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Alliance Comments & Analysis

As a quality organization, the Alliance is committed to communicating the role that home health care can play in health care delivery reform. To this end, the Alliance routinely provides regulatory comments and advisory letters to key departments of the U.S. Government.

Alliance Comments & Formal response Letters

Alliance Comments to RTI on Quality measures to satisfy the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act) domain of: Transfer of Health Information and Care Preferences When an Individual Transitions

Alliance Comments to Abt on Development of the Percent of Residents Experiencing One or More Falls with Major Injury During a Home Health Episode

Alliance Comments to CMS on Advancing Care Coordination Through Episode Payment Models (EPMs); Cardiac Rehabilitation Incentive Payment Model; and Changes to the Comprehensive Care for Joint Replacement Model (CJR)

Alliance Comments to RAND on IMPACT Act on Development and Maintenance of Post-Acute Care Cross-Setting Standardized Assessment Data

Alliance Comments to CMS on CY 2017 Home Health Prospective Payment System Rate Update; Home Health Value-Based Purchasing Model; and Home Health Quality Reporting Requirements

Alliance Comments to OMB on Pre-Claim Review 

Alliance Comments to NQF on the HCBS Interim Report June 2016

Alliance Comments to CMS on Medicare Prior Authorization of Home Health Services Demonstration

Alliance Comments to Acuman on MSPB Resource Use Measures

Alliance Comments to Senate Finance on Chronic Care Work Group Policy Options

Alliance Comments to CMS on Measures Under Consideration (2015)

Alliance Comments to RTI on Proposed Discharge to Community Measure

Alliance Comments to RTI on Potentially Preventable Readmissions for Post-Acute Care

Alliance Letter to CMS on ICD-10

Alliance Comments to Comprehensive Care for Joint Replacement Payment Model for Acute Care Hospitals Furnishing Lower Extremity Joint Replacement Services

Alliance Comments on the Proposed CMS Rule: CY 2016 Home Health Prospective Payment System Rate Update; Home Health Value-Based Purchasing Model; and Home Health Quality Reporting Requirements

Alliance Comments on Senate Finance Committee Chronic Condition Work Group

Alliance Comments on Proposed Rule, Medicare Program; Inpatient Rehabilitation Facility Prospective Payment System for Federal Fiscal Year 2016

Alliance Comments on the Proposed Rule, Medicare Program; Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities (SNFs) for FY 2016, SNF Value-Based Purchasing Program, SNF Quality Reporting Program, and Staffing Data Collection

Alliance Comments on ONC's Shared Nationwide Interoperability Roadmap

Alliance Comments on IMPACT Act of 2014 Implementation

Alliance Comments on Ad Hoc Measures Under Consideration for the IMPACT Act of 2014

Federal Health IT Strategic Plan 2015-2020

Proposed Rule on Medicare Shared Savings Program: Accountable Care Organizations

Alliance Comments on Home Health Compare Star Ratings

Alliance Comments on the Proposed Rulemaking on Conditions of Participation for Home Health Agencies: Revision of Requirements

Alliance Comments on the Proposed CMS Rule: Medicare and Medicaid Programs; CY 2015 Home Health Prospective Payment System Rate Update; Home Health Quality Reporting Requirements; and Survey and Enforcement Requirements for Home Health Agencies

Alliance Comments to House Ways and Means and Senate Finance on Discussion Draft on "Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act of 2014)

Alliance Comments to the Office of the National Coordinator on Voluntary 2015 Edition Electronic Health Record Certification Criteria: Interoperability Updates and Regulatory Improvements

Alliance Comments on the Office of the National Coordinator HIT Policy Committee Certification and Adoption Workgroup Certification for Long-Term and Post-Acute Care Virtual Hearing

Alliance Comments on American Nurses Association Request for Public Comment on the Draft Home Health Nursing: Scope and Standards of Practice

Alliance Comments to National Quality Forum on the Proposed CMS Measures Under Consideration

Alliance Comments on the Home Health Prospective Payment System Rate Update for CY 2014

Alliance Response to the Senate Finance Committee/House Ways & Means Letter to Post-Acute Care Providers

Alliance Comments on CMS' Proposed Home Health Quality Measures

Alliance Comments on the Proposed OIG Rule: Medicare and State Health Care Programs: Fraud and Abuse; Electronic Health Records Safe Harbor Under the Anti-Kickback Statute

Alliance Comments on the Proposed CMS Rule: Medicare Program; Physicians’ Referrals to Health Care Entities With Which They Have Financial Relationships: Exception for Certain Electronic Health Records Arrangements

Alliance Response to the Joint HHS/ONC Request for Information: Advancing Interoperability and Health Information Exchange

Alliance Response to the ONC Health IT Policy Committee Request for Comment on Meaningful Use Stage 3

Alliance Comments on the Home Health Prospective Payment System Rate Update for Calendar Year 2013

Alliance Comments on AHRQ's Request for Information on Quality Measurement Enabled by Health IT

Alliance Comments on ONC Proposed Rule for EHR Standards

Alliance Comments on Medicare Shared Savings Program: Accountable Care Organizations, Interim Final Rule

Alliance Comments on the Home Health Prospective Payment System Rate Update for CY 2012

Alliance Comments on Medicare Shared Savings Program: Accountable Care Organizations, Proposed Rule

Alliance Response to CMS/ONC Request for Information on Advancing Interoperability and Health Information Exchange

HOME AND COMMUNITY BASED SERVICES MEDICAID ANALYSIS

HCBS Waiver Expansion and Medicaid Nursing Home Spending: Implications, December 2012

Payment Concerns

Alliance Trend Report on Co-Payments (June 2011)

Formal Letters

Letter to Alan Simpson

Letter to Erskine Bowles