TN

Document ID: CMS-2008-0033-0003
Document Type: Public Submission
Agency: Centers For Medicare & Medicaid Services
Received Date: April 25 2008, at 12:03 PM Eastern Daylight Time
Date Posted: May 16 2008, at 12:00 AM Eastern Standard Time
Comment Start Date: March 17 2008, at 12:00 AM Eastern Standard Time
Comment Due Date: May 16 2008, at 11:59 PM Eastern Standard Time
Tracking Number: 80533322
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This is comment on Proposed Rule

Medicare Program; Application of Certain Appeals Provisions to the Medicare Prescription Drug Appeals Process

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PARTICIPATION IN AN ALJ - proposed change to 423.2010(b) include a 1 day turn around time for plans to request to participate. We feel this timeframe is too tight to be met. Also, the expense required to meet this timeframe should be considered. In order to meet the 1 day timeframe in writing an express mail carrier would be required, which is more expensive than regular mail. SUBMITTING EVIDENCE BEFORE THE ALJ HEARING - proposed change to 423.2018(b) include a requirement for enrolleess to submit all written evidence with 2 days. This requirement would place undue financial and timeliness on elderly enrollees. For the segment of this population that is on fixed incomes and/or lack ready transporation, this would be a deterent to utilizing their appeal rights. DISMISSAL OF A REQUEST FOR HEARING BEFORE AN ALJ - proposed change to 423.2052(a)(2)(iii) include a requirement for enrolleess to submit all written evidence with 2 days. This requirement would place undue financial and timeliness on elderly enrollees. For the segment of this population that is on fixed incomes and/or lack ready transporation, this would be a deterent to utilizing their appeal rights.