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NHC Comments on Negotiation Data Elements and Drug Price Negotiation Process for Initial Price Applicability Year 2027 under Sections 11001 and 11002 of the IRA ICR Forms

Putting Patients First Blog

The NHC appreciates CMS’ efforts to gather patient-centered data as part of this ICR and its commitment to making the process more relevant for patients and patient organizations. While we acknowledge these improvements, it is important to note that some aspects of the data collection process may remain challenging.

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NHC’s comments in response to the 2025 Notice of Benefit and Payment Parameters (NBPP)

Putting Patients First Blog

Making available more specific information about total costs and coverage will ensure that all consumers have comprehensive information to help them make smart health care decisions. These resources should aim to clarify insurance terms and concepts, aiding consumers in navigating the complexities of selecting a health plan.

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NHC Comments on Medicare Drug Price Negotiation Program: Draft Guidance, Implementation of Sections 1191 – 1198 of the Social Security Act for Initial Price Applicability Year 2027 and Manufacturer Effectuation of the Maximum Fair Price (MFP) in 2026 and 2027

Putting Patients First Blog

We believe that patient-centric engagement is essential to ensure that the negotiation process leads to outcomes that genuinely benefit patients. Patient Engagement The NHC recognizes and commends CMS’ willingness to improve the listening sessions and the data submission processes. Improving the Data Collection (ICR) Process.

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NHC Comments on Centers for Medicare & Medicaid Services (CMS) in response to the proposed rule Medicare and Medicaid Programs: Calendar Year 2025 Payment Policies under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies

Putting Patients First Blog

As these technologies become increasingly integral to patient care, it is essential for CMS to develop clear and consistent guidelines for the payment and coverage of AI-enabled services. Providing clear guidance, technical assistance, and streamlined processes can help facilitate the adoption of this innovative care model.

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NHC Comments on Centers for Medicare & Medicaid Services (CMS) in response to the CY 2025 OPPS proposed rule

Putting Patients First Blog

16 We encourage CMS to continue refining these data collection processes to ensure they capture meaningful and actionable information. We believe this process is crucial for adapting the payment system to evolving clinical practices and emerging medical technologies.