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 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)