The Alliance of Safety-Net Hospitals has submitted formal comments to the Centers for Medicare & Medicaid Services in response to selected aspects of that agency’s proposed rule calling for
contract year 2024 policy and technical changes in the Medicare Advantage program and other aspects of Medicare.
Among its comments, ASH expressed support for:
- requiring Medicare Advantage prior authorization denials to be made only by health care professionals with specific expertise in the medical fields in which they are making such decisions;
- adding clinical psychologists, licensed clinical social workers, and prescribers of medication for opioid use disorders to the list of specialists for which Medicare Advantage plans must meet network adequacy standards; and
- expanding the list of populations that Medicare Advantage plans must provide services to in a culturally competent manner to include, among others, people who live in rural areas and other areas with high levels of deprivation and who otherwise are adversely affected by persistent poverty or inequality.
The proposed regulation also calls for establishing care coordination programs, including coordination of
community, social, and behavioral health services, to help move toward parity between physical health and behavioral health services. While ASH expressed support for this requirement as well, it urged CMS to make Medicare Advantage plans responsible for its implementation, not providers, and to ensure that the process ultimately developed by those plans is not burdensome for providers.
Finally, to support CMS’s effort to address health equity, ASH urged CMS officials to consider ASH’s own proposal for introducing a new methodology for identifying community safety-net hospitals that play the greatest role in serving communities with the greatest health needs and providing them with new federal resources with which to carry out their vital work.
Go here to see ASH’s letter to CMS and here to see ASH “Proposal to Advance Health Equity.”
