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NHCOA Letter to CMS on Part B

June 1, 2020
Dear Administrator Verma:

We the undersigned organizations, representing both patients with serious illnesses and chronic diseases and their healthcare providers, write to ask for additional actions to ensure that patients are able to access the care they need during the COVID-19 pandemic. We appreciate the steps the Centers for Medicare and Medicaid Services (CMS) has already taken to expand access to care in home settings and we ask for additional flexibilities to ensure that providers and patients can make the care decisions most appropriate for individuals during this public health crisis.

We understand the difficulties of navigating medical treatment during these tenuous times in our country, and support taking the necessary steps to protect the lives of those individuals affected by the pandemic. In particular, we recognize that many at-risk populations are facing even more challenges right now and are struggling to access necessary medical treatment, including minority communities of color that are already disproportionately affected by the pandemic. Where reported, data across the country is showing higher infection and hospitalization rates amongst black, Hispanic, and Native American populations. We ask CMS to ensure that patients and providers have additional options for providing care in the most appropriate setting for patients during this public health emergency.

Specifically, we support allowing Medicare beneficiaries more options to receive physician administered Medicare Part B covered infused and injectable therapies in the home, when deemed the best course of treatment by their medical team. Medicare Part B is a critical program that helps provide beneficiaries with affordable treatments of chronic conditions such as: cancer, rheumatoid arthritis, osteoporosis, hypertension, Crohn’s disease, mental illness, and autoimmune diseases. Approximately 56.8 million seniors and individuals with disabilities rely on these services and are some of the sickest and most vulnerable Medicare beneficiaries, requiring highly personalized care, tailored around a specific treatment or combination of treatments that address their individual needs.

Furthermore, the current public health crisis has disproportionally impacted the health of older individuals and those with underlying comorbidities, making the Medicare-covered population especially vulnerable. In this current environment, some beneficiaries in need of treatment are now faced with the difficult decision to either forego essential therapies or treatment by staying home or potentially risk their own health by going to a hospital or physician’s office. This is especially true for individuals from communities of color, many of whom rely on public modes of transportation to go to and from their physician’s office.

The Centers for Medicare and Medicaid Services should expand its guidance to allow more flexibility for patients to receive in-home infusions and injections of therapies and treatments, at the direction of their physician and health care team. Without these additional flexibilities, reduced medication adherence could lead to deteriorating health for some of our most vulnerable Americans, while at the same time increasing risk of exposure to COVID-19. Expanding this guidance will allow for the continuity of care in a safe environment to help those most in need receive critical medical attention.

Sincerely,

National Hispanic Council on Aging

ADAP Advocacy Association
American Autoimmune Related Diseases Association
American Behcet’s Disease Association (ABDA)
Black Women’s Health Imperative
CaringKind
Casa Iris Housing Facility
Coalition of Texans with Disabilities
Community Access National Network (CANN)
DH/Perfil Latino TV, Inc.
Dia de la Mujer Latina
Diverse Elders Coalition
El Centro de la Raza
Epilepsy Alliance NC
Global Healthy Living Foundation
Global Liver Institute
HealthHIV
HealthyWomen
Hispanic Health Network
Kentuckiana Stroke Association
Latino Commission on AIDS
Latino Council
Lupus and Allied Diseases Association, Inc.
Lupus Foundation of America
NAACP
National Association of Hispanic Nurses
National Association of Nutrition and Aging Services Programs (NANASP) National Coalition for LGBT Health
National Infusion Center Association
National Minority Quality ForumNational Partnership for Women & Families

New Jersey Association of Mental Health and Addiction Agencies Prevent Blindness
Rain Total Care, Inc.
RetireSafe
Rocky Mountain Stroke Center
Senior Care Options, Inc.
Vida Senior Center