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FAH Statement | Medicare | FAH Policy Blog Team

FAH Submits Comments in Response to MA Proposed Rule

Today, FAH submitted comments in response to a Proposed Rule from the Centers for Medicare & Medicaid Services (CMS) making changes to the Medicare Advantage (MA) program. The FAH letter addressed support for the following policies:

  • CMS’ implementation of provisions of the Bipartisan Budget Act of 2018 allowing MA plans to offer additional telehealth benefits as basic benefits while urging expanded access to telehealth services fee-for-service Medicare beneficiaries; and
  • CMS’ adoption of the modified Plan All-Cause Readmission measure, which includes observation stays in the calculation of the measure.  

The letter also recommended future regulatory action to address issues not included in the Proposed Rule:  

  • Ensuring that MA organizations (MAOs) reimburse contracted providers for their enrollees’ bad debt;
  • Addressing concerns with inaccurate provider directories and inadequate networks;
  • Ensuring providers and enrollees can rely on MAO prior authorizations;
  • Requiring MAOs to use the Medicare fee-for-service Two-Midnight Rule when reviewing inpatient admissions vs. observation stays; and
  • Requiring MAOs to follow the Medicare Inpatient-Only list to determine procedures that must be performed in an inpatient setting.

You can find the letter here.