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DPC Submits Comments on Market Stabilization

2020-03-21T20:43:09+00:00March 9th, 2017|Categories: Comment Letter, Transportation Services|

A recent proposed rule released by the Centers for Medicare & Medicaid Services (CMS) provided guidance for market stabilization of the Affordable Care Act.  Within this proposed rule, network adequacy provisions for dialysis clinics provided a narrow scope for insurers. In comments submitted by DPC on March 6, we argued stronger time and distance criteria need to be added to these provisions. Research shows there is little difference between living in a metropolitan area compared to living in a rural environment, but there are significant mortality risks associated with actual distance from a dialysis facility. Additionally, after only 15 minutes of [...]

Re: CMS-3337-IFC: Medicare Program; Conditions for Coverage for End-Stage Renal Disease Facilities—Third Party Payment

2020-03-21T20:43:10+00:00January 10th, 2017|Categories: Charitable Premium Assistance, Comment Letter|

Re: CMS-3337-IFC: Medicare Program; Conditions for Coverage for End-Stage Renal Disease Facilities--Third Party Payment To whom it may concern: Dialysis Patient Citizens (DPC) writes to offer its comments on the above referenced interim final rule. We are requesting that the Agency withdraw the rule and follow the notice-and-comment rulemaking process prescribed by the Administrative Procedures Act (APA). We explain below why this unusual regulatory action reached an incorrect result. DPC's membership is restricted to kidney disease patients and their family members. We have more than 28,000 total members. DPC is a patient-led organization. Its by-laws require that the President, Vice [...]

Patient Group Comments to CMS re: Request for Information on Insurance Steering

2020-03-21T20:44:12+00:00September 22nd, 2016|Categories: Charitable Premium Assistance, Comment Letter|

Andy Slavitt Acting Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services 200 Independence Avenue, SW Washington, DC 20201 RE: CMS-6074-NC: “Inappropriate Steering of Individuals Eligible for or Receiving Medicare and Medicaid Benefits to Individual Market Plans” Dear Acting Administrator Slavitt: On behalf of the dialysis patients we represent, the American Kidney Fund (AKF), Dialysis Patient Citizens (DPC), and the National Kidney Foundation (NKF) appreciate the opportunity to provide comments on the Request for Information entitled “Inappropriate Steering of Individuals Eligible for or Receiving Medicare and Medicaid Benefits to Individual Market Plans” (RFI). More specifically, we are [...]

Comments to CMS re: Request for Information on Insurance Steering

2020-03-21T20:44:12+00:00September 20th, 2016|Categories: Charitable Premium Assistance, Comment Letter, Innovation|

Andrew Slavitt, Acting Administrator Centers for Medicare and Medicaid Services Department of Health and Human Services Hubert H. Humphrey Building 200 Independence Avenue, SW Washington, D.C. 20201 Re: CMS-6074-NC: “Request for Information: Inappropriate Steering of Individuals Eligible for or Receiving Medicare and Medicaid Benefits” Dear Mr. Slavitt: Dialysis Patient Citizens (DPC) responds herein to the Centers for Medicare and Medicaid Services (CMS) with comments on the above referenced Request for Information. As America’s largest patient-led organization representing dialysis patients, DPC’s membership consists of more than 28,000 dialysis and pre-dialysis patients and their families. We seek to ensure the patient point [...]

CMS-1651-P, Prospective Payment System and QIP

2020-11-25T21:20:29+00:00August 23rd, 2016|Categories: Comment Letter, Quality Incentive Program|

Andrew Slavitt, Acting Administrator Centers for Medicare and Medicaid Services Department of Health and Human Services Hubert H. Humphrey Building 200 Independence Avenue, SW Washington, D.C. 20201 Re: CMS-1651-P: End-Stage Renal Disease Prospective Payment System, Quality Incentive Program Dear Mr. Slavitt: Dialysis Patient Citizens (DPC) appreciates the opportunity to provide the Centers for Medicare and Medicaid Services (CMS) with comments on the proposed payment rule for the Medicare End Stage Renal Disease (ESRD) program. As America’s largest patient-led organization representing dialysis patients, DPC’s membership consists of more than 28,000 dialysis and pre-dialysis patients and their families. We seek to ensure [...]

DPC Complaint to OFM re: Washington State Insurance Plans

2022-08-05T22:12:59+00:00July 19th, 2016|Categories: Charitable Premium Assistance, Comment Letter, Innovation, Private Insurance Coverage, State Advocacy|

Re: Violations of the Medicare Secondary Payer Statute, 42 U.S.C. § 1395y(b), by Washington State Health Insurance Plans Dear Ms. Parker and Ms. Dotzel: We write to bring to your attention the fact that at least three group insurers in the state of Washington are offering large plans with provisions that violate the explicit terms of the Medicare Secondary Payer Statute. These violations not only potentially subject the insurers to statutory civil monetary penalties, but render these insurers’ plans nonconforming under applicable regulations. As America's largest patient-led organization representing 29,000 dialysis patients and family members, Dialysis Patient Citizens (DPC) strives to [...]

DPC Complaint to Department of Labor re: Insurance Plan Discrimination

2022-08-05T22:14:28+00:00June 28th, 2016|Categories: Charitable Premium Assistance, Comment Letter, Innovation, Private Insurance Coverage|

The Honorable Phyllis C. Borzi Assistant Secretary Employee Benefits Security Administration United States Department of Labor 200 Constitution Ave NW Washington, DC 20210 Re: Violations of Part 7 of the Employee Retirement Income Security Act Relating to Health Plans’ Treatment of End-Stage Renal Disease Dear Assistant Secretary Borzi: On behalf of the 29,000 dialysis patients and family members that we serve, Dialysis Patient Citizens (DPC) asks that the Employee Benefits Security Administration (EBSA) investigate activities some group health plans have undertaken that we believe discriminate against individuals with kidney failure in violation of Part 7 of the Employee Retirement Income Security [...]

Re: Discrimination Against End-Stage Renal Disease Patients by Health Net

2022-08-05T22:16:42+00:00May 3rd, 2016|Categories: Charitable Premium Assistance, Comment Letter, Private Insurance Coverage, State Advocacy|

Janice Rocco California Department of Insurance 300 Capitol Mall Suite 1700 Sacramento, CA 95814 Mary Watanabe Department of Managed Health Care (DMHC) 980 9th Street, Suite 500 Sacramento, CA 95814 Re: Discrimination against end-stage renal disease patients by Health Net Dear Deputy Commissioner Rocco and Deputy Director Watanabe: With 29,000 dialysis patient members, over 4,000 of whom reside in California, Dialysis Patient Citizens (DPC) is the nation’s largest patient-led organization representing individuals with end-stage renal disease (ESRD). On behalf of California’s 84,500 ESRD patients, I want to thank you for meeting with us to discuss the Health Net matter, which [...]

Proposed Changes to Dialysis Facility Compare Tool May Make It More Useful

2020-03-21T20:44:33+00:00March 16th, 2016|Categories: 5-Star Ratings, Article, Comment Letter|

Dialysis Facility Compare (DFC) is an online tool that allows users to search and compare dialysis facilities based on star ratings and certain measures. DPC has previously submitted suggestions on how to improve the proposed measures. Recently, the Centers for Medicare and Medicaid Services (CMS) announced in a Planned Changes document that the star ratings included in the DFC would be reassigned based on a 2014 threshold, meaning that the distribution of ratings would look more like it does on CMS’ other websites, and apply standards that are more familiar and intuitive to consumers. DPC submitted another comment letter (published [...]

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