C-TAC Comment Letters

Federal and Legislative Comment Letters

C-TAC comments on a number of proposed rules put forth by federal regulatory agencies. In addition, C-TAC engages with federal legislators to convey our position on a potential legislation that might impact people with serious illness and their caregivers. Below are recent letters from C-TAC to these bodies.

C-TAC 2026 Comment Letters

Comment Date
Comment Title

January 26, 2026

Re: Medicare Program; Contract Year 2027 Policy and Technical Changes to the Medicare Advantage (MA) Program, Medicare Prescription Drug Benefit Program, and Medicare Cost Plan Program

March 13, 2026

Re: Patient Protection and Affordable Care Act, HHS Notice of Benefit and Payment : Parameters for 2027; and Basic Health Program

March 30, 2026

Re: Request for Information (RFI) Related to Comprehensive Regulations To Uncover

May 27, 2026

Proposed Home and Community-based Services Measures

June 1, 2026

Proposed Hospice rule for FY2027

June 1, 2026

Advance Care Planning (ACP) requests for information in the proposed FY2027 Inpatient Rehab Facility and SNF rules

June 1, 2026

Medicare Program; FY 2027 Hospice Wage Index and Payment Rate Update and Hospice Quality Reporting Program Requirements

June 9, 2026

Re: Medicare Program; Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals (IPPS) and the Long-Term Care Hospital Prospective Payment System and Policy Changes and Fiscal Year (FY) 2027 Rates; Requirements for Quality Programs; and Other Policy Changes

June 15, 2026

Re: Medicare and Medicaid Programs; Patient Protection and Affordable Care Act; Interoperability Standards and Prior Authorization for Drugs for Medicare Advantage Organizations, Medicaid Managed Care Plans, State Medicaid Agencies, Children’s Health Insurance Program (CHIP) Agencies and CHIP Managed Care Entities, and Issuers of Qualified Health Plans on the Federally-Facilitated Exchanges

July 13, 2026

Proposed Rule on Federal Financial Assistance / 2 CFR Part 200

July 13, 2026

Request for Information (RFI); Comprehensive Review of the Essential Health Benefits Framework and Typical Employer Plan Standard

C-TAC 2025 Comment Letters

Comment Date
Comment Title

March 18, 2025

Re: Special Registrations for Telemedicine and Limited State Telemedicine Registrations

September 12, 2025

Re: Medicare and Medicaid Programs; CY 2026 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies; Medicare Shared Savings Program Requirements; and Medicare Prescription Drug Inflation Rebate Program (CMS-1832-P)

C-TAC 2024 Comment Letters

Comment Date
Comment Title

January 2, 2024

Re: Medicare Program; Contract Year 2025 Policy and Technical Changes to the Medicare Advantage (MA) Program, Medicare Prescription Drug Benefit Program, Medicare Cost Plan Program, and Programs of All-Inclusive Care for the Elderly; Health Information Technology Standards and Implementation Specifications

February 20, 2024

Re: Medicare Appeal Rights for Certain Changes in Patient Status

February 29, 2024

Re: Advance Notice of Methodological Changes for Calendar Year (CY) 2025 for Medicare Advantage (MA) Capitation Rates and Part C and Part D Payment Policies

April 10, 2024

Re: Medicare Program; Strengthening Oversight of Accrediting Organizations (AOs) and Preventing AO Conflict of Interest, and Related Provisions

April 25, 2024

Re: Developing and Implementing Performance Measures for Population-Based TCOC Models Request for Input (RFI)

May 6, 2024

Re: Request for Information (RFI) on Consolidation in Health Care Markets

May 28, 2024

Re: FY 2025 Hospice Wage Index and Payment Rate Update, Hospice Conditions of Participation Updates, and Hospice Quality Reporting Program Requirements

May 28, 2024

Re: Medicare Program; Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities; Updates to the Quality Reporting Program and Value-Based Purchasing Program for Federal Fiscal Year 2025

July 9, 2024

Re: Increasing Organ Transplant Access (IOTA) Model

July 10, 2024

Re: Addressing the Needs of Patients with Complex Chronic Conditions or Serious Illness Population-Based Total Cost of Care (PB-TCOC) Models (RFI)

July 22, 2024

Discussion Draft: Hospice Care Accountability, Reform, and Enforcement ( Hospice CARE) Act, Representative Blumenauer (D-OR-3rd)

August 20, 2024

Re: Medicare Program; End-Stage Renal Disease Prospective Payment System, Payment for Renal Dialysis Service Furnished to Individuals with Acute Kidney Injury, Conditions for Coverage for End-Stage Renal Disease Faciilities, End-Stage Renal Disease Quality Incentive Program, and End-Stage Renal Disease Treatment Choices Model

August 20, 2024

Re: Medicare Program; Calendar Year (CY) 2025 Home Health Perspective Payment System (HH PPS) Rate Update; HH Quality Reporting Program Requuirements; HH Value-Based Purchasing Expanded Model Requirements; Home Intravenous Immune Globulin (IVIG) Items and Services Rate Update; and Other Medicare Policies

September 9, 2024

Re: Medicare and Medicaid Programs; CY 2025 Payment Policies under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies; Medicare SHared Saving Program Requirements; Medicare Prescription Drug Inflation Rebate Program; and Medicare Overpayments

C-TAC 2023 Comment Letters

Comment Date
Comment Title

May 30, 2023

Re: Medicare Program; FY 2024 Hospice Wage Index and Payment Rate Update, Hospice Conditions of Participation Updates, Hospice Quality Reporting Program Requirements, and Hospice Certifying Physician Provider Enrollment Requirements

August 15, 2023

Re: Older Americans Act: Grants to State and Community Programs on Aging; Grants to Indian Tries for Support and Nutrition Services; Grants for Supportive and Nutritional Services to Older Hawaiian Natives; and Allotments for Vulnerable Elder Rights Protection Activities (ACL-RIN Number 0985-AA17)

August 17, 2023

Re: Request for Information; Episode-based Payment Model

September 11, 2023

Re: Medicare and Medicaid Programs; CY 2024 Payment Policies under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies; Medicare Shared Savings Program Requirements; Medicare Advantage; Medicare and Medicaid Provide and Supplier Enrollment Policies; and Basic Health Program

December 1, 2023

Re: 2023 Serious Illness Measures under Consideration (MUC)