Frequency and Notice of Continuing Disability Reviews
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Comments
Medicaid Program; Medicaid Fiscal Accountability Regulation
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Comments
Comments: Advance Beneficiary Notice of Noncoverage
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Statements & Testimony
House Testimony: “Legislation to Improve Americans’ Health Care Coverage and Outcomes”
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Comments
Comments: OIG Anit-Kickback Statute
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Comments
Comments: TennCare Demonstration, Amendment 42
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Comments
Comments: Nondiscrimination requirements for HHS grantees
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Comments
Comments: CMS Applicable Integrated Plan Coverage Decision Letter
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Comments
Oncology Care First Model: Informal Request for Information
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Letters
Elijah E. Cummings Lower Drug Costs Now Act (H.R. 3) Letter of Support
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Comments
Supplemental Nutrition Assistance Program: Standardization of State Heating and Cooling Standard Utility Allowances Comments
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Letters
Letter of Support for the Lower Drug Costs Now Act of 2019
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Comments
Comments: Revision of Categorical Eligibility in the Supplemental Nutrition Assistance Program
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Letters
Letter to CMS Time-limited Equitable Relief
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Comments
Comments: 2019 Medicare Plan Finder Review
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Comments
Medicare Program; Specialty Care Models to Improve Quality of Care and Reduce Expenditures
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Letters
Joint Letter to U.S. House on Part D Reforms
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Positions and Publications
Why New York Should Simplify Medical Bills and Improve Health Care Price Look-Up Tools
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Comments
Comments: Nondiscrimination in Health and Health Education Programs or Activities
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Comments
Request for Information: Reducing Administrative Burden to put Patients over Paperwork
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Positions and Publications
Case Study: Streamlining Part D Appeals Process Act
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Positions and Publications
Congress Must Streamline the Medicare Part D Prescription Drug Appeals Process
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Statements & Testimony
Statement for the Record: “Open Executive Session to Consider an Original Bill Entitled the Prescription Drug Pricing Reduction Act of 2019”
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Letters
Joint Sign-on Letter: Part D Improvements
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Letters
Joint Sign-on Letter: BENES Act
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Letters
BETTER Act Endorsement
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Comments
Comments: Consumer Inflation Measures Produced by Federal Statistical Agencies
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Statements & Testimony
Statement for the Record Senate Health, Education and Labor Committee Full Committee Hearing Lower Health Care Costs Act
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Statements & Testimony
Statement for the Record Energy & Commerce Health Subcommittee Hearing “No More Surprises: Protecting Patients from Surprise Medical Bills”
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Letters
Joint Letter: Introduction of H.R. 2073 and S.110
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Letters
Letter: Draft Medicare Part D Legislation
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Letters
Letter: Help Committee Bipartisan Legislation to Reduce Health Care Costs
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Comments
Comments: Proposed Interoperability and Patient Access Rule
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Comments
Comments: Direct Contracting—Geographic Population-Based Payment Model Option
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Statements & Testimony
Statement for the Record House Ways and Means Health Subcommittee Hearing “Protecting Patients from Surprise Medical Bills”
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Positions and Publications
Protect & Strengthen: ACA Coverage Protections
The Affordable Care Act (ACA) strengthened Medicare and Medicaid and created important coverage avenues and consumer protections for people of all ages. Despite these successes, the health law remains under attack in Congress, the states, and the courts.
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Comments
Comments: Part D Rebate Safe Harbor
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Comments
Comments: 2020 Final Medicare Communications and Marketing Guidelines
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Positions and Publications
2017 Medicare Trends and Recommendations
In 2017, Medicare Rights staff and volunteers addressed more than 15,000 questions and issues through the organization’s national helpline. In addition, over 2.8 million questions were answered for people with Medicare, their caregivers, and professionals serving them through Medicare Interactive, Medicare Rights’ free and independent online reference tool thoughtfully designed to help older adults and people with disabilities navigate the complex world of health insurance. This report will feature select helpline trends and highlight the most commonly searched for Medicare Interactive answers, providing a glimpse into the information and coverage needs of Medicare beneficiaries and their families.
