Position Statements & Comments

2012

• Comments on on Dec. 16, 2011, Essential Health Benefits Bulletin (Jan. 31, 2012)
• Comments on the proposed methodology for 2013 star ratings for Medicare Advantage plans and Prescription Drug plans (Jan. 13, 2012)
• Comments on the National Quality Forum's draft Multiple Chronic Conditions Measurement Framework (Jan. 13, 2012)

2011

• Comments on proposed changes to the Medicare Advantage and Medicare Prescription Drug Benefit Programs for 2013 (Dec. 12, 2011)
• Letter to Congress and the administration to preserve the Prevention and Public Health Fund (Dec. 1, 2011)
• Letter to Department of Health and Human Services on development of essential health benefits (Nov. 21, 2011)
• Comments on Food and Drug Administration Mobile Medical Applications draft guidance (Oct. 19, 2011)
• Comments on proposed rule for Standards Related to Reinsurance, Risk Corridors and Risk Adjustment in Health Insurance Exchanges (Sept. 28, 2011)
• Letter to Co-Chairs of Joint Select Committee on Deficit Reduction on Importance of Population Health Management (Sept. 26, 2011)
• Response to Proposed Rule on Changes to Medicare Part B of the 2012 Physician Fee Schedule (Aug. 30, 2011)
• Comments on Proposed Rule on the Medicare Shared Savings Program: Accountable Care Organizations (June 6, 2011)
• Comments on Proposed Rule for the Medicaid Program: Community First Choice Option (April 26, 2011)
• Comments: CMS Advance Notice of Methodological Changes for Calendar Year 2012 for Medicare Advantage (MA) Capitation Rates, Part C and Part D Payment Policies and 2012 Call Letter (March 4, 2011)
• Comments on Medicaid Program: Initial Core Set of Health Quality Measures for Medicaid Eligible-Adults (March 1, 2011)
• Response to the Request for Information Regarding Value-Based Insurance Design in Connection with Preventive Services (Feb. 28, 2011)
• Response to the HIT Policy Committee Meaningful Use Workgroup's Request for Comment on proposed Meaningful Use Stage 2 Objectives (Feb. 25, 2011)
• Support for Nurse Licensure Compact (Feb. 24, 2011)
• Comments on Interim Final Rule on Implementing Medical Loss Ratio (MLR) Requirements (Jan. 31, 2011)
• Comments on Proposed Changes to the Medicare Advantage and Medicare Prescription Drug Benefit Programs (Jan. 11, 2011)
• Response to Request for Information (RFI) on Development of Health Risk Assessment (HRA) Guidance (Jan. 03, 2011)

2010

• Comments on development of a National Health Care Quality Strategy and Plan (Oct. 15, 2010)
• Comments regarding coverage of preventive services under Affordable Care Act (Sept. 17, 2010)
• Comments on HIPAA and the HITECH Act (Sept. 13, 2010)
• Letter to National Association of Insurance Commissioners on medical loss ratio (Sept. 2, 2010)
• Letter to Department of Health and Human Services on medical loss ratio (Aug. 26, 2010)
• Comments on annual wellness visit benefit of Affordable Care Act (Aug. 24, 2010)
• Letter on Medicare Advantage Star Ratings (Aug. 20, 2010)
• Response to Request for Information on Development of an Inventory of Comparative Effectiveness Research (Aug. 9, 2010)
• Comments on draft federal framework on improving care for people with multiple chronic conditions (June 18, 2010)
• Letter to NAIC Health Reform Solvency Impact Subgroup on medical loss ratio definitions (June 15, 2010)
• Letter to National Association of Insurance Commissioners on medical loss ratio (May 25, 2010)
• Comments on Telephone Consumer Protection Proposed Rule (May 21, 2010)
• Response to Request for Information on medical loss ratio (May 14, 2010)
• Letter to National Association of Insurance Commissioners on medical loss ratio—Section 2718 of the Public Health Service Act (April 30, 2010)
• Letter to Sen. Rockefeller on medical loss ratio (April 21, 2010)
• Response to Task Force on Childhood Obesity Request for Information (March 26, 2010)
• Comments on Proposed Regulations for the Medicare and Medicaid Programs; Electronic Health Record Incentive Program (March 12, 2010)
• Comments on Genetic Information Nondiscrimination Act Interim Final Rules (Jan. 29, 2010)
• Letter to Congressional Leadership on Key Concepts for Health Care Reform (Jan. 29, 2010)
• Letter to Congressional Leadership on Medical Loss Ratio (Jan. 29, 2010)

2009

• Comments on the Genetic Information Nondiscrimination Act (GINA) Title I interim final rule (Dec. 3, 2009)
• Appeal to House, Senate Leadership for Greater Emphasis on Prevention, Chronic Disease Care Under System Reform (July 28, 2009)
• Letter Expressing Support for Extension of Medicare Advantage Special Needs Plan Authorization (July 16, 2009)
• Comments to HIT Policy Committee on Specific Priorities, Goals and Objectives in Meaningful Use Definition (June 26, 2009)
• Comments on Senate Finance Committee Policy Paper: Financing Comprehensive Health Care Reform: Proposed Health Systems Savings and Revenue Options (May 26, 2009)
• Comments on Senate Finance Committee Policy Paper: Expanding Health Care Coverage: Proposals to Provide Affordable Coverage to All Americans (May 22, 2009)
• Comments on Health Information Technology for Economic and Clinical Health (HITECH) Act Guidance (May 21, 2009)
• Comments on Senate Finance Committee Policy Paper: Transforming the Health Care Delivery System: Proposals to Improve Patient Care and Reduce Health Care Costs. (May 15, 2009)
• Letter to Senate leaders on privacy and security provisions in American Recovery and Reinvestment Act of 2009 (Jan. 28, 2009)

2008

• Principles for Health Care Reform (December 2008)
• Strategies and Processes for Population Health Improvement (August 2008)
• Policy and Technical Changes to Medicare Part D, Definitions: Morbid Obesity (June 26, 2008)
• Chronic Care Special Needs Plans, Recommendations for Reauthorization (June 2008)
• Medicare Improvements for Patients and Providers Act (June 11, 2008)
• Independence at Home Act (May 23, 2008)