In the letter, CHA generally supported the policies included in the proposed rule. They would expand access to behavioral health and ensure that MA beneficiaries have access to the same benefits and services as patients with traditional Medicare.
CHA offered specific comments on proposals, including:
- Behavioral health specialties and services in MA networks
- MA network adequacy and access to services
- Utilization management requirements
- Termination of services in post-acute care
- Review of medical necessity decisions
- Identifying overpayments for Medicare Parts A, B, C, and D