Regulatory Comments/Rulings

National Patient Advocate Foundation actively supports regulatory proposals that improve access to healthcare. As part of its Federal Government Affairs Program, NPAF submits comments to Regulatory Agencies, including the Food and Drug Administration (FDA) and the Department of Health and Human Services (DHHS), in an effort to incorporate the patient voice in regulatory decisions.

 

NPAF Comments re: Patient Protection and Affordable Care Act; Exchange Functions: Standards for Navigators and Non-Navigator Assistance Personnel - May 2013

REAP Comments re: Patient Protection and Affordable Care Act; Exchange Functions: Standards for Navigators and Non-Navigator Assistance Personnel - May 2013

NPAF Comments re: Comments in Response to Advancing Interoperability and Health Information Exchange Request for Information - April 2013

NPAF Comments re: Re: Medicare Program; Medical Loss Ratio Requirements for the Medicare Advantage and the Medicare Prescription Drug Benefit Programs - April 2013

NPAF Comments re: Request for Comments on the Summary of Benefits Redesign for Medicare Advantage-Prescription Drug Plans - March 2013

NPAF Comments re: Drug Shortages Task Force and Strategic Plan; Request for Comments - March 2013

NPAF Comments re: Streamline Applications - February 2013

NPAF Comments re: Medicaid, Children’s Health Insurance Programs, and Exchanges - February 2013

REAP Comments Medicaid, Children’s Health Insurance Programs, and Exchanges. - February 2013

NPAF Comments on Framework for Pharmacy Compounding State and Federal Roles. - January 2013

NPAF Comment Letter on Part C&D Star Ratings. - January 2013

NPAF Comments: CMS-9980-P- Patient Protection and Affordable Care Act; Standards Related to Essential Health Benefits, Actuarial Value, and Accreditation. - December 2012

REAP Comments: CMS-9980-P- Patient Protection and Affordable Care Act; Standards Related to Essential Health Benefits, Actuarial Value, and Accreditation - December 2012

PCORI Draft Methodology Report - September 2012

 

CMS-1589-P- Hospital Outpatient Prospective and Ambulatory Surgical Center Payment Systems and Quality Reporting Programs; Electronic Reporting Pilot; Inpatient Rehabilitation Facilities Quality Reporting Program; Quality Improvement Organization Regulations - September 2012

 

NPAF Comments Re: CMS-1590-P- Revisions to Payment Policies under the Physician Fee Schedule, DME Face-to-Face Encounters, Elimination of the Requirement for Termination of Non-Random Prepayment Complex Medical Review and Other Revisions to Part B for CY 2013 - August 2012

 

NPAF Comments Re: Using Patient-Reported Outcomes in Registries Draft White Paper - July 2012

 

NPAF Comments Re: May 2, 2012 Open Letter on Medicare and Medicaid Waste, Fraud, and Abuse - June 2012

 

NPAF Comments Re: Nationwide Health Information Network: Conditions for Trusted Exchange - June 2012

 

NPAF Comments Re: May 16, 2012 General Guidance on Federally-facilitated Exchanges - June 2012

 

NPAF Comments Re: Oregon’s Selection of the State’s Essential Health Benefits Benchmark Plan - June 2012

 

NPAF Comments Re: Medicaid Program; Payments for Services Furnished by Certain Primary Care Physicians and Charges for Vaccine Administration Under the Vaccines for Children Program - June 2012

 

NPAF Comments Re: Modernizing the Regulation of Clinical Trials and Approaches to Good Clinical Practice - May 2012

 

REAP Comments re: Modernizing the Regulation of Clinical Trials and Approaches to Good Clinical Practice; Public Hearing; Request for Comments - May 2012

 

NPAF Comments re: Draft Guidance Relating to the Development of Biosimilar Products - May 2012

 

NPAF Comments re FDA Public Hearing on Draft Guidances Relating to the Development of Biosimilar Products - May  2012

 

REAP Comments re: Medicare and Medicaid Programs; Electronic Health Record Incentive Program— Stage 2 - May 2012

 

NPAF Comment re: Medicare and Medicaid Programs; Electronic Health Record Incentive Program— Stage 2 - May 2012

 

Interim Final Rule on the Medicaid Program; Eligibility Changes Under the Affordable Care Act of 2010 CMD-2349-F - May 2012

 

Using Innovative Technologies and Other Conditions of Safe Use To Expand Which Drug Products Can Be Considered Nonprescription - May 2012

 
 

Interim Final Rule On The Establishment Of Exchanges And Qualified Health Plans MS-9989-F - May 2012

Performance Measurement Coordination Strategy For PPS-Exempt Cancer HospitalsApril 2012

NPFA FDA Public Hearing on Modernizing the Regulation of Clinical Trials and Approaches to Good Clinical Practice   - April 2012

Performance Measurement Coordination Strategy for Hospice and Palliative Care - April 2012

