Here is a template comment letter in support of a new, important proposal from the Centers for Medicare & Medicaid Services. The proposed rule seeks to modernize and clarify federal fraud and abuse regulations in a manner that would remove key barriers to industry-led innovation in the delivery of more efficient and better coordinated health care. In essence, the proposed rule would allow more health care providers to engage in value-based arrangements (such as new arrangements between JFS agencies and other types of providers) without fear of violating now outdated fraud and abuse policies. It would also allow health care providers to employ new tools (such as incentives for patient adherence to treatment) to encourage greater care coordination, outreach and engagement with patients while maintaining strong protections for patients and programs.
Since the inception of JFNA’s Strategic Health Resource Center, they have long advocated for the expansion of value-based arrangements in health care, seeing this as a means to promote better, more efficient, and more coordinated health care while preserving patients’ interests and high quality health care. The Network believes that your agency may be interested in submitting similar comments in support of these important changes and, therefore, we have prepared this template letter as well as these easy to follow instructions on how to submit a comment letter online. Please feel free to contact Elizabeth A. Cullen, J.D., M.P.A., Counsel, Health Policy, Strategic Health Resource Center, JFNA if you have any questions. The comment deadline is Tuesday, December 31, 2019.