C-TAC regularly submits comments on proposed Centers for Medicare and Medicaid Services (CMS) regulations that impact people with serious illness and their family caregivers. CMS senior leadership have confirmed this is the best way to advocate on behalf of our issues with the Administration. C-TAC’s comments have been consistently acknowledged in final CMS regulations. Not only is CMS reading our comments, but they recognize their importance by mentioning them in the final rules.
Here are our latest acknowledged comments.
Final Hospice Rule for 2025 – CMS acknowledged many of the comments we submitted.
- Request for Information on Payment Mechanism for High Intensity Palliative Care Services – CMS received 60 comments on this request and acknowledged the following comments we and others made:
- A few commenters suggested that CMS should first avoid using “comfort care” interchangeably with “palliative care,” clearly distinguish between “hospice care” and “palliative care” and remove the term “palliative” altogether and replace it with “high-cost therapies.”
Final Skilled Nursing Facility (SNF) Rule for 2025 – All but one of our comments were acknowledged:
- SNF QRP Quality Measure Concepts Under Consideration for Future Years — Request for Information
- One of these commenters supported the pain management concept but also encouraged CMS to use the Centers for Disease Control and Prevention (CDC) Clinical Practice Guideline for Prescribing Opioids for Pain as some SNF residents may appropriately need these medications, suggesting that there are key populations that should be excluded from any measures that could reduce their access to these medications.
- Another commenter recommended measures related to timely and appropriate referral to hospice, advance care planning, and palliative care access and utilization.
Response: We thank all the commenters for responding to this RFI. While we are not responding to specific comments in response to the RFI in this final rule, we will take this feedback into consideration for our future measure development efforts for the SNF QRP.
- Proposal To Collect Four New Items as Standardized Patient Assessment Data Elements
- Two commenters recommended that instead of collecting data on the proposed Living Situation assessment item, CMS should propose an item to collect information on financial insecurity. Both commenters stressed that financial insecurity underpins all the proposed SDOH items.
Response: We will consider this feedback as we evaluate future policy options.
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- Two commenters suggested that CMS consider assessing family caregiver burden as well as services delivery, the latter of which would capture whether referrals to appropriate services resulted in actual service delivery.
Response: We agree that it is important to understand family caregiver burden, service delivery, and the needs of residents with disabilities. As we continue to evaluate SDOH standardized patient assessment data elements and future policy options, we will consider this feedback.
Final Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals – Most of our comments were acknowledged here again including our support of the “Age Friendly Hospital Measure” and recommendations for future measures for this program:
- Another commenter suggested assessing family caregiver burden and whether referrals resulted in actual service delivery, both of which can be a factor in both the patient’s health and the use of emergency department visits or hospitalization.
- Commenters also recommended other measure concepts for development and inclusion in the LTCH QRP, including Advance Care Planning measure, palliative care access and utilization, and timely and appropriate referral to hospice.
Response: We thank all commenters for responding to this RFI. We will take this feedback into consideration regarding our future measure development efforts for the LTCH QRP.
C-TAC will continue to review proposed regulations and submit comments advocating for quality care for those with serious illness and their family caregivers.