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Comments
Comments: 2020 Call Letter
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Letters
LCAO Letter to Senate HELP Committee
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Comments
Comments: HHS Notice of Benefit and Payment Parameters for 2020
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Comments
Comments: Accrediting Organizations Conflict of Interest and Consulting Services RFI
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Comments
Joint Comments: Request for Information on Modifying HIPAA Rules to Improve Coordinate Care
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Comments
Comments: Modernizing Part D and Medicare Advantage to Lower Drug Prices and Reduce Out-of-Pocket Expenses (CMS-4180-P)
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Comments
Comments: ACA Exchange Program Integrity (CMS9922-P)
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Comments
Comments on Proposed Changes to the Medicare Advantage, Medicare Fee-for-Service, and Medicare Prescription Drug Benefit Programs (CMS-4185-P)
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Comments
Comments: Advance Notice of Proposed Rulemaking: Medicare Program; International Pricing Index Model for Medicare Part B Drugs
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Comments
Comments: State Relief and Empowerment Waivers (1332 Waivers) Guidance
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Comments
Comments: Drug Pricing Transparency
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Comments
Comments in Response to Proposed Rulemaking: Inadmissibility on Public Charge Grounds
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Comments
Comments: Medicare and Medicaid Programs; Regulatory Provisions to Promote Program Efficiency, Transparency, and Burden Reduction
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Comments
Comments: Medicare Anti-Kickback Statute and Beneficiary Inducements CMP Request for Information
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Comments
Comments: “Healthy Michigan”
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Comments
Comments: Alabama Medicaid Workforce Initiative
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Comments
Comments: Medicare Program; Medicare Shared Savings Program; Accountable Care Organizations–Pathways to Success
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Comments
Comments: 2019 Final Medicare Communications and Marketing Guidelines (MCMG)
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Letters
Letter to CMS RE: Final 2019 Medicare and You Handbook
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Letters
Letter to CMS Re: Extension of Relief Opportunity for Marketplace Enrollees
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Comments
Comments: 2019 Physician Fee Schedule
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Comments
Comments: CY 2019 Changes to the End-Stage Renal Disease (ESRD) Prospective Payment System, Quality Incentive Program, Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) CMS-1691-P
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Letters
Letter to Congress Re: Changes to the Part D Coverage Gap
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Comments
Comments: Kentucky HEALTH
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Comments
Comments: Mississippi Medicaid Workforce Training Initiative
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Letters
Letter to Congress Affirming Our Commitment to Maintaining the Bipartisan Budget Act (Bba) of 2018’s Part D Donut Hole Reforms
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Comments
Comments: HHS Blueprint to Lower Drug Prices and Reduce Out-of-Pocket Costs
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Comments
Comments: Request for Information on Direct Provider Contracting Models
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Letters
Letter to CMS Re Inaccuracies in the Draft Medicare & You Handbook for 2019
-
Comments
Comments: 2019 Medicare Advantage Marketing Materials
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Letters
Letter to Congress: Certain Provisions in the FY18 Omnibus Appropriations Bill
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Letters
Letter in Support for the Medicare Beneficiary Opioid Addiction Treatment Act (S. 2704)
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Letters
Letter: Opposition to H.J. Res. 2
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Positions and Publications
2016 Medicare Trends and Recommendations:
In 2016, the Medicare Rights Center’s (Medicare Rights) staff and helpline volunteers fielded more than 16,758 questions and issues through the organization’s National Consumer Helpline. Clients included Medicare beneficiaries, families, and caregivers across the country. As in previous years, clients were geographically and socioeconomically diverse, and needed help with a wide array of complex Medicare-related issues.
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Analysis of the Bipartisan Budget Act of 2018
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Comments
Advance Notice of Methodological Changes for Calendar Year (CY) 2019 for Medicare Advantage (MA) Capitation Rates, Part C and Part D Payment Policies and 2019 Call Letter
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Comments
Comments on Promoting Healthcare Choice and Competition Across the United States
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Comments
Comments on proposed changes to the Medicare Advantage, Medicare Fee-for-Service, and the Medicare Prescription Drug Benefit programs (CMS-4182-P)
-
Comments
Comments on Draft Strategic Plan FY 2018-2022
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Comments
Comments on Medicare Program: Cancellation of Advancing Care Coordination through Episode Payment and Cardiac Rehabilitation Incentive Payment Models; Changes to Comprehensive Care for Joint Replacement Payment Model (CMS-5524-P)
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Positions and Publications
Medicare Snapshot: Stories from the Helpline
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Comments
Comments on “Medicare Red Tape Relief Project”
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Positions and Publications
New York’s Health System Transformation
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Comments
Comments on Affordable Care Act: Reducing Regulatory Burdens and Improving Health Care Choices to Empower Patients
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Comments
Comments on CMS “Welcome to Medicare” Packages
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Comments
Comments to Seema Verma Suggesting Improvements to Parts C and D
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Comments
Comments on Patient Protection and Affordable Care Act; Market Stabilization (CMS-9929-P)
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Comments
Comments on Advance Notice of Methodological Changes for Calendar Year (CY) 2018 for Medicare Advantage (MA) Capitation Rates, Part C and Part D Payment Policies and 2018 Call Letter
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Positions and Publications
2015 Medicare Trends and Recommendations:
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Comments
Comments on Conditions for Coverage for End-Stage Renal Disease Facilities Third Party Payment (CMS-3337-IFC)
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Comments
Comments on Enhancements to the Star Ratings for 2018 and Beyond
