The Medicare Rights Center (Medicare Rights) is pleased to submit comments in response to the Interim Final Rule with Comment: Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency (IFC). 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.
General comments
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). It is vital to find ways to ensure that people with Medicare can comply with public health guidelines, protecting themselves and others, while retaining access to necessary medical treatment and evaluation.
We recognize that it may be appropriate to continue some of these policies beyond the current emergency period. We urge CMS to gather data and engage with stakeholders in order to identify such opportunities and to work with Congress, where necessary, to advance long-term solutions. This may include legislative and regulatory efforts to preserve those rule and waiver changes that expand access and lower barriers to needed care. But before this can begin in earnest, beneficiary-protective and oversight rules must be reinstated as soon as possible to ensure high quality care and services are being provided and to fight against fraud and abuse.
