Recommendations on Deregulation Opportunities Submitted to HHS

HHS issued a Request for Information in May soliciting recommendations on specific regulations that should be eliminated "to lower healthcare costs, reduce burdens on physicians, and address the prevalence of chronic disease." The Alliance engaged its multiple workgroups to identify specific areas for inclusion and submitted to HHS a detailed chart of regulations with corresponding recommendations across specific guidance. These included recommendations to:

• Correct several problematic NCCI edits including Total Contact Cast (TCC)
• Revise Coverage w Evidence Development (CED) processes and the Transitional Coverage for Emerging Technologies (TCET) pathways – as they are cumbersome and do not achieve the desired results of bringing product to market faster.
• Remove burdens to the Medicare process for obtaining therapeutic shoes for patients with diabetes that currently creates unnecessary delays in care.
• Issue clear, enforceable guidance to Medicare Advantage Programs requiring that their coverage and documentation requirements align with, and are no more restrictive than, those established under Medicare Fee-for-Service (FFS) as is required in regulation.
• Update provisions for lymphedema compression treatment coverage to enable payment for clinicians to measure and fit lymphedema compression garments, and more...

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