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Medicare Snapshot: Stories from the Helpline
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Comments
Comments on Affordable Care Act; HHS Notice of Benefit and Payment Parameters for 2018 (CMS–9934–P)
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Comments
Comments on Inappropriate Steering of Individuals Eligible for or Receiving Medicare and Medicaid Benefits to Individual Market Plans
-
Comments
Comments on Payment Policies under the Physician Fee Schedule
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Comments
Comments on the Proposed Medicare Changes (HHS-2015-49)
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Statements & Testimony
Part B Drug Payment Model Testimony
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Comments
Comments on the Proposed Part B Drug Payment Model
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Comments
Comments in Response to Senate Finance Committee Chronic Care Working Group Proposals
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Positions and Publications
2014 Medicare Trends and Recommendations
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Comments
Comments on the proposed Revisions to Requirements for Discharge Planning
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Comments
Comments on Medicare-Medicaid Plan Quality Ratings Strategy
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Letters
Sign-on Letter for Notice of Benefit and Payment Parameters for 2017
-
Comments
Comments on Notice of Benefit and Payment Parameters for 2017
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Comments on Alternative Payment Model (APM) Framework, Draft White Paper
-
Comments
Comments on the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA)
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Letters
Letter of Support for Medicare Prescription Drug Savings and Choice Act of 2015 (S. 1884 & H.R. 3261)
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Letters
Letter of Support for Medicare Prescription Drug Price Negotiation Act of 2015 (S. 31 & H.R. 3061)
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Letters
Response to Senate Finance Committee’s Request for Input on Chronic Care Policies
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White House Conference on Aging Comment Letter
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Letters
Letter of Support for DME Competitive Bidding Program
-
Letters
2015 Medicare Drug Savings Act Letter of Support to U.S. House
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Letters
2015 Medicare Drug Savings Act Letter of Support to U.S. Senate
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Positions and Publications
Medicare Snapshot: Stories from the Helpline
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Letters
Response to House legislative package to repeal and replace the Sustainable Growth Rate (SGR) formula (H.R. 2)
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Positions and Publications
FIDA Toolkit for New York City and Nassau County Health Care Providers
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Letters
Sign-on Letter: Draft 2016 Part C and Part D Call Letter
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Comments
Medicare Rights Feedback on CMS 2016 Part C and Part D Call Letter
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Positions and Publications
2013 Medicare Trends and Recommendations
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Positions and Publications
Medicare Part B Enrollment: Pitfalls, Problems and Penalties
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Positions and Publications
Health Reform and Medicare: The Doughnut Hole in 2015
-
Positions and Publications
Medicare Snapshot: Stories from the Helpline
-
Positions and Publications
How Medicare is Affected by the Overturn of the Defense of Marriage Act (DOMA)
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Statements & Testimony
Hearing on the Future of Medicare Advantage Health Plans
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Positions and Publications
A Winning Strategy for Medicare Savings: Better Prices on Prescription Drugs
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Positions and Publications
New York’s Medicare Marketplace Update
-
Statements & Testimony
Messing with Success: How CMS’ Attack on the Part D Program Will Increase Costs and Reduce Choices for Seniors
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Positions and Publications
2012 Medicare Trends and Recommendations
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Statements & Testimony
Medicare Advantage: What Beneficiaries Should Expect Under the President’s Health Care Plan
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Positions and Publications
Health Reform and Medicare: Closing the Doughnut Hole
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Positions and Publications
Build on What Works: Medicare Cost Savers
-
Positions and Publications
The Affordable Care Act: Before and After
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Statements & Testimony
10 Years Later: A Look at the Medicare Prescription Drug Program
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Statements & Testimony
The President’s and Other Bipartisan Proposals to Reform Medicare
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Positions and Publications
Paying More for Less: More Medicare Cost Sharing
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Positions and Publications
Paying More for Less: Medigap Cost Sharing
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Positions and Publications
Paying More for Less: Premium Support
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Positions and Publications
Paying More for Less: Raising the Eligibility Age
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Positions and Publications
Medicare Facts and Faces: Refused at the Pharmacy Counter
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Positions and Publications
A Bridge to Health
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Positions and Publications
Medicare Voices: Celebrating 47 Years of Medicare
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Positions and Publications
New York’s Medicare Marketplace
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Positions and Publications
Deficit Reduction and Medicare President Obama’s Plan
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Positions and Publications
Painting a Grim Picture
-
Positions and Publications
Medicare Facts and Faces: Planning Ahead
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Positions and Publications
Medicare and Medicaid: Essential Partners
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Positions and Publications
Recertification in New York State
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Positions and Publications
Streamlining Medicare and QMB Enrollment for New Yorkers
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Positions and Publications
Questions and Answers on Medicare and Health Reform
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Positions and Publications
Medicare Facts and Faces: Why Consumers Disenroll from Medicare Private Health Plans
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Positions and Publications
Local Promise
-
Positions and Publications
Warning Signs: Preliminary Report Highlights Problems with State Implementation of MIPPA LowIncome Reforms
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