The Arc and UCP joined the Consortium for Citizens with Disabilities (CCD) in commenting on two important issues that were addressed in the Affordable Care Act (ACA). The Centers on Medicare and Medicaid (CMS) had issued a Notice of Proposed Rulemaking on new requirements for accountability and transparency in the review and approval of Section 1115 demonstrations. Section 1115 demonstrations are used by states to test new ideas in Medicaid coverage. Individuals with disabilities have much at stake when changes to Medicaid policy are considered and there must be an opportunity for input by individuals with disabilities, their families, providers that support them, and other state and national advocates when the state and federal government are considering changes. See our comments at http://www.thearc.org/document.doc?id=2784
The CCD also responded to the National Committee for Quality Assurance’s (NCQA) request for comment on standards for the new Accountable Care Organizations (ACOs). NCQA is a private, not-for-profit organization that develops quality standards and performance measures for a broad range of health care entities. ACOs are a new way of organizing health care delivery to encourage cost savings and improved quality and access to care. CCD urged NCQA to require ACOs to link costs savings to patient outcome measures so that the system provides incentives to both improve the quality of care and patient outcomes while working toward better efficiencies. See http://www.thearc.org/document.doc?id=2789
UCP and The Arc also provided comments on proposed regulations implementing additional fraud screening requirements and other proposals to prevent and stop fraud by providers and suppliers in the Medicare and Medicaid programs. UCP and The Arc sought clarification on how affiliates and chapters who provide Medicaid services would be treated under the new rules and provided comments on the proposed new payment suspension provisions when there is an investigation of an allegation of fraud.