Measuring Healthcare Quality For The Dual Eligible Beneficiary Population: Final Report To The Department Of Health And Human Services - april 2012

 

REAP FDA Public Hearing on Modernizing the Regulation of Clinical Trials and Approaches to Good Clinical Practice - April 2012

 

NPAF Comments re: Public-Private Partnerships for Patient Registries – Draft White Paper for Third Edition of “Registries for Evaluating Patient Outcomes: A User’s Guide - March 2012

 

NPAF Comments Re: Evaluation of Sex Differences in Medical Device Clinical Studies - March 2012

 

PCORI Comments on Draft National Priorities for Research and Research Agenda - March 2012

 

CMS Proposed Decision Memo for Transcatheter Aortic Valve Replacement (TAVR) - March 2012

 

Request for Measures and Domains To Use in Hospital Development of a Standardized Instrument For Use in Public Reporting of Family Experience of Pediatric Inpatient Care - February 2012

 

REAP Essential Health Benefits Bulletin Comment  Letter - January 2012

 

Request for Adjustment to the Medical Loss Ratio (MLR) for the State of Wisconsin - January 2012

 

Request for Adjustment to the Medical Loss Ratio (MLR) for the State of North Carolina - January 2012

 

Extension of Essential Health Benefits Bulletin Comment Deadline - January 2012

 

Request for Adjustment to the Medical Loss Ratio (MLR) for the State of Kansas – December 2011

 

Request for Adjustment to the Medical Loss Ratio (MLR) for the State of Texas – December 2011

 

Request for Adjustment to the Medical Loss Ratio (MLR) for the State of Oklahoma – December 2011

 

Proposed Changes to the Medicare Advantage and the Medicare Prescription Drug Benefit Programs for Contract Year 2013 – December 2011

 

NPAF Comments: Medicaid Program: Eligibility Changes under the Affordable Care Act of 2010 - October 2011

 

NPAF Comments: Exchange Functions in the Individual Market: Eligibility Determinations; Exchange Standards for Employees - October 2011

 

NPAF Comments: Health Insurance Premium Tax Credit - October 2011

 

NPAF Comments: Establishment of Exchanges and Qualified Health Plans CMS-9989-P - October 2011

 

REAP Comment Letter re: Establishment of Exchanges and  Qualified Health Plans Proposed Rules - October 2011 



NPAF
Comments Provided to HHS at Open Session on Consumer Advocates on Essential Health Benefits - October 2011



Summary of Benefits and Coverage and the Uniform Glossary
- October 2011



Hospital Outpatient Prospective Payment System Proposed Rule for CY 2012
 - August 2011



FDA Accelerated Approval Process
 - July 2011

 

Methods for Assuring Access to Covered Medicaid Services - July 2011

 

Opportunities for Alignment Under Medicaid and Medicare - July 2011

 

Methods for Assuring Access to Covered Medicaid Services - July 2011

 

Proposed Changes to the Hospital Inpatient Prospective Payment System for FY 2012 - June 2011

 

FDA_User_Fee_Program_for_Biosimilars - June 2011

 

Accountable Care Organizations - Waiver Designs - May 2011

 

Accountable Care Organizations - IRS Code - May 2011

 

Accountable Care Organizations - Antitrust Enforcement Policy - May 2011

 

Accountable Care Ogranizations - May 2011

 

Patient Notification of Right to Access State Survey - March 2011

 

Patient Notification of Medicare Medicaid LTC Closure - March 2011

 

Medicaid Community First Choice Option Program - March 2011

 

Revisions to Chapter 5 of the Medicare Managed Care Plan - March 2011

 

Value Based Insurance Design - February 2011

 

Rate Increase Disclosure and Review - February 2011

 

Revisions to the 2011 Medicare Marketing Guidelines - January 2011

 

Medical Loss Ratio Requirements under the ACA - January 2011

 

ODAC Regarding updates on new drug applications and biolgoics license applications - January 2011

 

Medicare Advantage and the Medicare Prescription Drug Benefit Program - January 2011

 

Requirements for Long Term Care Facilities; Hospice Services - December 2010

 

Parallel Review of Medical Products - December 2010

 

Request for Information Regarding ACOs and the Medicare Shared Savings Program - December 2010

 

Risk Evaluation and Mitigation Strategy (REMS) - August 2010

 

Revisions to Payment Policies Under the Physician Fee Schedule - August 2010

 

Hospital Outpatient Prospective Patient System - August 2010

 

Disclosure Policies of the U.S. Food and Drug Administration - July 2010

 

Erythropoietin Stimulating Agents (ESAs) for the Treatment of Chronic Kidney Disease (CKD) and Dialysis-related Anemia  -     - July 2010

 

Prescription Drug User Fee Act Reauthorization - May 2010

 

Erythropoiesis-Stimulating Agents (ESAs) in Anemia Related to Kidney Disease - February 2010