NCCS Policy Comments

Cancer Leadership Council recommendations on Essential Health Benefits Bulletin

February 3, 2012

The Cancer Leadership Council (CLC) urges that the Department of Health and Human Services (HHS) reconsider the approach to defining essential health benefits that is outlined in the bulletin and publish a notice of proposed rulemaking, with a 90-day comment period, that would define a national minimum uniform set of benefits, permit states some flexibility to expand the minimum benefit package, provide clarity about state benefit mandates beyond 2015, and establish a transparent process for updating the minimum benefit package.

Essential Health Benefits Bulletin, issued by Center for Consumer Information and Insurance Oversight

February 2, 2012

In our comments, we offer some overarching recommendations regarding the proposed regulatory framework for defining EHB set forth in the bulletin and some specific comments on the details included within the bulletin. NCCS also looks forward to the opportunity to help the Department further refine its regulatory approach in this area.

Comments on Essential Health Benefits

December 6, 2011

NCCS has filed comments with the Secretary of Health and Human Services offering our advice on planned rules defining essential health benefits (EHB) under the Affordable Care Act. We have recommended that EHB should regard cancer as a chronic disease and that those diagnosed with cancer should receive care planning and coordination services.

Comments on ANPRM on Common Rule Revisions

October 26, 2011

NCCS has filed comments on proposed changes to the Common Rule which governs the consent process for those participating in clinical trials.

Comments on Summary of Benefits and Coverage

October 21, 2011

NCCS has filed comments on the proposed rule for a new Summary of Benefits and Coverage required by the health care reform law.

Comments on the Food and Drug Administration's Draft Guidance for Industry and Food and Drug Administration Staff: In Vitro Companion Diagnostic Devices

October 12, 2011

NCCS filed comments on the Food and Drug Administration's Draft Guidance for Industry and Food and Drug Administration Staff: In Vitro Companion Diagnostic Devices on October 12th, 2011. The Draft sets out a proposed framework for drug and test makers to use in developing targeted treatments and new tests to help identify patients most likely to benefit from a given treatment.

Comments on Proposed Rule on Establishment of Exchanges and Qualified Health Plans

September 22, 2011

NCCS filed comments with the Department of Health and Human Services, Centers for Medicare and Medicaid Services, on September 22, in response to the proposed rule on the establishment of health insurance exchanges and qualified health plans.

Comments on the proposed rule for the Medicare program Physician Fee Schedule

August 29, 2011

NCCS submitted comments to the Department of Health and Human Services, Centers for Medicare and Medicaid Services on the proposed rule for the Medicare program, relating to payment policies under the physician fee schedule and other revisions to Medicare Part D.

Comment on proposed regulations implementing a provision of the federal health care reform legislation

July 22, 2011

NCCS submitted a comment letter to the Centers for Medicare and Medicaid services regarding proposed interim final rules relating to patients’ ability to request review of health plan claims and coverage decisions—either from within the health plan or from an external third party.

Comments on ACO Proposed Rule

June 8, 2011

NCCS provides comments to the Centers for Medicare and Medicaid Services on its proposed rule for Accountable Care Organizations (ACOs) to be implemented under the Affordable Care Act. NCCS was especially pleased that the proposal included a heavy emphasis on patient-centered care and a requirement that ACOs identify high-risk individuals and develop individualized care plans for target patient populations.